DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-40,498

PRECISION TWIST DRILL CO.
RHINELANDER, WISCONSIN

Notice of Negative Determination
Regarding Application for Reconsideration

By application dated June 10, 2002, the United Steelworkers
of America, District-2, Local 9408 requested administrative
reconsideration of the Department's negative determination
regarding eligibility to apply for Trade Adjustment Assistance
(TAA), applicable to workers and former workers of the subject
firm. The denial notice was signed on May 7, 2002, and published
in the Federal Register on May 17, 2002 (67 FR 35140).
Pursuant to 29 CFR 90.18(c) reconsideration may be granted
under the following circumstances:
(1) If it appears on the basis of facts not previously
considered that the determination complained of
was erroneous;
(2) if it appears that the determination complained of
was based on a mistake in the determination of facts
not previously considered; or
(3) if in the opinion of the Certifying Officer, a mis-
interpretation of facts or of the law justified
reconsideration of the decision.


The petition for the workers of Precision Twist Drill Co.,
Rhinelander, Wisconsin was denied because the "contributed
importantly" group eligibility requirement of Section 222(3) of
the Trade Act of 1974, as amended, was not met. The "contributed
importantly" test is generally demonstrated through a survey of
customers of the workers' firm. The survey revealed that none of
the respondents increased their purchases of imported twist drill
bits, while decreasing their purchases from the subject firm
during the relevant period. The investigation also revealed that
Precision Twist Drill Co., Rhinelander, Wisconsin did not import
articles "like or directly competitive" with the products
produced at the subject plant. The separations at the subject
plant were due to a transfer of plant production to another
domestic facility.
The petitioner supplied additional information based on a
company announcement dated April 25, 2002 indicating that the
Rhinelander facility would close down and approximately two-
thirds of the blank drill bit production would be manufactured
overseas.
Based on data supplied during the initial investigation and
further contact with the company, the shifts in plant production
did not occur during the relevant period of the investigation.
The shift in the production of blank drill bits to foreign
sources began during July 2002. Any potential future company
imports of blank drill bits are beyond the relevant period of the
initial investigation.
The petitioner further alleges the subject plant once
manufactured drills for Boeing and that production was shifted to
Crystal Lake, Illinois. Since then, the company indicated they
would shift that production to Brazil.
Recent information provided by the company indicates that
the product (special drill bits) produced for Boeing was never
produced at the subject plant. Therefore, the shift in
production to Brazil by the Crystal Lake plant is not a relevant
factor that is considered in meeting the "contributed
importantly" group eligibility requirement of Section 222(3) of
the Trade Act of 1974, as amended.
Conclusion
After review of the application and investigative findings,
I conclude that there has been no error or misinterpretation of
the law or of the facts which would justify reconsideration of
the Department of Labor's prior decision. Accordingly, the
application is denied.

Signed at Washington, D.C. this 11th day of July 2002.

/s/ Edward A. Tomchick


EDWARD A. TOMCHICK
Director, Division of
Trade Adjustment Assistance