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    Air Products and Chemicals Inc.

    Paul E. Huck

    7201 Hamilton Boulevard

    Sr. Vice President and

    Allentown, PA 18195-1501

    Chief Financial Officer

    Tel (610) 481-7932

    Fax (610) 481-7009

    e-mail: huckpe@airproducts.com

3 February 2010

Mr. John Hartz

Senior Assistant Chief Accountant

Securities and Exchange Commission

Division of Corporate Finance

Mail Stop 7010

100 F Street, N.E.

Washington, D.C. 20549

    RE:

    Air Products and Chemicals, Inc.

Form 10-K: For the Year Ended 30 September 2009

Form 10-Q: For the Quarterly Period Ended 31 December 2009

Dear Mr. Hartz:

In response to your letter of 27 January 2010, we provide the information below. Our
responses have been numbered to correspond with the comments in your letter. The original
comments, contained in your letter of 27 January 2010, have been included in italics for
reference during your review.

* * * * * * * * * *

Comment 1 — General

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.

Response:

In future filings, we will make the revisions described in our responses to your comments 2 through
10 as detailed below.

Comment 2 — Pasadena, Texas Facility, page 14

Tell us whether it is reasonably possible that losses related to the violations alleged at this
site could be material to your results of operations. If so, please explain the nature of the
allegations and whether aside
from any fines, you may be required to undertake material remediation, and/or capital expenditures
related to this issue.

Response:

Discussion of this matter was disclosed in Item 3, Legal Proceedings, as a result of the
requirements of Item 103 of Regulation S-K which requires disclosure of environmental
administrative proceedings involving a governmental authority unless the registrant believes that
such proceeding will result in no

monetary sanction, or in monetary sanctions, exclusive of
interest and costs, of less than $100,000. The losses related to the alleged violation are not
material to the Company’s results of operations.

Comment 3 — Selected Financial Data, page 16

You presented your cash provided by operating activities in the Other Data section. While
presentation of cash flows from operating activities is useful, this data should be considered in
the framework of a statement of cash flows, which reflects management’s decision as to the use of
these cash flows and the external sources of capital used. The implication of a presentation which
shows only the cash flows generated from operations portion of a cash flows statement is that the
use of such cash flows is entirely at the discretion of management. Please also present your cash
flows from investing and financing activities. See Section 202.03 of the SEC’s Codification of
Financial Reporting Policies for guidance.

Response:

In annual future filings, we will expand Item 6- Selected Financial Data to include cash used for
investing activities and cash provided by (used for) financing activities within the Other Data
section as underlined below.

    Revised
Disclosure:

    (Millions of dollars, except per share)

    2010

    2009

    2008

    2007

    2006

    Other Data

    Depreciation and Amortization

    $
    840

    $
    869

    $
    790

    $
    705

    Capital expenditures on a GAAP basis (C)

    1,236

    1,159

    1,553

    1,358

    Capital expenditures on a non-GAAP basis (C)

    1,475

    1,355

    1,635

    1,487

    Cash provided by operating activities

    1,323

    1,680

    1,500

    1,348

    Cash used for investing activities

    (1,040
    )

    (920
    )

    (1,483
    )

    (947
    )

    Cash provided by (used for) financing activities

    102

    (699
    )

    (15
    )

    (423
    )

    Dividends declared per common share

    1.79

    1.70

    1.48

    1.34

    Market price range per common share

    81—41

    106—65

    99—66

    70—53

    Weighted average common shares outstanding (in millions)

    210

    212

    216

    222

    Weighted average common shares outstanding assuming
dilution (in millions)

    214

    219

    223

    228

    Book value per common share at year-end

    $
    22.68

    $
    24.03

    $
    25.52

    $
    22.67

    Shareholders at year-end

    8,600

    8,900

    9,300

    9,900

    Employees at year-end (D)

    18,900

    21,100

    22,100

    20,700

Comment 4 — Liquidity and Capital Resources, page 30

We note your disclosure on page 68 that various debt agreements to which you are a party include
certain financial covenants and other restrictions. As such, please disclose here or elsewhere in
the filing the specific terms of any material debt covenants in your debt agreements. In addition,
if it is reasonably likely that you will not be in compliance with any of your material debt
covenants, please disclose the required ratios/amounts as well as the actual ratios/amounts as of
each reporting date. This will allow readers to understand how much cushion there is between the
required ratios/amounts and the actual ratios/amounts. Please also consider showing the specific
computations used to arrive at the actual ratios/amounts with corresponding reconciliations to US
GAAP amounts, if necessary. See Sections I.D and IV.C of the SEC Interpretive Release No. 33-8350.

