March 15, 2024

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Sofema Aviation Services (SAS) www.sassofia.com considers key aspects of an EASA Compliant MOE (Maintenance Organisation Exposition) in use by Third Countries 145 Organisations.

Introduction – Preliminary Considerations.

The MOE shall be customized by each organisation to demonstrate how they comply with:

  • Part-145. This includes requirements of Part-M or Part-ML referred to in Part-145 regulation, as applicable
  • The Foreign Part-145 User Guides (ref. “Foreign Part-145 approvals – documentation Index”, FO.CAO.00136-XXX)

For each detailed procedure described within the MOE, the Part-145 organisation should address the following fundamental questions:

  • What must be done?
  • Who should do it?
  • When must be done?
  • Where must it be done?
  • How must it be done?
  • Which procedure(s)/form(s) should be used?

The organisation may choose to use another format to the one described in this user guide, as long as all the applicable sections of the regulation are addressed and cross-referenced.

Important Note – However, for standardisation purposes, to facilitate the production of the MOE by the Maintenance Organisation and review by the assigned inspector, it is recommended to:

  • Strictly adhere to the MOE structure, chapters/paragraph numbering titles and expected content of this User Guide.
  • The Maintenance Organisation should however customize the document to its own organisation and may also include additional paragraphs where necessary.

Concerning An MOE Serving Multiple Regulatory Approvals

Part-145 AMC material states that: “Where an organisation uses a different format, for example, to allow the exposition to serve for more than one approval …”

  • This AMC has to be read in conjunction with the implementing rules of the Basic Regulation, thereby limiting the use of the EASA Part-145 MOE for approvals covered by the Basic Regulation, in consideration that the competent authority responsible for the Part-145 approval does not have any legal power to approve procedures, means and methods for aircraft outside the Basic Regulation.

As a consequence, the EASA MOE shall not refer to any national approval and must be exclusively dedicated to EASA Part-145

Concerning MOE Configuration

  • EASA acknowledges, however, the need for the industry to standardize as much as possible the organisation procedures in cases where multiple regulatory approvals have to be managed;
  • In this case, consideration may be given to accept “associated procedures” (see definition in par. 1.7 MOE Structure) serving more than one regulatory approval, provided that the following minimum requirements are met for each single “associated” procedure/list;
  • The structure of the document has to comply with the following criteria:
  • Associated procedures/lists shall meet the same rules in terms of document structure as described for the MOE;
  • When the organisation is developing an MOE supplemented by associated procedures/lists, then:

 – The MOE must contain at least the information required by 145.A.70(a)1 to 145.A.70(a)12 and 145.A.70(a)17 and a minimum regulatory compliance procedure in each chapter, and “associated” procedures/lists as defined below:

 – Associated Procedure: means a procedure providing additional and customised details on how the organisation intends to comply with applicable requirements;

 – Associated List: means any of the lists required by 145.A.70(a), when published separately from the MOE

Note – A clear indication is provided of which part of the text is applicable to EASA. In this way, when EASA is issuing approval for the related document, it is clearly identified that only the parts applicable to EASA are being approved.

  • EASA is not responsible for information in the document which is identified as applicable to other regulatory approvals.
  • When the organisation is not able to clearly indicate which part of the text is applicable to EASA, a stand-alone “associated procedure” shall be developed only for the EASA approval.

Work instructions

Work Instructions are intended to be those documents including detailed instructions for maintenance personnel on how to perform their duties on a daily basis.

They could also include lists/forms which are not required by 145.A.70 (a), such as for example the list of tools service providers, a list of internal auditors, a template to list units stored in a certain location, templates listing staff on duty, etc.

Work instructions do not require EASA approval and are to be fully controlled by the maintenance organisation.

Note – The Compliance Monitoring function remains responsible for ensuring any such document does not conflict with MOE or associated procedures/lists.

Next Steps

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EASA compliant, EASA Part 145 Maintenance Organization Exposition (MOE), EASA Part 145 MOE, EASA Third Country, EASA Third Country Part 145, MOE, Regulatory Approval, SAS blogs