DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-80,334

RR DONNELLEY
VON HOFFMANN DIVISION
A SUBSIDIARY OF RR DONNELLEY & SONS COMPANY
INCLUDING ON-SITE LEASED WORKERS FROM RIVERSIDE STAFFING
ELDRIDGE, IOWA

Notice of Revised Determination
on Reconsideration


The initial investigation, initiated August 2, 2011, resulted
in a negative determination, issued on October 6, 2011, that was
based on the absence of increased imports and shift in production.
The determination was applicable to workers and former workers of
RR Donnelley, Von Hoffmann Division, a subsidiary of RR Donnelley &
Sons Company, including on-site leased workers from Riverside
Staffing, Eldridge, Iowa (RR Donnelley, Von Hoffmann Division).
The notice of determination was published in the Federal Register
on October 26, 2011 (Vol. 76 FR 66329). The workers’ firm is
engaged in activities related to the production of commercial books
and forms.
As required by the Trade Adjustment Assistance (TAA) Extension
Act of 2011 (the TAAEA), the investigation into this petition was
reopened for a reconsideration investigation to apply the
requirements for worker group eligibility under chapter 2 of title
II of the Trade Act of 1974, as amended by the TAAEA, to the facts
of this petition.
Based on a careful review during the reconsideration
investigation, the Department of Labor determines that the worker
group at RR Donnelley, Von Hoffmann meets the requirements for
eligibility to apply for trade adjustment assistance.
Section 222(a)(1) has been met because a significant number
or proportion of the workers in RR Donnelley, Von Hoffmann Division
have become totally or partially separated, or are threatened to
become totally or partially separated.
Section 222(a)(2)(B) has been met because RR Donnelley has
shifted to a foreign country the production of commercial books and
forms like or directly competitive with the article produced by the
subject workers which contributed importantly to worker group
separations at RR Donnelley, Von Hoffmann Division.
Conclusion
After careful review, I determine that workers of RR Donnelley,
Von Hoffmann Division, a subsidiary of RR Donnelley & Sons Company,
including on-site leased workers from Riverside Staffing, Eldridge,
Iowa, who were engaged in employment related to the production of
commercial books and forms, 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 RR Donnelley & Sons Company, Von Hoffmann
Division, a subsidiary of RR Donnelley & Sons Company,
including on-site leased workers from Riverside Staffing,
Eldridge, Iowa, who became totally or partially separated from
employment on or after July 15, 2010, 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 28th day of December, 2011


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


DEPARTMENT OF LABOR
Employment and Training Administration

TA-W-80,334

RR DONNELLEY
VON HOFFMANN DIVISION
A SUBSIDIARY OF RR DONNELLEY & SONS COMPANY
INCLUDING ON-SITE LEASED WORKERS FROM RIVERSIDE STAFFING
ELDRIDGE, IOWA

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 (“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.
Workers of a firm may be eligible for worker adjustment
assistance if they satisfy the criteria of subsection (a) and (b)
of Section 222 of the Act, 19 U.S.C. § 2272(a) and (b). For the
Department of Labor to issue a certification for workers under
Section 222(a) of the Act, 19 U.S.C. § 2272(a), the following three
criteria must be met:
(1) 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 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
(2) The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied in one of two
ways:
(A) Increased Imports Path:
(i) sales or production, or both, at the workers’ firm must
have decreased absolutely, AND
(ii) imports of articles like or directly competitive with
articles produced by such firm or subdivision have
increased; and
(iii) the increase 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 or subdivision.

(B) Shift in Production Path:
(i) 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
(ii)(I) 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;
(II)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
(III)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.

For the Department to issue a secondary worker certification
under Section 222(b) of the Act, 19 U.S.C. § 2272(b), to workers of
a Supplier or a Downstream Producer, the following criteria 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 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 that was the basis for such
certification; and

(3) 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(c) of the Act, 19 U.S.C. § 2272(c), defines the
terms “Supplier” and “Downstream Producer.”
The investigation was initiated in response to a petition
filed on August 2, 2011 on behalf of workers at RR Donnelley, Von
Hoffman Division, a subsidiary of RR Donnelley & Sons Company,
Eldridge, Iowa (subject firm). Workers of the subject firm are
engaged in activities related to the production of commercial books
and forms.
The petitioner alleged that outsourcing to foreign plants led
to worker group separations at the subject firm.
With respect to Section 222(a)(2)(B) of the Act, the
investigation revealed that there has not been a shift in
production of articles like or directly competitive with commercial
books and forms produced by the subject firm to a foreign country.
With respect to Section 222(a)(2)(A)(ii) of the Act, the
investigation revealed that imports of articles like or directly
competitive with commercial books and forms produced by the
subject firm have not increased.
With respect to Section 222(b)(2) of the Act, the
investigation revealed that the subject firm is not 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).
In order for the Department to issue a certification of
eligibility to apply for Alternative Trade adjustment assistance
(ATAA), the worker group must be certified eligible to apply for
trade adjustment assistance. Since the workers are denied
eligibility to apply for TAA, the workers cannot be certified
eligible for ATAA.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of RR Donnelley, Von
Hoffman Division, a subsidiary of RR Donnelley & Sons Company,
including on-site leased workers from Riverside Staffing,
Eldridge, Iowa, are denied eligibility to apply for adjustment
assistance under Section 223 of the Trade Act of 1974, as amended,
and are also denied eligibility to apply for alternative trade
adjustment assistance under Section 246 of the Trade Act of 1974,
amended.
Signed in Washington, D.C. this 6th day of October, 2011

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






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