DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-74,058

PENTEL OF AMERICA, LTD.
MANUFACTURING DIVISION
TORRANCE, CALIFORNIA

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(a) of the Act, 19 U.S.C. § 2272(a), are
satisfied if the following criteria are met:
I. The first criterion (set forth in Section 222(a)(1) of the
Act, 19 U.S.C. § 2272(a)(1)) requires that a significant
number or proportion of the workers in the workers' firm
must have become totally or partially separated or be
threatened with total or partial separation.

II. The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied if either:

(i)(I) there has been a shift by the workers' firm to a
foreign country in the production of articles or
supply of services like or directly competitive with
those produced/supplied by the workers' firm; OR
(i)(II) there has been an acquisition from a foreign
country by the workers' firm of articles/services that
are like or directly competitive with those
produced/supplied by the workers' firm.

III. The third criterion requires that the shift/acquisition
must have contributed importantly to the workers'
separation or threat of separation. See Section
222(a)(2)(B)(ii) of the Act, 19 U.S.C. §
2272(a)(2)(B)(ii).

The investigation was initiated in response to a petition
filed on May 7, 2010 by a State Workforce Office on behalf of
workers of Pentel of America, Ltd., Torrance, California. The
workers are engaged in activities related to production of
writing instruments.
The investigation revealed that workers of Pentel of
America, Ltd., who are engaged in activities related to
production writing instruments, meet the criteria for
certification.
Criterion I has been met because a significant proportion
of workers have been separated during the relevant period.
Criterion II has been met because the workers' firm has
shifted to a foreign country the production of articles like
or directly competitive with the writing instruments produced
by the workers.
Criterion III has been met because the shift in
production of writing instruments by Pentel of America, Ltd.,
contributed importantly to worker group separations at the
Torrance, California facility.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Pentel of America,
Ltd., Torrance, California, who are engaged in activities
related to production of writing instruments, 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 Pentel of America, Ltd., Torrance,
California, Manufacturing Division, who became totally or
partially separated from employment on or after May 6,
2009, 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 11th day of August, 2010

/s/ Michael W. Jaffe

______________________________
MICHAEL W. JAFFE
Certifying Officer, Office of
Trade Adjustment Assistance