DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-70,474

SAMUEL STEEL PICKLING COMPANY
TWINSBURG, OHIO

Certification Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended ("Act"), 19 U.S.C. § 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 workers of a firm
under Section 222(c) of the Act, 19 U.S.C. § 2272(c), can be
satisfied if the following criteria are met:
I. 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;

II. the workers' firm is a Supplier or Downstream Producer
to a firm that employed a group of workers who
received a certification of eligibility under Section
222(a) of the Act, 19 U.S.C. § 2272(a), and such
supply or production is related to the article or
service that was the basis for such certification; and

III. either
(A) the workers' firm is a supplier and the component
parts it supplied to the firm 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
described in paragraph (2) contributed importantly to
the workers' separation or threat of separation.

Section 222(d) of the Act, 19 U.S.C. § 2272(d), defines the
term "Downstream Producer" as "a firm that performs additional,
value-added production processes or services directly for
another firm for articles or services with respect to which a
group of workers in such other firm has been certified under
subsection (a) [of Section 222 of the Act]" and defines the term
"value-added production processes or services" to "include final
assembly, finishing, testing, packaging, or maintenance or
transportation services."
The investigation was initiated in response to a petition
filed on May 22, 2009 on behalf of workers of Samuel Steel
Pickling Company, Twinsburg, Ohio (Samuel Steel Pickling
Company). Workers at the subject firm are engaged in activities
related to toll processing services such as cleaning, slitting,
and coating steel coils. The workers are not separately
identifiable by services.
The investigation revealed that workers of Samuel Steel
Pickling Company, Twinsburg, Ohio who are engaged in
employment related to toll processing services meet the
criteria as a Downstream Producer for secondary worker
certification.
Criterion I has been met because a significant number or
proportion of the workers in the workers' firm have become
totally or partially separated.
Criterion II has been satisfied because workers of Samuel
Steel Pickling Company supplied toll processing services to
Viking and Worthington Steel Enterprise, LLC, Valley City, Ohio,
and workers of Viking and Worthington Steel Enterprise, LLC,
Valley City, Ohio are covered by certification number TA-W-
63,342. The certification was based on increased customer
imports of steel coil, and the toll processing services were
related to steel coil produced by Viking and Worthington Steel
Enterprise, LLC, Valley City, Ohio.
Criterion III has been met because the loss of business
described above by Samuel Steel Pickling Company as a
downstream producer, with Viking and Worthington Steel
Enterprise, LLC, Valley City, Ohio contributed importantly to
the worker separations at Samuel Steel Pickling Company.











Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Samuel Steel Pickling
Company, Twinsburg, Ohio who are engaged in activities related
to toll processing services meet the worker group certification
criteria under Section 222(a) of the Act, 19 U.S.C. § 2272(a).
In accordance with Section 223 of the Act, 19 U.S.C. § 2273, I
make the following certification:
"All workers of Samuel Steel Pickling Company, Twinsburg,
Ohio, who became totally or partially separated from
employment on or after May 18, 2008 through two years from
the date of certification, and all workers in the group
threatened with total or partial separation from employment
on the date of certification through two years from the
date of certification, are eligible to apply for adjustment
assistance under Chapter 2 of Title II of the Trade Act of
1974, as amended."
Signed in Washington, D.C., this 16th day of October 2009


/s/ Elliott S. Kushner

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