Possibly, as a function manager. L-1A managerial capacity includes managing an essential function at a senior level with discretion over its operations, even without subordinate managers, provided she is not primarily performing the function's routine tasks herself.
Function management is a recognized route, with a catch
The regulations define managerial capacity to include an employee who manages an essential function within the organization, exercises discretion over its day-to-day operations and works at a senior level in the hierarchy. Transportation and cold-chain logistics is plainly essential to a produce distributor, so the question is what she actually does. If she negotiates carrier contracts, sets routing policy, owns the freight budget and directs the dispatchers who execute it, the function-manager description fits. If she is on the phone arranging loads for most of the day, it does not, whatever the title. The catch is that officers look for someone else performing the routine work; the petition should name the dispatchers, describe their duties and show that the manager's own time is spent on decisions, escalations and contracts. A staffing plan that leaves her as the only person in logistics on the U.S. side will be read as a dispatcher's role.
Hypothetical example: a cold-storage routing manager says she oversees freight strategy, but the U.S. unit has no dispatch staff and expects her to assign every truck herself. The first review should produce a weekly duty estimate and an organization chart that names the people performing routine load coverage. Carrier contracts, budget approvals and escalation records can establish senior discretion; a calendar full of individual load bookings points the other way. Correct the staffing plan before filing, not by retitling the same role. The underlying transfer also requires a full continuous twelve months of qualifying foreign employment within the relevant three-year period. Keep that threshold separate from the managerial-capacity analysis: meeting one does not cure a weak showing on the other.