Possibly, but the petition must show she will primarily manage rather than perform the operational work. With a small staff, the evidence usually turns on whether her subordinates are supervisors or professionals and how much of her week is spent directing them.
Small sites are judged on function, not headcount alone
Regulations recognise that a manager can qualify without a large staff if she manages an essential function at a senior level, but the petition must explain the function, its importance to the business, and the discretion she exercises over it. Hypothetical example: an East Hants cold-storage company's U.S. cross-dock has a site supervisor, two forklift operators and a part-time clerk. If the transferee will set rates, negotiate carrier contracts, approve capital spending, hire and discipline staff and report to the Canadian owners, that is managerial work over a function even though the team is small. If she will drive the forklift when someone is sick and answer the phones most of the day, the role is operational. Write an honest weekly time allocation. Reviewers compare the claimed duties with the size and revenue of the operation, so a plan to grow the team is useful supporting evidence, not a substitute for current facts.
Hypothetical example: an East Hants mushroom-substrate producer transfers its purchasing director to a small U.S. facility. The first review should produce a weekly-duty table: vendor negotiations, budget authority, personnel decisions, and operating tasks. Signed delegation limits, organization charts, and employment agreements settle whether she directs an essential function or simply keeps production moving. If routine hands-on work dominates because no one else can do it, the company should address staffing before claiming a management position.