Response:

For all periods presented, the Company was in compliance with all debt covenants. As required by
Sections I.D and IV.C of the SEC Interpretive Release No. 33-8350, if it becomes reasonably likely
that the Company will not be in compliance with a material debt covenant, disclosures about the
requirements, including ratios, will be included in the applicable future filings.

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The Company has one material financial covenant associated with its $1.45 billion multicurrency
revolving facility. The covenant indicates that the Company shall not exceed a maximum leverage
ratio of 60%. The leverage ratio is defined in the agreement as consolidated total long-term debt
as a percentage of consolidated total long-term debt plus consolidated shareholders’ equity. For
purposes of the ratio calculation, consolidated shareholders’ equity is adjusted by subtracting
consolidated goodwill. The Company’s ratio was significantly below the specified level for all
periods presented. In future filings, we will expand the disclosures within the Debt footnote to
include the additional disclosures underlined below.

Revised Disclosure:

14. Debt

(Excerpt)

Various debt agreements to which the Company is a party include certain financial covenants and
other restrictions, including restrictions pertaining to the ability to create property liens and
enter into certain sale and leaseback transactions. The Company has one material financial
covenant associated with its $1.45 billion multicurrency revolving facility. The covenant
indicates that the Company shall not exceed a maximum leverage ratio of 60%. The leverage ratio is
defined in the agreement as consolidated total long-term debt as a percentage of consolidated total
long-term debt plus consolidated shareholders’ equity. For purposes of the ratio calculation,
consolidated shareholders’ equity is adjusted by subtracting consolidated goodwill. The Company is
in compliance with this and all other financial debt covenants.

Comment 5 — Impairment of Long-Lived Assets, page 36

To the extent that any of your reporting units have estimated fair values that are not
substantially in excess of the carrying value and to the extent that goodwill for these reporting
units, in the aggregate or individually, if impaired, could materially impact your operating
results or total shareholders’ equity, please provide the following disclosures for each of these
reporting units in future filings:

    •

    Identify the reporting unit;

    •

    The percentage by which fair value exceeds the carrying value as of the most-recent
step-one test;

    •

    The amount of goodwill;

    •

    A description of the assumptions that drive the estimated fair value;

    •

    A discussion of the uncertainty associated with the key assumptions. For example, to
the extent that you have included assumptions in your discounted cash flow model that
materially deviates from your historical results, please include a discussion of these
assumptions;

    •

    A discussion of any potential events and/or circumstances that could have a negative
effect to the estimated fair value.

If you have determined that the estimated fair value substantially exceeds the carrying value for
all of your reporting units, please disclose this determination in future filings. Please also
provide the above disclosures, as applicable, for any long-lived assets or asset groups for which
you have determined that
fair value is not substantially in excess of the carrying value and to the extent that the asset
amounts, in the aggregate or individually, could materially impact your operating results or total
shareholders’ equity. Please refer to Item 303 of Regulation S-K and Sections 216 and 501.14 of
the SEC’s Codification of Financial Reporting Policies for guidance.

Response:

In the fourth quarter of 2009, the Company conducted the required annual test of goodwill for
impairment. As a result, the Company compared the estimated fair value of each of its business
reporting units to their carrying value and determined that the fair value substantially exceeded
the carrying value for each of the reporting units. This fact will be disclosed in future filings,
as illustrated below. If the fair value of

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a reporting unit does not substantially exceed its
carrying value, the Company will provide the disclosure outlined above for such reporting unit.

