DEPARTMENT OF LABOR
Employment and Training Administration
TA-W-58,466

ROYAL INDEMNITY COMPANY
A SUBSIDIARY OF ROYAL & SUNALLIANCE USA, INC.
CHARLOTTE, NORTH CAROLINA

Negative Determinations Regarding Eligibility
To Apply for Worker Adjustment Assistance
And 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 an investigation regarding certification of eligibility
to apply for worker adjustment assistance.
The investigation was initiated on December 6, 2005, in
response to a petition filed on behalf of workers at Royal
Indemnity Company, a subsidiary of Royal & SunAlliance USA, Inc.,
Charlotte, North Carolina. The workers provide IT service support
for Royal Indemnity employees and insurance information for
participants.
The investigation revealed that Royal Indemnity Company, a
subsidiary of Royal & SunAlliance USA, Inc., Charlotte, North
Carolina, does not produce an article within the meaning of Section
222(a)(2) of the Act. In order to be considered eligible to apply
for adjustment assistance under Section 223 of the Trade Act of
1974, the worker group seeking certification (or on whose behalf
certification is being sought) must work for a "firm" or
appropriate subdivision that produces an article and there must be
a relationship between the workers' work and the article produced
by the workers' firm or appropriate subdivision. The workers
engaged in the service support and information sharing activities
do not support a firm or appropriate subdivision that produces an
article domestically that is trade effected and thus the worker
group can not be considered import impacted or affected by a shift
in production of an article.
Moreover, the separations occurring at the subject firm has to
do with corporate restructuring and the company's decision to exit
the United States market.
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 assistance
(ATAA) for older workers.
In order for the Department to issue a certification of
eligibility to apply for ATAA, the worker group must be certified
eligible to apply for trade adjustment assistance (TAA). Since the
workers are denied eligibility to apply for TAA, the workers cannot
be certified eligible for ATAA.







Conclusion
After careful review of the facts obtained in this
investigation, I determine that workers of Royal Indemnity Company,
a subsidiary of Royal & SunAlliance USA, Inc., Charlotte, North
Carolina, are denied eligibility to apply for adjustment assistance
under Section 223 of the Trade Act of 1974, and are also denied
eligibility to apply for alternative trade adjustment assistance
under Section 246 of the Trade Act of 1974.
Signed in Washington, D. C. this 15th day of December 2005

/s/ Linda G. Poole

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