DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-92,551

BRUNNER MANUFACTURING COMPANY, INC.
INCLUDING ON-SITE LEASED WORKERS FROM MANPOWER
GREENWOOD, SOUTH CAROLINA

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(b) of the Act, 19 U.S.C. § 2272(b), can be
satisfied if the following criteria are 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 or service 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
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 January 13, 2017, on behalf of workers of Brunner
Manufacturing Company, Inc., including on-site leased workers
from Manpower, Greenwood, South Carolina (Brunner Manufacturing
Company). The workers' firm is engaged in activities related to
the production of cold-formed fasteners used in finished
articles such as tractors and lawn mowers. The subject worker
group is engaged in activities related to assembling, packaging,
and shipping the fasteners produced by the subject firm.
Workers at the subject firm are not separately identifiable by
the article produced.
During the course of the investigation, information was
collected from the workers' firm and the petitioners.
Section 222(b)(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(b)(2) has been met because Brunner
Manufacturing Company, Inc. is a Supplier 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 is related to the finished article that
was the basis for such certification.
Section 222(b)(3)(A) has been met because the cold-formed
fasteners produced by Brunner Manufacturing Company for a firm
that employed a certified worker group accounted for at least
20 percent of the production or sales of Brunner Manufacturing
Company.
Section 222(b)(3)(B) has been met because the loss of
business by Brunner Manufacturing Company with the firm that
employed a certified worker group contributed importantly to
worker separations at Brunner Manufacturing Company.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Brunner Manufacturing
Company meet the worker group certification criteria under
Section 222(b) of the Act, 19 U.S.C. § 2272(b). In accordance
with Section 223 of the Act, 19 U.S.C. § 2273, I make the
following certification:
"All workers of Brunner Manufacturing Company, Inc.,
including on-site leased workers from Manpower, Greenwood,
South Carolina, who became totally or partially separated
from employment on or after January 12, 2016, 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 10th day of March 2017.
/s/Del Min Amy Chen
______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance