Sofema Aviation Services (SAS) www.sassofia.com looks at the roles and responsibilities related to the production and management control of the Maintenance Organisation Exposition (MOE)
Introduction
The purpose of the maintenance organisation exposition (MOE) is to identify the procedures, means and methods of the approved EASA 145 organisation. An up-to-date and effective MOE is crucial to maintaining valid organisational approval.
1/To properly monitor the EASA Part 145 approval, the organisation must identify the particular edition of the MOE and subsequent changes to it. Therefore the MOE requires direct administration control through an identified person – usually the compliance manager – (but not always)
2/ For each detailed procedure described within the MOE, the Part 145 organisation should address the following questions:
o What and when must it be done?
o Where and how must it be done?
o Who should do it?
o Which procedural documentation should be used?
3/ EASA requires independence within the role of compliance auditing
- This means that the compliance manager (or auditor) should independently audit the content of the MOE procedures (independence is not possible if the CM is the owner of the content!)
- There is a difference between ownership of content and management of the MOE
o In most (but not all companies) the CM is the administrative manager of the MOE means he is responsible for the physical well-being, correctness and presentation of the MOE to the Authority.
o Managing the administrative content of the MOE in no way impacts the integrity of the process or precludes the oversight and independence of compliance audit
This means the CM can manage the content and independently audit it as well!
Important Note – Managing the MOE is not the same as being responsible for the specific content – means as a CM I will format and load “your content” into the MOE.
Please accept that you (The Nominated post holder / business areas manager) – are directly responsible for the content which allows me (The CM) to both independently audit the content and manage the document.
4/ EASA typically expects a Single Point of Contact within an organisation
- This is often the Compliance Manage but could be for example the Accountable Manager or other.
4/ Regarding everything else to be discussed it is an organisational responsibility to determine who does what in terms of roles and responsibilities
- The AM has overall authority.
- Each Nominated Manager is responsible for the following within their respective business areas
o Process and Procedures
o Safety Management
o Delivery of QC Production Process
o Staff Training & Competency
- The Compliance Manager is Responsible for the Content of the Compliance Procedures only within the MOE (must be audited separately / independently)
- The Compliance Manager independently audits the process and procedures which are owned by the Nominated Manager (NP)
- The Safety Manager is Responsible for the Related Safety Content within the MOE – May be audited by the CM (Independent)
Important Note
Please note However that there are multiple other options within an organisation. Means another person may manage the MOE – this is after all an administrative task – managing and controlling the document (over 90% of EASA organisations this role is performed by the compliance manager) however it is not compulsory and there are other options
Who decides on other options? (essentially it is the organisations choice)
- Ultimately it is the Accountable Manager who must agree the specific structure of the organisation as well as admin roles and responsibilities
- The AM decides on the business structure within his organisation and how the reporting lines are managed.
Who is a Nominated Post Holder within an EASA Part 145 Organisation?
In general if you have specific responsibility for high level process and procedures you are considered a post holder (Technical Director – Base Maintenance Manager – Line Maintenance Manager – Workshop Manager may all be post holders in one organisation)
- Alternatively, only the Technical Director could be considered the NP if he is the only person responsible for all process and procedures within a smaller organisation and the other managers report to him)
Consider also the following information for additional guidance.
Who owns the Maintenance Organisation Exposition – MOE?
Whilst it is quite normal for the Compliance Manager to be responsible for the overall integrity of the MOE, to ensure it is presented to the Regulator when required and to reference the MOE during compliance audits.
It is not normal however for the Compliance Manager to be responsible for the procedural contents of the MOE – why?
- Well put quite simply the procedural contents of the MOE should be the responsibility of the business area owner or Manager.
- How procedures are enacted within the business is the prerogative of the Production Manager and Ultimately the Post Holder (PH) or Nominated Person (NP) rather than the Quality Manager.
Note – The concern relates to the fact that if the Quality Manager is responsible for writing the maintenance procedures he is deciding what should be done and how it should be done. (Means that in a way the CM is actually managing the business)
- Thereby creating a conflict, rather than independently assessing the effectiveness and compliance of a given procedure he is actually the author and owner of the text!
- Compliance with the contents of the MOE shall assure compliance with the requirements of Part 145, In fact this becomes a prerequisite to obtaining and retaining a maintenance organisation approval certificate.
- However the compliance assessment of this must be demonstrated to be independent from the physical delivery of the process and procedures.
Regulatory Expectations
- It is understood that the competent authority or in the case of third countries EASA direct will approve the organisation as long as the procedures are being followed and work standards maintained.
- It is further understood that the Regulatory Authority reserves the right to suspend, limit or revoke the approval of the organisation if there is evidence that procedures are not followed or standards not upheld.
The MOE typically covers the following main parts:
- The management MOE covering the parts specified earlier.
- The maintenance procedures covering all aspects of how aircraft components may be accepted from outside sources and how aircraft will be maintained to the required standard.
- The quality & safety system procedures including the methods of qualifying mechanics, inspection, certifying staff and quality audit personnel.
Next Steps
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Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com) provide multiple courses covering all regulatory and vocational activities within the 145 organization, please see the websites or email team@sassofia.com
Tags:
Accountable Manager, Base Maintenance Manager, Compliance Manager, Each Nominated Manager, EASA Part 145 Organisation, Line Maintenance Manager, Maintenance Organisation Exposition (MOE), Management Control, Nominated Post Holder, QC Production Process, Quality Manager, Safety Management, SAS blogs, Staff training, Technical Director, Workshop Manager
