What are some circumstances where you perhaps need to submit a variance to TWC for approval on a prospective instructor? Offering a program where formal education in the past was not common, such as the culinary field; submitting a request for variance for a potential instructor due to limited formal education opportunities could be warrented. This is common among potential candidates that worked in Europe over the past several decades. Formal education was not readily available and/or not comprable to degree granting institutions in America. But, their experience is overwhelming and could be interpreted to be equivalent to American degrees.