To my knowledge, merely being an employee of a company does not make one a lobbyist for that company. Moreover, there is a substantive difference between approaching the government to advocate a specific policy favorable to a client, and being approached by the government seeking data to inform policy decisions.
Therefore, I believe that there is no requirement for disclosure. I can't cite relevant case law, but perhaps someone else can.
OPH: Any thoughts on this?
It sounds like it's not going to be possible to sort this out without the text of the statute to see exactly how they draw the line. If you see it posted, I'd be grateful if you could ding me. Thanks.