DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-40,529

L-S ELECTRO-GALVANIZING COMPANY
CLEVELAND, OHIO

Notice of Revised Determination
on Reconsideration

By letter of May 23, 2002, the company requested
administrative reconsideration regarding the Department=s
Negative Determination Regarding Eligibility to Apply for Worker
Adjustment Assistance, applicable to the workers of the subject
firm.
The initial investigation resulted in a negative
determination issued on April 22, 2002 based on the finding that
imports of corrosion-resistant zinc coated cold rolled steel
coils did not contribute importantly to worker separations at the
Cleveland plant. The denial notice was published in the Federal
Register on May 2, 2002 (67 FR 22112).
To support the request for reconsideration, the company
official provided clarification concerning the relationship
between the subject firm and their sole customer. The company
official indicated that their sole customer was a majority owner
(Joint Venture) of L-S Electro-Galvanizing Company (LSE),
Cleveland, Ohio and that the subject firm was in direct support
of that operation. The subject firm applied a corrosion-
resistant zinc coating on cold rolled steel coil substrate
produced by the customer. The official further indicates that
the closure of the customer facility at the same location as the
subject firm is the reason for the closure of the subject plant.
The company official further indicated that the sole customer
was certified for TAA under TA-W-38,362.
Clarification by the company and review of the initial
investigation show that the subject firm was in direct support of
a TAA certified facility (TA-W-38,362, LTV Steel Company, Inc.,
Cleveland, Ohio) that had a majority controlling interest in the
subject firm's operation. Since the workers of the subject firm
were in direct support of the affiliated TAA certified facility,
they meet all eligibility requirements of the Trade Act of 1974,
as amended.
Conclusion
After careful review of the additional facts obtained on
reconsideration, I conclude that increased imports of articles
like or directly competitive with those produced at L-S Electro-
Galvanizing Company, Cleveland, Ohio, contributed importantly to
the declines in sales or production and to the total or partial
separation of workers at the subject firm. In accordance with
the provisions of the Act, I make the following certification:





"All workers of L-S Electro-Galvanizing Company, Cleveland,
Ohio, who became totally or partially separated from
employment on or after December 3, 2000 through two years
from the date of this certification, are eligible to apply
for adjustment assistance under Section 223 of the Trade Act
of 1974."

Signed in Washington, D.C. this 20th day of June 2002.


/s/ Edward A. Tomchick
________________________
EDWARD A. TOMCHICK
Director, Division of
Trade Adjustment Assistance



DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-40,529

L-S ELECTRO-GALVANIZING COMPANY
CLEVELAND, OHIO

Negative Determination Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974 (19
USC 2273) as amended by the Omnibus Trade and Competitiveness Act
of 1988 (P. L. 100-418), the Department of Labor herein presents
the results of an investigation regarding certification of
eligibility to apply for worker adjustment assistance.
In order to make an affirmative determination and issue a
certification of eligibility to apply for adjustment assistance,
each of the group eligibility requirements of Section 222 of the
Act must be met:
(1) that a significant number or proportion of the workers
in the workers' firm, or an appropriate subdivision
thereof, have become totally or partially separated, or
are threatened to become totally or partially
separated;

(2) that sales or production, or both, of the firm or
subdivision have decreased absolutely; and

(3) that increases of imports of articles like or directly
competitive with articles produced by the firm or
appropriate subdivision have contributed importantly to
the separations, or threat thereof, and to the absolute
decline in sales or production.

The investigation was initiated on January 7, 2002 in
response to a petition filed by the Union, United Steel Workers
of America, Local 9126, on behalf of workers at L-S Electro-
Galvanizing Company, Cleveland, Ohio. The workers apply
corrosion-resistant zinc coating to cold rolled steel coils.
The investigation revealed that criterion (3) has not been
met.
Sales, production and employment declined at the subject
firm during the relevant period.
The subject firm does not import and has no plans to begin
importing in the future.
The U.S. Department of Labor conducted a survey of a major
customer of L-S Electro-Galvanizing Company, Cleveland, Ohio,
regarding their purchases of zinc coating processes applied to
its cold rolled steel coils in 2000 and 2001 and for the time
period of January through March 2001 and 2002. The respondent
reported decreasing purchases from the subject firm and other
domestic sources. There were no customer imports of articles
like or directly competitive with those produced by the subject
firm.


Conclusion
After careful review, I determine that all workers of L-S
Electro-Galvanizing Company, Cleveland, Ohio, are denied
eligibility to apply for adjustment assistance under Section 223
of the Trade Act of 1974.
Signed in Washington, D. C. this 22nd of April 2002

/s/ Linda G. Poole
____________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance