SecProbe.io

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

      DIVISION OF
CORPORATION FINANCE

        February 20 , 2014

Via E -mail
M. Scott Crocco
Senior Vice President and Chief Financial  Officer
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown,  Pennsylvania 18195 -1501

 Re: Air Products and Chemicals, Inc.
  Form 10 -K for the Fiscal Year Ended September  30, 2013
  Filed November 26 , 2013
  File No. 1 -04534

Dear Mr. Crocco :

  We have limited our review of your filing to your contacts with a country that has  been
identified as a state sponsor  of terrorism, an d we have the following comment .  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we  are asking you to provide us with information so we may
better understand your disclosure.

  Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  I f you do not
believe our comment applies  to your facts and circumstances, please tell us why in your
response.

  After reviewing the information you provide in response to this comment , we may have
additional comments.

General
1. You stated in your letter  to us dated April 20, 2011 that your non -U.S. subsidiaries sold
products into Syria.  Syria is designated as a state sponsor of terrorism by the State
Department and is subject to U.S. economic sanctions and export controls.   Please tell us
about your con tacts with Syria since the referenced letter.   Your response should describe
any products or services you have provided into Syria, directly or indirectly, since the
referenced letter, and any agreements, arrangements, or other contacts you have had with
the government of Syria or entities it controls.

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of

M. Scott Crocco
Air Products and Chemicals, Inc.
February 20 , 2014
Page 2

 1934 and all appl icable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comm ents, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclos e
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202) 551 -
3470 if you have any questions about the comment  or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Pamela Long
  Assistant Director
 Division of Corporation Finance