DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-41,255

AMERICAN GREETINGS CORPORATION
CORBIN, KENTUCKY

Notice of Negative Determination
Regarding Application for Reconsideration; A Corrected
Republication in Full

A corrected republication in full is necessary for the
Notice of Negative Determination Regarding Application for
Reconsideration applicable to workers of American Greetings
Corporation, Corbin, Kentucky, TA-W-41,455. The notice was
published in the Federal Register on July 9, 2002 (FR 67 45546),
FR Document 02-17147. The word "not" was inadvertently omitted
from the decision, and this correction is issued to insert the
word "not" in the third paragraph, 4th line between the words
"did" and "contribute". The notice is republished as follows:
By application received on June 6, 2002 and June 7, 2002, a
worker and the Teamsters, Local 89, respectively, 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 13, 2002, and
published in the Federal Register on June 4, 2002 (67 FR 38521).
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 American Greetings
Corporation, Corbin, Kentucky was denied because the "contributed
importantly" group eligibility requirement of Section 222(3) of
the Trade Act of 1974, as amended, was not met. Increased
imports did not contribute importantly to worker separations.
The denial was based on Corbin, Kentucky production of printed
greeting card sheets being consolidated with another American
Greetings Corporation domestic production facility. The company
did not import printed greeting card sheets during the relevant
period.
The petitioners allege that American Greetings Corporation
has been forced to restructure the company in order to cut costs,
which resulted in lost jobs at the Corbin plant over a three year
period, leading to the final closing of the subject plant. The
petitioners further allege that the jobs lost at the Corbin plant
is the result of American Greetings moving manufacturing
production (candles, party goods, print greeting cards) from the
Corbin plant to China, Mexico, Taiwan and Hong Kong. A copy of
a label attached to the petitioner(s) request depicts that a
product produced in China was imported directly to American
Greetings Corp., Corbin, Kentucky.
A review of the initial decision and recent clarification by
the company indicate there was no decline in the firm's customer
base. Any declines in plant sales or production (party goods,
gift wrap and bows, candles, printed greeting card sheets) are
due to shifts in plant production to other domestic locations.
That is, virtually all plant production was shifted to other
domestic sources, except for a small portion of printed greeting
card sheets that were ordered from a foreign source and scheduled
to enter the United States beyond the relevant period of the
investigation. In any event, the amount of printed greeting card
sheets to be imported is relatively low and would not be
considered a major contributing factor to the layoffs at the
subject firm.
Further review and contact with the company shows that the
preponderance in the declines in employment at the subject plant
is related to other factors unrelated to imported products "like
or directly competitive" with what the subject plant produced.
That is, internet card competition and cost cutting measures such
as the elimination of some high cost product lines and the
consolidation of subject plant production to other affiliated
domestic locations to cut costs are the dominant factors leading
to the layoffs at the subject plant.
The Department contacted the company regarding a label
attached and labels referenced in the petitioner's request for
reconsideration. The company indicated that some of the products
produced by the subject plant have been intermittently imported,
but the amount of each type of product imported was negligible
during the relevant period.
In a further allegation by the petitioner, it is indicated
that the subject plant candle production was shifted to China and
imported back to the United States. The company indicated
candles imported back to the United States were negligible during
the relevant period.
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 21st day of June 2002.


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