DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-59,228

NORTH AMERICAN COMMUNICATIONS, INC.
DUCANSVILLE, PENNSYLVANIA

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
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 April 18, 2006 in response
to a petition filed on behalf of workers at North American
Communications, Inc., Duncansville, Pennsylvania. The workers at
the subject facility produce and ship direct mail.
The investigation revealed that criteria (I.C) and (II.B) have
not been met.
The investigation revealed that North American Communications,
Inc. allocates production to different facilities based on the
geographic needs of particular clients. Although some production of
the corporation was moved to Mexico as a result of increased sales
in the Southern and Western parts of the country, that move was not
causally related to any diminished production at the Duncansville
plant.
Sales and production for all locations of the firm increased
in 2005 compared with 2004 and also increased in the first quarter
of 2006 compared with the same quarter one year earlier.
A primary cause of separations at the subject plant is the
seasonality of employment there, typically increasing in the fourth
quarter of the year and decreasing in the first quarter of the
following year. It is anticipated that production capacity in
Pennsylvania will be more fully utilized in the more active periods
of the year. Additionally, although reconfiguration of shift work
operations at Duncansville has resulted in some separations, these
were not related to imports or shifts of production abroad.
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 North
American Communications, Inc., Duncansville, Pennsylvania are
denied eligibility to apply for adjustment assistance under Section
223 of the Trade Act of 1974, and alternative trade adjustment
assistance under Section 246 of the Trade Act of 1974.
Signed in Washington, D.C., this 29th day of June 2006

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