DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-58,505
ROCK-TENN COMPANY
PIEDMONT, SOUTH 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 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 December 14, 2005 in
response to a petition filed by the South Carolina State Trade
Coordinator on behalf of workers of Rock-Tenn Company, Piedmont,
South Carolina. The workers produce corrugated boxes.
The investigation revealed that criteria (I.B), (I.C) and
(II.B) have not been met.
Sales and production at the Piedmont, South Carolina plant
increased in 2003-2004 and in January through October, 2005
compared with the same period of the previous year.
The investigation also revealed that there were no company
imports of corrugated boxes, nor was there a shift in production of
corrugated boxes from Rock-Tenn Company's, Piedmont facility to a
foreign country during the period under investigation.
The U.S. Department of Labor conducted a survey of major
customers of the subject firm regarding their purchases of
corrugated boxes in 2004 and 2005. The survey revealed that
respondents did not import corrugated boxes in 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 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, I determine that all workers of Rock-
Tenn Company, Piedmont, South 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 1st day of February, 2006.

/s/ Richard Church
______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance