DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-55,908

BOERICKE AND TAFEL
A SUBSIDIARY OF
NATURE'S WAY PRODUCTS HOLDING COMPANY
INCLUDING LEASED WORKERS OF REMEDY INTELLIGENCE STAFFING
SANTA ROSA, CALIFORNIA

Certification Regarding Eligibility
To Apply for Worker Adjustment Assistance and
Negative Determination Regarding Eligibility to
Apply for Alternative Trade 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 its investigation regarding certification of eligibility
to apply for worker adjustment assistance.
In order to make an affirmative determination and issue a
certification of eligibility to apply for Trade Adjustment
Assistance, the group eligibility requirements in either paragraph
(a)(2)(A) or (a)(2)(B) of Section 222 of the Trade Act must be met.
It is determined in this case that the requirements of (a)(2)(A) of
Section 222 have been met.
The investigation was initiated on November 3, 2004 in
response to a petition filed by a California state agency
representative on behalf of workers at Boericke and Tafel, a
subsidiary of Nature's Way Products Holding Company, Santa Rosa,
California. The workers at the subject firm produce homeopathic
nutritional supplements. The subject firm leased workers from
Remedy Intelligence Staffing.
The investigation revealed that the subject firm's sales,
production, and employment decreased in 2003 compared to 2002 and
again in January through July of 2004 compared to the same period
in 2003.
Furthermore, the investigation revealed that the subject
firm's imports of homeopathic nutritional supplements increased
during the relevant period.
In addition, in accordance with Section 246 the Trade Act of
1974 (26 USC 2813), as amended, the Department of Labor herein
presents the results of its investigation regarding certification
of eligibility to apply for alternative trade adjustment assis-
tance (ATAA) for older workers.
The group eligibility criteria for the ATAA program that the
Department must consider under Section 246 of the Trade Act are:
1. Whether a significant number of workers in the workers' firm
are 50 years of age or older.
2. Whether the workers in the workers' firm possess skills that
are not easily transferable.
3. The competitive conditions with the workers' industry (i.e.,
conditions with the industry are adverse).

The Department has concluded that criterion 2 has not been
met. The investigation revealed that workers of the subject
facility possess skills that are easily transferable to other
positions in the local area.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that increases of imports of articles
like or directly competitive with homeopathic nutritional
supplements produced at Boericke and Tafel, a subsidiary of
Nature's Way Products Holding Company, Santa Rosa, California.
contributed importantly to the total or partial separation of
workers and to the decline in sales or production at that firm or
subdivision. In accordance with the provisions of the Act, I make
the following certification:
"All workers of Boericke and Tafel, a subsidiary of Nature's
Way Products Holding Company, including leased workers of
Remedy Intelligence Staffing, Santa Rosa, California who
became totally or partially separated from employment on or
after October 21, 2003 through two years from the date of
certification are eligible to apply for adjustment assistance
under Section 223 of the Trade Act of 1974."
I further determine that all workers of Boericke and Tafel, a
subsidiary of Nature's Way Products Holding Company, including
leased workers of Remedy Intelligence Staffing, Santa Rosa,
California are denied eligibility to apply for alternative trade
assistance under section 246 of the Trade Act of 1974."
Signed in Washington, D. C., this 18th day of November 2004.

/s/ Richard Church

_______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance