DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,010

VELSICOL CHEMICAL LLC
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)(II)(aa) imports of articles like or directly
competitive with articles into which one or more
component parts produced by such firm are directly
incorporated 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 petition
filed on October 25, 2011 by the United Steelworkers Local 357
on behalf of workers of Velsicol Chemical LLC, Memphis,
Tennessee (Velsicol). The workers’ firm is engaged in
activities related to the production of
Hexachlorocyclopentadiene. Hexachlorocyclopentadiene is used as
an intermediate for a chemical called endosulfan and in the
production of Chlorendic Anhydride.
During the course of the investigation, information was
collected from the workers’ firm.
Section 222(a)(1) has been met because 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.
Section 222(a)(2)(A)(i) has been met because the sales
and production of Hexachlorocyclopentadiene by Velsicol have
decreased absolutely.
Section 222(a)(2)(A)(ii)(II)(aa) has been met because
company imports of Chlorendic Anhydride like or directly
competitive with Chlorendic Anhydride directly incorporating
Hexachlorocyclopentadiene produced by Velsicol have increased.
Finally, Section 222(a)(2)(A)(iii) has been met because
the increased company imports of Chlorendic Anhydride
contributed importantly to the worker group separations and
sales/production declines at Velsicol.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Velsicol Chemical
LLC, Memphis, Tennessee, who are engaged in activities related
to the production of Hexachlorocyclopentadiene 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 LLC, Memphis, Tennessee,
who are engaged in activities related to the production of
Hexachlorocyclopentadiene who became totally or partially
separated from employment on or after February 13, 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/ Michael W. Jaffe
______________________________
MICHAEL W. JAFFE
Certifying Officer, Office of
Trade Adjustment Assistance