November 25, 2009

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

RE: Air Products and Chemicals, Inc. (the “Company”) Annual Report on Form 10-K — File No. 1-4534

Ladies and Gentlemen:

     Filed herewith, on behalf of Air Products and Chemicals, Inc., is the Company’s Annual Report on Form 10-K for the fiscal year ended September 30, 2009.

     The Company adopted new authoritative accounting guidance during fiscal year 2009, the impacts of which are discussed in Note 2 of the financial statements. Other than this new authoritative accounting guidance, no material changes in accounting principles or practices or the methods of applying such principles or practices have been made from the preceding year.

Sincerely,
 

/s/ Mary T. Afflerbach  

Mary T. Afflerbach
Corporate Secretary and
Chief Governance Officer 

Enclosure