Plant and equipment held for use is grouped for impairment testing at the lowest level for which
there is identifiable cash flows. Impairment testing of the asset group occurs whenever events or
changes in circumstances indicate the carrying amount of the assets may not be recoverable. Such
circumstances would include a significant decrease in the market
value of a long-lived asset grouping, a
significant adverse change in the manner in which the asset grouping is being used or in its
physical condition, a history of operating or cash flow losses associated with the use of the asset grouping, or
changes in the expected useful life of the long-lived assets. There were no such events or changes
in circumstances that occurred during the reporting periods. The Company has not had an impairment
of long-lived assets held for use. Any impairment charges have been necessitated by the decision
to sell or abandon an asset.

In future filings, we will expand the disclosures within the Impairment of Long-Lived Assets
section of the Critical Accounting Policies and Estimates to include the additional disclosures
underlined below.

Revised Disclosure:

Impairment of Long-Lived Assets

Plant and Equipment

Net plant and equipment at 30 September 2010 totaled $x,xxx.x. Plant and equipment held for use is
grouped for impairment testing at the lowest level for which there is identifiable cash flows.
Impairment testing of the asset group occurs whenever events or changes in circumstances indicate
that the carrying amount of the assets may not be recoverable. Such circumstances would include a
significant decrease in the market value of a long-lived asset grouping, a significant adverse
change in the manner in which the asset grouping is being used or in its physical condition, a
history of operating or cash flow losses associated with the use of the asset grouping, or changes
in the expected useful life of the long-lived assets. There were no such events or changes in
circumstances that occurred during the reporting periods.

If such circumstances are determined to exist, an estimate of undiscounted future cash flows
produced by that asset group is compared to the carrying value to determine whether impairment
exists. If an asset group is determined to be impaired, the loss is measured based on the
difference between the asset group’s fair value and its carrying value. An estimate of the asset
group’s fair value is based on the discounted value of its estimated cash flows. Assets to be
disposed of by sale are reported at the lower of carrying amount or fair value less cost to sell.

The assumptions underlying cash flow projections represent management’s best estimates at the time
of the impairment review. Factors that management must estimate include industry and market
conditions, sales volume and prices, costs to produce, inflation, etc. Changes in key assumptions
or actual conditions that differ from estimates could result in an impairment charge. The Company
uses reasonable and supportable assumptions when performing impairment reviews and cannot predict
the occurrence of future events and circumstances that could result in impairment charges.

Goodwill

The purchase method of accounting for business combinations currently requires the Company to make
use of estimates and judgments to allocate the purchase price paid for acquisitions to the fair
value of the net tangible and identifiable intangible assets. Goodwill represents the excess of the
aggregate purchase price over the fair value of net assets of an acquired entity. Goodwill,
including goodwill associated with equity affiliates of $xx.x, was $xxx.x as of 30 September 2010.
The majority of the Company’s goodwill is assigned to reporting units within the Merchant Gases and
Electronics and Performance Materials segments. Disclosures related to goodwill are included in
Note 9 to the Consolidated Financial Statements.

4

The Company performs an impairment test annually in the fourth quarter of the fiscal year. In
addition, goodwill would be tested more frequently if changes in circumstances or the occurrence of
events indicated that potential impairment exists. The impairment test requires the Company to
compare the fair value of business reporting units to carrying value, including assigned goodwill.
The Company has designated its reporting units for goodwill impairment testing as one level below
the operating segment for which discrete financial information is available and whose operating
results are reviewed by segment managers regularly. Currently, the Company has four business
segments and fifteen reporting units. Reporting units are primarily based on products and
geographic locations within each business segment.

In the fourth quarter of 2010, the Company conducted the required annual test of goodwill for
impairment. The Company determined the fair value of each of the reporting units substantially
exceeded its carrying value and therefore, there were no indications of impairment.

The Company primarily uses an income approach valuation model, representing the present value of
future cash flows, to determine fair value of a reporting unit. The Company’s valuation model uses
a five-year growth period for the business and an estimated exit trading multiple. Management has
determined the income approach valuation model represents the most appropriate valuation
methodology due to the capital intensive nature of the business, long-term contractual nature of
the business, relatively consistent cash flows generated by the Company’s reporting units, and
limited comparables within the industry. The principal assumptions utilized in the Company’s income
approach valuation model include revenue growth rate, operating profit margins, discount rate, and
exit multiple. Revenue growth rate and operating profit assumptions are consistent with those
utilized in the Company’s operating plan and long-term financial planning process. The discount
rate assumption is calculated bas