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From a Part-145 Amendment to an MOE Review Matrix

· 5 min read

An amendment does not arrive as a tidy list of changes to your Maintenance Organisation Exposition (MOE). A compliance or quality owner must identify the source text, decide whether it applies to the organisation, find the affected procedure and evidence, and record the decision. Searching the rule and the MOE separately leaves the hardest part—the connection between them—to memory and spreadsheets.

This worked example shows the review method, using public EASA material and fictional company documents. It does not say that every organisation needs the same MOE amendment.

Start with a specific source change​

EASA's Part-145 AMC/GM Amendment 9 includes material associated with occurrence reporting under 145.A.60. A reviewer can use it as a prompt to inspect how their organisation handles relevant safety occurrence information and interfaces with the appropriate design approval holder or declarant. The correct action depends on the official text, the organisation's approval and procedures, and a qualified review. Check the currently applicable edition and any later amendments before using this example for real work.

The point is to avoid jumping straight from “the source changed” to “rewrite the MOE.” First establish what the amendment says, what your current controlled material says, and whether the two are actually connected.

What to bring into one review​

For a bounded occurrence-reporting review, the source set might include:

  • the official Part-145 rule, AMC/GM and amendment document, with edition and retrieval date;
  • the current approved MOE section and amendment history;
  • the occurrence-reporting procedure and any reporting/interface instructions;
  • related forms, training material, records and previous audit findings;
  • the organisation's scope, products and arrangements that determine applicability.

The EASA Easy Access Rules for Continuing Airworthiness are useful for navigation, but the reviewer still needs to check the legal instrument, decision and version behind a conclusion. Do not treat a search result or summary as the final authority.

A small review matrix​

The following rows are fictional examples of review questions, not findings of non-compliance or mandatory changes.

Source to inspectCompany document to inspectReviewer questionEvidence or next action
Part-145 occurrence-reporting text and related AMC/GMMOE occurrence-reporting sectionDoes the MOE describe the relevant reporting route and point to the current procedure?Record exact source and MOE references; ask the accountable owner to confirm applicability.
Same source, where the design-holder/declarant interface is relevantOccurrence-reporting procedure and contact listIs the recipient/interface defined for the organisation's actual work?Check the current interface agreement or contact record; note uncertainty rather than inventing a recipient.
Approved internal procedureReport form and example closed recordCan a reviewer trace a report from initial identification to the relevant decision and communication?Sample an authorised record and note any evidence gap.
Approved process, if it changedTraining and competence materialWould the accepted procedure change require briefing or training?Let the training owner decide; do not assume every amendment triggers retraining.

This structure separates a possible effect from an approved action. It also gives an auditor a clearer trail than a paragraph saying “reviewed, no impact.” If the source is irrelevant to a specific organisation, the matrix should explain why and cite the basis for that decision.

How the planned Aviation.Bot workflow would help​

The Aviation.Bot external regulatory library is under construction. The planned web and desktop experience would let a reviewer open the relevant official source in that library, then search it alongside their own controlled documents. A browser user would upload selected files to a workspace; a desktop user could work with a selected local folder. The external library itself is online, and the AI and indexing data path depends on the selected configuration.

A useful task would be:

Compare this identified Part-145 amendment with the selected MOE section and occurrence procedure. Return a table of source references, candidate affected documents, the reason for each match, missing evidence and questions for the human reviewer. Do not assert compliance or edit controlled documents.

The expected benefit is less time moving between official PDFs, MOE versions, forms and spreadsheets, with more of the source trail visible in one review. That is a workflow hypothesis, not a measured time-saving claim. The reviewer must open the cited original text, check applicability and approve any controlled change.

Make the output useful before using AI​

Even a manual version of this process is worth doing. Choose one amendment and one controlled procedure set. Record the edition of every source; use one row per candidate impact; assign an owner and status; and keep “no change needed” decisions with their reasons. This gives the team a concrete review artifact whether or not the planned library is available yet.

For the broader method, see EASA Part-145 MOE review and regulatory change impact review.

Library status: Aviation.Bot's new external-library workflow is being built. Join the Early Access list on Aviation.Bot to hear when the aviation library and the new web/desktop experience are available. The current beta has a different, narrower scope.