Not by itself. Supervising non-professional employees is treated as managerial only when the role also carries authority over personnel decisions and discretion over the operation, or when the person manages an essential function rather than the workers. The petition must describe that wider authority.
Describe the function, not the foreman
The regulatory definition of managerial capacity looks for someone who manages the organization, a department, a subdivision, a function or a component; who supervises and controls the work of other supervisory, professional or managerial employees, or manages an essential function; who has authority to hire and fire or to recommend those actions; and who exercises discretion over day-to-day operations. A first-line supervisor of non-professionals is excluded unless the supervised employees are professional. For the Kent service manager the honest route is the essential-function argument: he will own the U.S. service operation, decide which manufacturer warranties the branch carries, set service pricing, negotiate with dairy customers and control parts purchasing, while technicians perform the installations. If in truth he will spend most days on a ladder with a wrench, the category does not fit and no amount of drafting should be used to pretend otherwise.
Hypothetical example: a packaging-line manager is called a director, yet her weekly calendar shows she personally repairs machinery for most of each shift. The first review uses that calendar, organization chart and personnel authority to test the actual capacity. A title cannot settle the question. The company must either staff the operational work below her and document her control of the function, or choose a category that fits the hands-on position.