DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-56,560

INTERSTATE TOOL AND DIE COMPANY
MADISON HEIGHTS, MICHIGAN

Negative Determination
Regarding Application for Reconsideration

By letter dated April 18, 2005, the company official
requested administrative reconsideration of the Department's
negative determination regarding eligibility for workers and
former workers of the subject firm to apply for Trade Adjustment
Assistance (TAA). The Department’s determination was signed on
March 23, 2005 and the Notice of determination was published in
the Federal Register on May 2, 2005 (70 FR 22710).
The negative determination was based on the findings that
during the investigatory period of 2003 through January 2005, the
subject company neither imported prototype automotive parts nor
shifted such production abroad, and the subject company’s major
declining customers did not import prototype automotive parts.
Pursuant to 29 CFR 90.18(c) reconsideration may be granted
under the following circumstances:
(1) If it appears on the basis of facts not previously
considered that the determination complained of
was erroneous;
(2) if it appears that the determination complained of
was based on a mistake in the determination of facts
not previously considered; or


(3) if in the opinion of the Certifying Officer, a mis-
interpretation of facts or of the law justified
reconsideration of the decision.
The company official, in the request for reconsideration,
infers that the scope of the initial investigation was in error
because the term prototype parts is a misleading description of
the work done by the firm. The company official now states that
the firm supported the advance engineering groups of domestic
automobile manufacturers.
During a February 14, 2005 telephone conversation, a company
official stated that workers at the subject company are engaged
in the prototype and production for the aerospace and automotive
industries. Further, the Business Confidential Data Request form
completed by another company official submitted, in part, on
February 16, 2005, identified “prototype auto parts” as the
product manufactured at the subject facility. Therefore, the
Department determines that the scope of the investigation was not
in error.


Conclusion
After review of the application and investigative findings,
I conclude that there has been no error or misinterpretation of
the law or of the facts which would justify reconsideration of
the Department of Labor's prior decision. Accordingly, the
application is denied.
Signed at Washington, D.C., this 5th day of May 2005
/s/ Linda G. Poole
_______________________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance