Through the document-control system’s revision history, draft files with metadata, review comments, meeting records and a statement from the quality director confirming authorship and the manager’s purely approving role.
Authorship is proven by the trail, not the signature block
Controlled documents in a quality system are usually released under a manager’s signature even when an engineer wrote them, and USCIS understands this once it is explained. The evidence of authorship lives in the document-control records: the change requests she raised, the draft versions with her name in the file properties, the review comments she answered, the training she delivered on each revision and the effectiveness reviews she led. Export those records with dates, add the release history showing the manager’s approval role, and have the quality director state in writing who wrote the procedure and who approved it.
Corroborate with customer correspondence in which she answered audit questions about the procedure. This trail demonstrates both that the knowledge is the company’s and that hers is advanced, which is the pair of facts the category turns on. Hypothetical example: a hand-tool maker protects its manufacturing instructions as confidential and hesitates to include them.
It can describe the process in detail, provide redacted extracts, and explain the confidentiality treatment rather than omit the evidence entirely. The first review should match each claimed skill to a dated training record or controlled document. A bare assertion that the employee is indispensable fails because it does not show what she knows or how the company recognizes it.