Yeah, I agree with the above posters. It is very likely that this is something like cradle cap.
This is super random, but does she use Johnson & Johnson baby shampoo by any chance? I've heard its been known to dry/clog pores in the scalp. I used it a few years ago and had serious clogging/crusting and when I stopped using it, it went away. I'd look into a different shampoo and shampooing more frequently..
Good luck with everything!
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