Possibly. Direct supervision can support personnel management if the direct reports are actually supervisory, professional or managerial employees; a site foreman who genuinely directs a crew may be supervisory. If the direct reports do not meet those definitions, the case would need another basis, such as managing an essential function at a senior level.
Function management is the harder road, and often the honest one
The definition of managerial capacity offers two routes. One rests on directing other supervisors, professionals or managers; the other rests on managing an essential function of the organization without necessarily supervising anyone. Occupational labels do not decide the first route. A site foreman who genuinely assigns and oversees a crew's work may be a supervisory employee, while a trades worker without supervisory duties is not; a scheduler or estimator is professional only if the position normally requires the relevant degree. The petition should therefore document what each direct report actually does and whether Deirdre has authority over personnel actions. If those reports do not qualify, function management may still work, but it demands specificity: identify the essential function, explain why it matters to the organization, show that Deirdre operates at a senior level, and document who performs the hands-on work. An organizational chart, duty descriptions and delegation records should support whichever branch is claimed.
Hypothetical example: A Canadian manufacturer of reusable medical trays wants its product-strategy director to lead a U.S. subsidiary. The first review should count a full twelve months on qualifying overseas payroll during the three years before filing, verify the corporate link, and map who will perform day-to-day production after transfer. Minutes assigning authority, payroll for subordinate staff, and a chart showing decision layers settle the managerial question better than an impressive title. A director who personally processes every order may be a key employee without managing a function at the required level. The company should also plan against the seven-year maximum period for this classification. Hiring plans that never remove operational tasks from the transferee can undermine both the initial description and a later extension.