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What Is the Protocol Gas Verification Program (PGVP)?

  • May 5, 2021
  • 2 min read

The Protocol Gas Verification Program (PGVP) is an EPA initiative established in March 2011 to ensure the accuracy of calibration gases used in continuous emissions monitoring systems (CEMS). Facilities subject to 40 CFR Part 75 emissions monitoring and reporting requirements must procure EPA protocol gases from a production site listed as a PGVP participant on the date of purchase—or from a vendor selling unaltered protocol gases from a PGVP-approved production site. Full requirements are outlined in 40 CFR 75.12(g)(6) and (7).


These gases and their associated QA/QC checks are what make emissions data defensible. EPA relies on that data to assess compliance with emission reduction requirements under the Clean Air Act—and the integrity of that data starts with the calibration gas in your CEMS.


PGVP Objectives and EPA Requirements

The Clean Air Markets Division (CAMD) administers the PGVP with four core objectives:

  1. Ensure that EPA protocol gases meet the accuracy requirements of 40 CFR Part 75

  2. Help calibration gas consumers make informed purchasing decisions

  3. Give well-performing vendors an incentive to maintain good practices

  4. Encourage underperforming vendors to make measurable improvements


CAMD maintains a current list of approved PGVP participants and vendor IDs on its program website. Verify you're referencing the most current list—vendor approval status changes, and purchasing from a lapsed site has real consequences for your data.


How the PGVP Affects Part 75 Facilities

EPA conducts blind audits of gas vendors and does not typically notify individual facilities when a vendor loses approved status. That means calibration gas from a lapsed vendor can go undetected—until it shows up as invalid data during a QA/QC event.


Facilities should check the approved vendor list at the start of each year and confirm their gas supplier is still on it. The Emissions Collection and Monitoring Plan System (ECMPS) includes a built-in feature that lets sites verify their cylinders were produced at an approved vendor site—use it as part of your routine QA/QC workflow.


PGVP Compliance Support from Alliance Technical Group

Calibration gas is one piece of a larger compliance picture. Alliance partners with Part 75 facilities to deliver dependable emissions testing, continuous monitoring expertise, and strategic compliance guidance that strengthens data reliability, simplifies reporting, and helps facilities meet the highest regulatory standards—from CEMS shelter construction and system maintenance to DAS software, stack testing, and ongoing QA/QC support.



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