Comment submitted by Robert Davis, Airgas

The proposed Protocol Gas Verification Program is important to maintain the integrity of EPA protocol gas quality. Historically we have seen that when there is no audit program the accuracy of the EPA protocol gases tends to drift industry wide. Such a program would insure that vendors are being held to a higher standard of accuracy as subscibed to in the" EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards ". The public information from the audit of EPA protocol gases in the PGVP would allow all users of EPA protocol gases more knowledge about different EPA protocol gas manufacturing locations. Without this program there could be further accuracy issues which would affect the quality of data for part 75 facilities reporting emissions.