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PENHOLD · L-1B FIELD GUIDE

Should a project schedule identify who controls work at each customer site?

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THE DIRECT ANSWER

Where relevant, explain the actual supervision and placement arrangement rather than relying only on dates and locations. The offsite conditions concern substance.

Make the assignment understandable

Identify who directs daily work and how the placement connects with the petitioner’s product or service requiring specialized knowledge. A timeline alone cannot answer the control or labor-for-hire questions.

Training records, permitted project descriptions, internal qualification documents, and other evidence that accurately explains the knowledge can usually support the claim, and the company should decide in advance what can be shared and what needs special handling. Internal design standards, the sequence library and its revision history, commissioning checklists that carry the employer's own methodology, training material written for new technicians, and project records showing which installations the specialist personally configured all describe knowledge that is specific to the organization. Use corporate ownership records and operating evidence for the organization link; use contracts, payroll, tax documents, leave records, and supervisor letters for the foreign employment; use training records, controlled manuals, work samples, and a detailed US assignment for the knowledge claim.