UNITED STATES DEPARTMENT OF LABOR
Employment and Training Administration
TA-W-96,832
STTS USA, INC.

DBA SATYS SEALING & PAINTING USA

PORTLAND, OREGON
Certification Regarding Eligibility
To Apply for Trade Adjustment Assistance for Workers

In accordance with Section 223 of the Trade Act of 1974, as amended ("the Act"), 19 U.S.C.
§ 2273, the Department of Labor ("Department") herein presents the results of an investigation
regarding certification of eligibility to apply for Trade Adjustment Assistance ("TAA") for workers.

The investigation was initiated in response to a TAA petition dated April 5, 2021 and
filed on April 6, 2021 by a State Workforce Office, on behalf of workers and former workers of
STTS USA, Inc., dba Satys Sealing & Painting USA, Portland, Oregon (hereafter referred to as the
"worker group"). In accordance with 20 C.F.R. 618.110 a worker group is defined as, ""¦inclusive
of teleworkers and staffed workers."

The worker group is engaged in activities related to the supply of aircraft painting/sealing
services and are not separately identifiable by service.

The petition alleged that worker separations, or threats thereof, were due to the workers'
firm holding the Boeing aircraft paint contract and Boeing having locations outside of the USA
performing like work.

During the course of the investigation, the Department collected information from the
petitioner(s), the workers' firm, and other relevant sources.

The group eligibility requirements for workers of a firm under Section 222(b) of the Act,
19 U.S.C. § 2272(b), are satisfied if the following criteria are met:

Employment Criterion

(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.
20 C.F.R. 618.225(e)(1)(ii) states that an "Analysis of separation data must generally
consist of a: "(A) Comparison of employment on the petition date to employment on the date that is
1 year prior to the petition date; (B) Review of employment activity during the 1-year period prior
to the petition date; and (C) Review of evidence provided by the workers' firm regarding actual
and threatened separations that occur, or are scheduled to occur, after the petition date."

The Department determines that the employment criterion has been met.

Supplier/Downstream Producer Criterion

(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 subsection (a), and such supply
or production is related to the article or service that was the basis for such certification
(as defined in subsection (c) (3)and (4)); and
Section 222(c)(3) of the Trade Act, 19 U.S.C. § 2272(c), defines the term "Downstream
Producer" to mean "a firm that performs additional, value-added production processes or services
directly for another firm for articles or services with respect to which a group of workers in such
other firm has been certified under subsection (a)." For purposes of this "Downstream Producer"
definition, the Trade Act provides that, ""¦value-added production processes or services include
final assembly, finishing, testing, packaging, or maintenance or transportation services."

The Department determines that the Downstream Producer criterion has been met.

Contributed Importantly Criterion

(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
determined under paragraph (I).
20 C.F.R. 618.225(e)(5) states that the loss of business with the aforementioned firm
must occur during the 1-year period prior to the petition date to have contributed importantly to
separations or threat of separations at the workers' firm." Sec. 222(c) of the Trade Act and 20

C.F.R. 618.110 defines contributed importantly as, "a cause that is important but not necessarily
more important than any other cause."
The Department determines that the contributed importantly criterion has been met.
Conclusion
After careful review of the facts obtained in the investigation, I determine that workers
of STTS USA, Inc., dba Satys Sealing & Painting USA, Portland, Oregon, who are engaged
in activities related to the supply of aircraft painting/sealing services 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 STTS USA, Inc., dba Satys Sealing & Painting USA, Portland, Oregon, who
became totally or partially separated from employment on or after April 5, 2020 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 31st day of August, 2021.

/s/ Hope D. Kinglock
_______________________
HOPE D. KINGLOCK
Certifying Officer, Office of
Trade Adjustment Assistance