An organization chart placing site coordinators and consultants under your direction, engagement letters with audit firms you select, policies bearing your approval but drafted by others, budget approvals, and correspondence in which staff take instruction from you. Task lists in your own name work against you.
Collect the paper that shows delegation
Adjudicators read function-manager petitions for evidence of other people doing the work. The most persuasive items are contemporaneous: an audit program approved by her and executed by named site coordinators, with their reports addressed to her; an engagement letter with an external safety consultant that she signed on the company's behalf; a training calendar she approved and a trainer's invoice; regulatory filings signed by her and prepared by a compliance administrator; a budget request she submitted and controls. Add the affiliate's organization chart showing her reporting to its president and the coordinators reporting to her on safety matters even if they sit in operations for other purposes.
Include the equivalent set from Canada for the qualifying year. Avoid a résumé that lists audits she performed, procedures she wrote and training she delivered, unless it is framed as work she did before her role became managerial. The documents should make it hard to conclude she is a working compliance officer with a director's title.