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145.A.70 requires the organisation to produce and maintain a Maintenance Organisation Exposition (MOE) that documents the organisation's structure, procedures, scope of work, and the means by which it complies with Part 145, and to submit it to the competent authority for approval.
What it means in practice
The MOE is the organisation's primary compliance document. It describes how the organisation is structured, who is responsible for what, what procedures are used, and how the organisation meets each requirement of Part 145. The competent authority reviews and approves the MOE as part of the initial approval process and must approve any subsequent amendments that affect the basis of approval.
In day-to-day operations, the MOE serves as the reference document for all personnel. It defines the organisation's policies and procedures for maintenance, quality, safety, training, and administration. Procedures referenced in the MOE but contained in separate manuals or documents must be controlled as part of the overall MOE system.
Key requirements
The MOE must contain specific content, including: a statement signed by the accountable manager confirming compliance with Part 145; the organisation's safety policy; the scope of work; details of management personnel and their responsibilities; descriptions of human resources, facilities, tools, and equipment; procedures for maintenance, certification, record-keeping, occurrence reporting, and quality monitoring; the list of certifying staff; the list of subcontracted organisations; and any applicable line stations.
The MOE must be amended to remain current, and amendments must be submitted to the competent authority. Certain amendments, particularly those that affect the terms of approval or the management system, require prior approval from the competent authority before implementation. The accountable manager must approve all MOE amendments.
Common compliance gaps
A widespread issue is the MOE not reflecting actual practices. Procedures described in the MOE evolve over time, but the document is not updated to match. This creates a gap between what is written and what is done, which is itself a non-compliance. Organisations also sometimes fail to submit amendments to the competent authority for approval when required, particularly for indirect approval amendments which can be implemented before formal acceptance.
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