Lamentably, the full purpose of maintenance organisation expositions (MOEs) is often overlooked. The MOE is far more than a simple exercise in compliance; it should also be a guide to ‘getting the job done’. The procedures set out in the MOE must be followed. Over the course of numerous post-holder approvals, in nine countries and on three continents, I have written numerous MOEs. As a former maintenance manager, I believe passionately in the MOE serving also as a practical guide.
It is NEVER enough to state only that a MOE has been accepted or approved by the respective national authority (N.B: these terms have vastly different meanings between the various jurisdictions so, check which term your own authority uses and ensure that you understand its significance). At the most fundamental level, authority acceptance is often viewed as confirmation that the MOE is fit for purpose; acceptance means no such thing. The national authority may assign to you only two audits per year and have precious little time to assign to you in the intervening period. Each inspector will have many organisations for which he / she must provide oversight and will have no slack in their timetable. The MOE could be regarded as compliant with the applicable regulations but, the maintenance organisation is compliant only if it follows the MOE.
The national authority IS NOT responsible for compliance within an approved maintenance organisation; the organisation – alone – is. Compliance is the responsibility of every single person in an approved maintenance organisation, be they post-holders or otherwise. Each person, therefore, should be trained on the applicable parts of the MOE and exercise self-discipline in following the procedures set out.
This is where we get back to the heart of the matter: a MOE should be a clear, simple and brief statement of the procedures by means of which the organisation works. A MOE requires diligent crafting and should make full use of the flexibility afforded by the regulations. Take, for example, the use of Cat-A certifying staff. Whilst Cat A personnel may neither defer defects nor undertake fault diagnosis, there is a great deal they can do and the following is an example (the precise set depends upon the national authority in question, plus the aircraft make / model):
- Pre-Flight / Transit Check;
- Replacement of wheel assemblies;
- Replacement of wheel brake units;
- Replacement of emergency equipment;
- Replacement of ovens, boilers and beverage makers;
- Replacement of internal and external lights, filaments and flash tubes;
- Replacement of windscreen wiper blades;
- Replacement of passenger and cabin crew seats, seat belts and harnesses;
- Closing of cowlings and refitment of quick access inspection panels;
- Replacement of galley and toilet system components but excluding gate valves;
- Simple repairs and replacement of internal compartment doors and placards but excluding doors forming part of a pressure structure;
- Simple repairs and replacement of overhead storage compartment doors and cabin furnishing items;
- Replacement of static wicks;
- Replacement of aircraft main and APU aircraft batteries;
- Replacement of in-flight entertainment system simple components such as screens and Passenger Control Units, but excluding public address;
- Inspection for and removal of de-icing/anti-icing fluid residues, including removal/closure of panels, cowls or covers or the use of special tools;
- Routine lubrication and replenishment of all system fluids and gases;
- FDR downloading;
- Simple repairs and replacement sidewalls and ceiling panels;
- Simple repairs and replacement of passenger cabin windows, excluding parts forming part of a pressure structure.
The above represent the majority of routine tasks on a flight line. Using Cat A certifiers, therefore, not only reduces reliance upon Cat B1 / 2 certifiers but, also, enable your less-experienced personnel to certify at least some maintenance at a much earlier stage in their careers. It gives the maintenance organisation flexibility and reduces costs.
Refer to: EASA Part-145.A.30(e)(g) and 35(a)-(i)/(m).
Please contact me to discuss further.
