DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-52,807

BRUBAKER TOOL CORPORATION
A SUBSIDIARY OF TALBOTT HOLDINGS
MILLERSBURG, PENNSYLVANIA

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:

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. 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 September 11, 2003 in
response to a petition filed by a company official on behalf of
workers at Brubaker Tool Corporation, a subsidiary of Talbott
Holdings, Millersburg, Pennsylvania. The workers at the subject
firm produce endmills and taps; they are not separately
identifiable by product line.
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
import endmills and taps during 2001, 2002, or during the period of
January through August 2003.
Furthermore, the investigation revealed that the subject firm
did not shift abroad the production of endmills and taps during the
relevant period.
Petitioners also allege that job losses were due to their firm
losing business as a supplier to a firm that shifted production
abroad or was affected by increased imports. The investigation
revealed, however, that was not the case.
The subject firm did not supply a component to a primary firm
whose workers have been certified as trade impacted. The endmills
and taps sold by Brubaker Tool are used in the manufacturing
process and are thus not a component part of the article that was
the basis of the certification of the primary firm.
The Department of Labor surveyed the subject firm's major
customers regarding their purchases of endmills and taps. The
survey revealed no increases in imports during the relevant period.
Conclusion
After careful review, I determine that all workers of Brubaker
Tool Corporation, a subsidiary of Talbott Holdings, Millersburg,
Pennsylvania are denied eligibility to apply for adjustment
assistance under Section 223 of the Trade Act of 1974.
Signed in Washington, D.C. this 16th day of October 2003

/s/ Richard Church

______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance