DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-75,003

VELSICOL CHEMICAL, LLC
SUBSIDIARY OF TRUE SPECIALTIIES CORPORATION LLC
INCLUDING ON-SITE LEASED WORKERS FROM QUARLES BUILDING
MAINTENANCE AND MURRAY GUARD SERVICES
MEMPHIS, TENNESSEE

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:
(1) a significant number or proportion of the workers in such
workers' firm have become totally or partially separated, or
are threatened to become totally or partially separated; and

(2)(A)(i) the sales or production, or both, of such firm have
decreased absolutely; and

(ii)(I) imports of articles or services like or directly
competitive with articles produced or services supplied by
such firm have increased; and

(iii) the increase in imports described in clause (ii)
contributed importantly to such workers' separation or
threat of separation and to the decline in the sales or
production of such firm.

The investigation was initiated in response to a Trade
Adjustment Assistance (TAA) petition filed on December 16, 2010
by the United Steel Workers, Local 357, on behalf of workers of
Velsicol Chemical Corporation, LLC, Subsidiary of True
Specialties Corporation LLC, Memphis, Tennessee (subject firm).
The workers at the subject firm are engaged in employment
related to the production of industry chemicals for various
uses. Workers are separately identifiable by article produced.
One worker groups consists of workers engaged in employment
related to the production of Chlorendic Anhydride. Another
worker group consists of workers engaged in employment related
to the production of Hexachlorocyclopentadiene. The worker
groups include on-site leased workers from Quarles Building
Maintenance and Murray Guard Services. Some members of the
worker groups may be covered by an agreement that may contain
"bumping" provisions.
Workers engaged in the production of Chlorendic Anhydride
The investigation revealed that workers of Velsicol
Chemical Corporation, LLC, Subsidiary of True Specialties
Corporation LLC, Memphis, Tennessee, engaged in employment
related to the production of Chlorendic Anhydride, meet the
criteria for certification.
Section 222(a)(1) has been met because a significant
number or proportion of workers at the subject firm engaged in
employment related to the production of Chlorendic Anhydride has
been totally or partially separated, or threatened with such
separation.
Section 222(a)(2)(A)(i) has been met because subject firm
sales and/or production of Chlorendic Anhydride has decreased
absolutely during the relevant period.
Section 222(a)(2)(A)(ii) has been met because, during the
relevant period, the subject firm has increased its reliance
on imports of articles like or directly competitive with
Chlorendic Anhydride produced by the workers engaged in
employment related to the production of Chlorendic Anhydride.
Finally, Section 222(a)(2)(A)(iii) has been met because
the increased imports of articles like or directly competitive
with Chlorendic Anhydride contributed importantly to worker
group separations of workers engaged in employment related to
the production of Chlorendic Anhydride and sales/production
declines of Chlorendic Anhydride at the Velsicol Chemical
Corporation, LLC, Memphis, Tennessee facility.
Workers engaged in the production of Hexachlorocyclopentadiene
The investigation revealed that workers of Velsicol
Chemical Corporation, LLC, Subsidiary of True Specialties
Corporation LLC, Memphis, Tennessee, engaged in employment
related to the production of Hexachlorocyclopentadiene, do meet
the criteria for certification.
Section 222(a)(2)(A)(i) has not been met because subject
firm sales and/or production of Hexachlorocyclopentadiene has
increased during the relevant period. Further, Section
222(a)(2)(B)(i) has not been met because there has been a
shift to/acquisition from a foreign country by the subject
firm in the production of articles like or directly
competitive with those produced by the workers engaged in
employment related to the production of
Hexachlorocyclopentadiene.
Conclusion
After careful review of the facts obtained in the
investigation, I determine the workers of Velsicol Chemical
Corporation, LLC, Subsidiary of True Specialties Corporation
LLC, Memphis, Tennessee, engaged in employment related to the
production of Hexachlorocyclopentadiene, do not meet the
requirements for eligibility to apply for worker adjustment
assistance for workers, and I determine that workers of Velsicol
Chemical Corporation, LLC, Subsidiary of True Specialties
Corporation LLC, Memphis, Tennessee, engaged in employment
related to the production of Chlorendic Anhydride, 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 Velsicol Chemical Corporation, LLC,
Subsidiary of True Specialties Corporation LLC, including
on-site leased workers of Quarles Building Maintenance and
Murray Guard Services, Memphis, Tennessee, who are engaged
in employment related to the production of Chlorendic
Anhydride, and who became totally or partially separated
from employment on or after December 15, 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 19th day of April, 2011


/s/Del Min Amy Chen__________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance