DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-52,106

BETTER METHODS ALEXANDER, INC.
A WHOLLY OWNED SUBSIDIARY OF BMI HOLDINGS, INC.
PATERSON, NEW JERSEY

Negative Determination Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended (19 USC 2273), the Department of Labor herein presents
the results of an investigation regarding certification of
eligibility to apply for worker adjustment assistance. The group
eligibility requirements for directly-impacted (primary) workers
under Section 222(a) the Trade Act of 1974, as amended, can be
satisfied in either of two ways:
I. Section (a)(2)(A) all of the following must be satisfied:
A. a significant number or proportion of the workers in
such workers' firm, or an appropriate subdivision of
the firm, have become totally or partially separated,
or are threatened to become totally or partially
separated;
B. the sales or production, or both, of such firm or
subdivision have decreased absolutely; and
C. increased imports of articles like or directly
competitive with articles produced by such firm or
subdivision have contributed importantly to such
workers' separation or threat of separation and to the
decline in sales or production of such firm or
subdivision; or



II. Section (a)(2)(B) both of the following must be satisfied:

D. a significant number or proportion of the workers in
such workers' firm, or an appropriate subdivision of
the firm, have become totally or partially separated,
or are threatened to become totally or partially
separated;
E. there has been a shift in production by such workers'
firm or subdivision to a foreign country of articles
like or directly competitive with articles which are
produced by such firm or subdivision; and

C. One of the following must be satisfied:
1. the country to which the workers' firm has shifted
production of the articles is a party to a free
trade agreement with the United States;
2. the country to which the workers' firm has shifted
production of the articles is a beneficiary country
under the Andean Trade Preference Act, African
Growth and Opportunity Act, or the Caribbean Basin
Economic Recovery Act; or
3. there has been or is likely to be an increase in
imports of articles that are like or directly
competitive with articles which are or were produced
by such firm or subdivision.

The investigation was initiated on June 20, 2003 in
response to a petition filed by the company on behalf of workers
at Better Methods Alexander, Inc., a wholly owned subsidiary of
BMI Holdings, Inc., Paterson, New Jersey. The workers at the
subject firm produced converted paper.
The investigation revealed that criteria (a)(2)(A)(I.C) and
(a)(2)(B)(II.B) were not met.
The investigation revealed that the subject firm did not
increase imports of converted paper from 2001 to 2002 or during
the period of January through May 2003 when compared to the same
period in 2002.
Furthermore, the investigation revealed that the subject
firm shifted only a negligible amount of its production of
converted paper to Mexico during the relevant period.
The Department of Labor surveyed the subject firm's major
declining customers regarding their purchases of converted
paper. These surveys revealed no imports of converted paper
during the relevant period.
Conclusion
After careful review, I determine that all workers of
Better Methods Alexander, Inc., a wholly owned subsidiary of BMI
Holdings, Inc., Paterson, New Jersey are denied eligibility to
apply for adjustment assistance under Section 223 of the Trade
Act of 1974.
Signed in Washington, D.C. this 4th day of August 2003.

/s/ Linda G. Poole

______________________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance