Managing your MOE

The aviation industry thrives on safety, compliance, and efficiency. However, recent regulatory changes have raised concerns about the increasing complexity of the EASA Part-145 Maintenance Organisation Exposition (MOE). With the latest update to Part-145 regulations now requiring full compliance with the Acceptable Means of Compliance (AMC), many industry professionals are questioning whether the MOE has become overly burdensome to manage.

The Challenge of Full AMC Compliance

The EASA’s decision to require organizations to fully integrate AMCs into their MOE brings both benefits and challenges. On one hand, it ensures a standardized and harmonized approach to regulatory compliance, leaving less room for interpretation and potential safety risks. On the other hand, it significantly increases the volume and complexity of documentation that maintenance organizations must maintain.

Previously, organizations had some flexibility in how they structured their MOEs, provided they met the essential requirements of Part-145. Now, with full AMC compliance mandated, organizations must adapt to a more rigid framework that may not necessarily align with their existing procedures and operational realities. This raises key concerns:

1. Administrative Overload – The MOE, already a substantial document, is now growing even larger, requiring more resources to maintain and update.
2. Reduced Flexibility – Organizations may find it challenging to tailor procedures to their specific operational needs while maintaining strict adherence to AMCs.
3. Increased Approval Timelines – Competent authorities may need more time to review and approve MOEs, potentially delaying implementation of necessary changes.
4. Potential for Compliance Gaps – With a more complex document, ensuring ongoing compliance across all sections becomes a greater challenge, especially for smaller organizations with limited compliance resources.
5. Implementation of SMS in Chapter 3 – The requirement to incorporate a Safety Management System (SMS) into Chapter 3 of the MOE adds another layer of complexity. If an organization chooses to reference an external SMS Manual instead, the MOE transitions into an interconnected document system, making compliance management even more challenging.

Finding a Balanced Approach

The intent behind the regulatory change is clear—greater safety and consistency across the industry. However, should EASA consider a more pragmatic approach to MOE management? A potential solution could be allowing organizations to demonstrate alternative means of compliance more easily, rather than enforcing a one-size-fits-all model.

Additionally, digitalization could play a crucial role in making the MOE more manageable. The adoption of structured digital compliance management systems, automated tracking, and real-time regulatory updates could ease the burden on maintenance organizations.

Industry Voices Matter

As the aviation maintenance sector adapts to these changes, it is crucial for industry professionals to engage in discussions with regulators to ensure that safety objectives are met without unnecessarily increasing administrative complexity.

What are your thoughts? Has your organization faced challenges with the new Part-145 MOE requirements?