DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-63,431

GREENVILLE TOOL & DIE COMPANY
GREENVILLE, MICHIGAN

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 May 23, 2008, in
response to a petition filed by a company official on behalf of
workers of Greenville Tool & Die Company, Greenville, Michigan.
The workers produced sheet metal stamping dies for the
automotive industry. The workers are not separately
identifiable by articles produced.
The investigation revealed that criteria (I.B) and (II.B)
have not been met.
Sales and production at the subject firm increased from
2006 to 2007 and during January through May 2008 as compared to
the corresponding 2007 period. The investigation also revealed
that the subject firm did not shift production of sheet metal
stamping dies to a foreign country during the relevant period.
Petitioners also filed as adversely affected secondary
workers as suppliers to a firm or subdivision primarily affected
by increased imports or a shift of production abroad.
In order to make an affirmative determination and issue a
certification of eligibility to apply for adjustment assistance,
the following group eligibility requirements under Section
222(b) must be met:
(1) a significant number or proportion of the workers in
the workers' firm or an appropriate subdivision of the
firm have become totally or partially separated, or
are threatened to become totally or partially
separated;

(2) the workers' firm (or subdivision) is a supplier or
downstream producer to a firm (or subdivision) that
employed a group of workers who received a
certification of eligibility to apply for trade
adjustment assistance benefits and such supply or
production is related to the article that was the
basis for such certification; and

(3) either-

(A) the workers' firm is a supplier and the component
parts it supplied for the firm (or subdivision)
described in paragraph (2) accounted for at least 20
percent of the production or sales of the workers'
firm; or

(B) a loss of business by the workers' firm with the
firm (or subdivision) described in paragraph (2)
contributed importantly to the workers' separation or
threat of separation.

The investigation revealed that criterion (3) has not been
met.
The investigation revealed that the subject firm is a
supplier to a trade certified firm, but that production or sales
to this firm did not account for at least 20 percent of the
production or sales of the subject firm.
Furthermore, the loss of business by the worker's firm with
this customer did not contribute importantly to the worker's
separation or threat or separation. The subject firm
experienced increased overall sales at the time that sales to
this customer declined from 2006 to 2007. The subject firm has
since experienced further increases in sales and production.
The investigation further revealed that the company
anticipates possible declines in sales or production later this
year. Therefore, if conditions change, a new trade adjustment
assistance petition may be filed.


Conclusion
After careful review, I determine that all workers of
Greenville Tool & Die Company, Greenville, Michigan, 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 2nd day of July 2008

/s/ Elliott S. Kushner

______________________________
ELLIOTT S. KUSHNER
Certifying Officer, Division of
Trade Adjustment Assistance