SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

March 2, 2007

Via U.S. mail and facsimile

Mr. Paul E. Huck
Vice President and Chief Financial Officer
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, Pennsylvania 18195

 RE: Form 10-K for the fiscal year ended September 30, 2006
  Form 10-Q for the peri od ended December 31, 2006
   File No. 1-4534

Dear Mr. Huck:

  We have reviewed your response lett er dated February 26, 2007 and have the
following additional comments.  If you disagree with our comment, we will consider
your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as nece ssary in your explanation.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

  FORM 10-K FOR THE YEAR ENDED SEPTEMBER 30, 2006

General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

Mr. Paul E. Huck
March 2, 2007
Page 2 of 3
Financial Statements

Notes to the Financial Statements

Note 9.  Plant and Equipment, page 62

2. We note your response to prior comment 12.  You will provide additional disclosures regarding the useful lives of your production facilities by segment.  Please consider
also providing the corresponding amount of production facilities r ecorded by segment
to make this disclosure more meaningful.  Please also disclose th e useful lives of your
distribution equipment.

Note 19.  Commitments and Contingencies

Environmental, page 73

3. We note your response to prior comment 14.  You state that certain of the disclosures
previously requested and required by SA B Topic 5:Y have been provided in your
critical accounting policies.  Please provide  these disclosures in the notes to your
financial statements.  Please also provide disclosures in Note 19 regarding the Pace
facility, which should include the amounts accrued, reasonably likely losses, and the
current stage of the inves tigation and/or remediation.

FORM 10-Q FOR THE PERIOD ENDED DECEMBER 31, 2006

General

4. Please address the above comments in your interim filings as well.

*    *    *    *

  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly facilitate our review.  Please file your supplemental
response on EDGAR as a correspondence file .  Please understand that we may have
additional comments after reviewin g your responses to our comments.

Mr. Paul E. Huck
March 2, 2007
Page 3 of 3

If you have any questions regarding these comments, please direct them to Nudrat
Salik, Staff Accountant, at ( 202) 551-3692 or, in her absence,  to the undersigned at (202)
551-3769.

       S i n c e r e l y ,

       R u f u s  D e c k e r
       Accounting Branch Chief