Where the process is taught through mentorship on the floor rather than written procedures, that gap should be documented honestly: identify who trained the employee, over what period, and what specific adjustments or techniques were learned, rather than manufacturing a written manual that did not previously exist.
Explain an oral-transfer process without inventing paper records
Ask supervisors and colleagues who can corroborate the training to describe, in writing, what the employee actually learned and when. A retroactively created manual can be useful context, but should be labelled as a current summary rather than presented as a contemporaneous training record if it was not.
Use evidence created during ordinary work wherever possible: mentor statements, shift assignments, maintenance tickets, annotated diagrams, training attendance, quality records, and messages resolving particular production failures. Each declarant should explain direct knowledge and dates. A new summary may organize the material, but label it as prepared for the petition rather than backdating it. Connect every example to the proposed U.S. tasks and the petitioning organization’s product or process. The recurring mistake is manufacturing a polished manual that falsely appears contemporaneous while ignoring credible shop-floor records.
Hypothetical example: a Clarence-Rockland paper-converting equipment specialist learned tension-control adjustments beside a senior operator over several years. The employer has no formal curriculum, but retains work orders bearing the employee’s notes, production reports showing reduced web breaks after specific changes, and rosters identifying the mentor. Supervisors prepare signed accounts that distinguish what they observed from what others told them. The U.S. assignment plan then identifies the same equipment configuration and explains how the specialist will transfer those practices, without pretending an oral apprenticeship produced certificates that never existed.