DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-63,302

BCS CUYAHOGA, LLC
A SUBSIDIARY OF BCS INDUSTRIES, LLC
SOLON, OHIO

Certification Regarding Eligibility
To Apply for Worker Adjustment Assistance and
Alternative Trade Adjustment Assistance

In accordance with Section 223 of the Trade Act of
1974 (19 USC 2273), as amended, 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 May 5, 2008 in
response to a petition filed on behalf of the workers BCS
Cuyahoga LLC, a subsidiary of BCS Industries LLC, Solon,
Ohio. The workers produce steel products particularly cold
finished bar, annealed rod and wire.
The investigation revealed that workers wages of BCS
Cuyahoga LLC were also reported under FEID number for BCS
Industries LLC.
The investigation also revealed employment and sales
at the subject facility decreased from 2006 to 2007.
The Department of Labor surveyed the subject firm's
major declining customers regarding purchases of wire, rod
and cold formed bar in 2006, 2007 and January through April
2008. The survey revealed increased import purchases from
2006 to 2007.
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 group eligibility
requirements of Section 246 of the Trade Act must be met.
The Department has determined in this case that the
requirements of Section 246 have been met.
A significant number of workers at the firm are age 50
or over and possess skills that are not easily
transferable. Competitive conditions within the industry
are adverse.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that increases of imports of
articles like or directly competitive with the steel
products produced by BCS Cuyahoga LLC, a subsidiary of BCS
Industries LLC, Solon, Ohio, 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 BCS Cuyahoga LLC, a subsidiary of BCS
Industries LLC, Solon, Ohio, who became totally or
partially separated from employment on or after May 2,
2007 through two years from the date of certification,
are eligible to apply for adjustment assistance under
Section 223 of the Trade Act of 1974, and are also
eligible to apply for alternative trade adjustment
assistance under Section 246 of the Trade Act of
1974."
Signed in Washington, D.C., this 12th day of June 2008.

/s/ Linda G. Poole
______________________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance