DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-70,885

NEFF-PERKINS COMPANY
PERRY FACILITY
PERRY, 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 "Supplier" as "a firm that produces and supplies directly
to another firm component parts for articles, or services used
in the production of articles or in the supply of services, as
the case may be, that were the basis for a certification of
eligibility under subsection (a) [of Section 222 of the Act] of
a group of workers employed by such other firm."
The investigation was initiated in response to a petition
filed on June 3, 2009 on behalf of workers of Neff-Perkins
Company, Perry Facility, Perry, Ohio. The workers produce
molded rubber products.
The investigation revealed that workers of Neff-Perkins
Company, Perry Facility, Perry, Ohio who are engaged in
employment related to the production of molded rubber products
meet the criteria for certification.
Criterion I has been met because a significant proportion
of workers of the subject firm are threatened to become
totally separated during the relevant period.
Criterion II has been satisfied because the workers' firm
produced and sold molded rubber products to ITW Tomco, Bryan,
Ohio to be incorporated into automotive plastic injection
molded parts. Workers of ITW Tomco are covered by
certification number TA-W-64,405 issued based on a shift in
production of automotive plastic injection molded parts to
Mexico.
Criterion III has been met because the loss of business
with ITW Tomco by Neff-Perkins Company contributed importantly
to worker group separations at the Perry, Ohio facility.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Neff-Perkins Company,
Perry Facility, Perry, Ohio, who are engaged in employment
related to the production of molded rubber products 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 Neff-Perkins Company, Perry Facility,
Perry, Ohio, who became totally or partially separated from
employment on or after May 28, 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 13th day of November, 2009.

/s/ Michael W. Jaffe
______________________________
MICHAEL W. JAFFE
Certifying Officer, Division of
Trade Adjustment Assistance