No. Explain the company knowledge the trainer actually holds and why the US assignment requires it. Selection and communication ability are not the complete legal showing.
Connect a lesson to an actual work problem
Identify an exception or process decision the employee understands and provide reliable evidence of applying it. Distinguish advanced company procedures from general skills anyone in the occupation might teach. Avoid claiming that every qualifying process must be secret, or that a training title excuses the qualifying employment and company requirements.
What the statute forbids is an arrangement that amounts to labour for hire: one where the client principally controls and supervises the worker, or where the placement is not connected to a product or service requiring the petitioner's specialized knowledge. If the replacement would need months inside the company to learn coating formulations, calibration tolerances and the failure modes discovered during four seasons of trials, that is knowledge special to the organisation. Uniqueness is not required, so there is no need to claim that nobody else understands the system; what is needed is a factual description of knowledge built inside the organisation over time and applied to identifiable pieces of work.