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 a valid organisational approval.
Question 1 – Who owns the MOE?
Question 2 – Who is responsible for the contents of the MOE?
Answer It’s the same person isn’t it? – The Quality Manager!
Well actually it’s not! Whilst it is quite normal for the Quality 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 Quality 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.
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 he is 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 assessment of this must be demonstrated to be independent from the physical delivery of the process and procedures.
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 four 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 system procedures including the methods of qualifying mechanics, inspection, certifying
staff and quality audit personnel.
Contracting operator procedures and paperwork.
Sofema Aviation Services provides regulatory training in all aspects of EASA Part 145 compliance. For further information please see www.sassofia.com or email: office@sassofia.com
