DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-94,932

DUNAN PRECISION MANUFACTURING INC.
A SUBSIDIRAY OF DUNAN PRECISION
INCLUDING WORKERS WHOSE WAGES ARE REPORTED UNDER
LL ROBERTS COMPANY DBA KEY BUSINESS SOLUTIONS
AND INCLUDING ON-SITE LEASED WORKERS FROM LGS STAFFING COMPANY
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;
(2)(B)(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
(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; AND
(ii) the shift/acquisition must have contributed
importantly to the workers' separation or
threat of separation.

The investigation was initiated in response to a petition
filed on June 25, 2019 by a State Workforce Office on behalf of
workers and former workers of DunAn Precision Manufacturing Inc.,
a subsidiary of DunAn Precision, Memphis, Tennessee (DunAn
Precision Manufacturing). The workers' firm is engaged in
activities related to the production of aluminum microchannel
coils and copper tubing primarily used for HVAC manufacturing.
The subject worker group (DunAn Precision Manufacturing)
includes workers whose wages are reported under LL Roberts Company
DBA Key Business Solutions and includes on-site leased workers
from LGS Staffing Company.
During the course of the investigation, information was
collected from the petitioner, and workers' firm.
Section 222(a)(1) has been met because a significant number
or proportion of the workers in DunAn Precision Manufacturing
have become totally or partially separated, or are threatened to
become totally or partially separated.
Section 222(a)(2)(B) has been met because the workers' firm
has shifted to a foreign country the production of a(n) article
like or directly competitive with the aluminum microchannel coils
and copper tubing produced by the subject workers which
contributed importantly to worker group separations at DunAn
Precision Manufacturing.

Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of DunAn Precision
Manufacturing, who are engaged in activities related to the
production of aluminum microchannel coils and copper tubing, 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 DunAn Precision Manufacturing Inc., a
subsidiary of DunAn Precision, including workers whose wages
are reported under LL Roberts Company DBA Key Business
Solutions and including on-site leased workers from LGS
Staffing Company, Memphis, Tennessee, who became totally or
partially separated from employment on or after June 24,
2018, 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 24th day of July 2019.

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