Comparison
EASA MOE and CAME: The Organization Manuals
The Short Answer
One Exposition per Approval
The maintenance organization exposition (MOE) is the manual a Part-145 maintenance organization keeps under 145.A.70. The continuing airworthiness management exposition (CAME) is the manual a Part-CAMO organization keeps under CAMO.A.300. Both sit in Regulation (EU) No 1321/2014: Part-145 is Annex II and Part-CAMO is Annex Vc.
EASA's guidance material gives the same purpose for each: specify the scope of work and show how the organization intends to comply, and give its staff the information and procedures they need to do their jobs. Complying with the contents is meant to keep the organization in compliance with the Annex. The MOE covers doing maintenance. The CAME covers managing the continuing airworthiness of aircraft: the maintenance program, airworthiness directives, records, contracted maintenance, and the airworthiness review.
The MOE
What 145.A.70 Requires
Point 145.A.70(a) lists seventeen items the MOE must include, directly or by reference. Grouped:
- Accountable manager statement
- A signed statement that the organization will at all times work to Part-145, Part-M and Part-ML as applicable and to the approved MOE, countersigned by the chief executive officer if that is a different person.
- People and structure
- The safety policy and objectives, the named post-holders and their duties, an organization chart showing lines of accountability, and the list of certifying staff, support staff and airworthiness review staff with their scope of authorization.
- Scope and facilities
- A general description of manpower resources and staff planning, the facilities at each approved location, the scope of work that matches the terms of approval, and a list of approved locations.
- Procedures
- The procedure for amending the MOE, the procedure that sets the scope of changes not requiring prior approval, and the procedures that show how the organization complies with the Annex.
- Lists
- Commercial operators served regularly, subcontracted organizations, contracted organizations, and the alternative means of compliance currently approved for the organization.
The CAME
What CAMO.A.300 Requires
Point CAMO.A.300(a) requires the organization to give the competent authority a CAME and any referenced manuals and procedures, with fourteen items of information. Grouped:
- Accountable manager statement and safety policy
- The same signed commitment as in the MOE, covering Part-CAMO, Part-M and Part-ML as applicable and the approved CAME, plus the organization's safety policy.
- Scope, people and structure
- The scope of work against the terms of approval, manpower and staff planning, the named post-holders with their duties and authorities, an organization chart, the list of staff who may issue airworthiness review certificates or recommendations, and a description of the facilities.
- Safety reporting and compliance procedures
- The internal safety reporting scheme and the procedures that show compliance, including management system processes, control of contracted and subcontracted activity, continuing airworthiness management, airworthiness review and permit to fly procedures, the scope of changes not requiring prior approval, and CAME amendment.
- Lists
- The approved aircraft maintenance programs for the aircraft under a continuing airworthiness management contract, the maintenance contracts, and the currently approved alternative means of compliance.
Approval
Who Approves It, and How Changes Are Handled
For both manuals, the competent authority approves the initial issue (145.A.70(b) and CAMO.A.300(b)), and the organization must amend it as necessary to remain an up-to-date description of the organization. After that the two rules work the same way. Amendments are managed under the organization's own procedures: for the MOE, the procedure that sets the scope of changes not requiring prior approval and the procedure for amending the MOE; for the CAME, the equivalent two procedures. Any amendment outside the scope of the first procedure, and any amendment linked to the changes the Annex lists as needing prior approval, must be approved by the competent authority (145.A.70(c) and CAMO.A.300(c)).
The list that needs prior approval is short. In Part-145 (145.A.85(a)) it covers changes to the certificate and terms of approval, changes of the accountable manager, nominated persons and quality manager, changes to their reporting lines, the procedure for changes not requiring prior approval, and additional locations. Part-CAMO (CAMO.A.130(a)) has a parallel list. The organization must apply before the change and may implement it only on receipt of formal approval. The acceptable means of compliance says the application should go in at least 30 working days before the intended change, and 20 working days where a nominated person is changing.
That second procedure is itself something the authority approves. A procedure for changes not requiring prior approval is how an organization revises ordinary procedures without sending every edit to the authority, and it is where the practical weight of an MOE or CAME sits. Write it carefully, because the line it draws decides which edits are the organization's to make.
Indirect approval is a different mechanism with a similar flavor. It is the route M.A.302(c) gives for approving the aircraft maintenance program, described below. The rules do not use that term for amending the MOE or the CAME.
Layout
The Parts of an MOE
AMC1 145.A.70(a) “provides an outline of the layout of an acceptable MOE.” An organization may use a different format, for example so the exposition serves more than one approval, but then it should carry an index that shows where each subject is found.
- Part 1, General
- Accountable manager statement, safety policy, management personnel and chart, certifying staff list, manpower, facilities, scope of work, and the change procedures with and without prior approval.
- Part 2, Maintenance procedures
- Supplier and subcontractor control, acceptance and storage of components and material, tools and calibration, maintenance data, repair, scheduled maintenance, AD and modification work, documentation and release to service, occurrence reporting, and line maintenance. A separate Part L2 adds line maintenance procedures.
- Part 3, Management system procedures
- Hazard identification and safety risk management, internal safety reporting, change management, safety training, compliance monitoring and audits, and certifying staff qualification, authorization and records.
- Part 4, Relationship with customers and operators
- The list of operators served regularly, and the customer interface procedures and paperwork.
- Part 5, Supporting documents
- Sample documents and the lists of subcontractors, line maintenance locations, contracted organizations and alternative means of compliance.
- Parts 7 to 9, Other authorities
- Reserved for supplementary procedures where the organization also holds an FAA Part 145, Transport Canada CAR 573 or Brazilian RBAC 145 approval, to be based on the Maintenance Annex Guidance. Part 6 is reserved.
Layout
The Parts of a CAME
AMC1 CAMO.A.300 gives the equivalent outline and the same allowance for a different format with a cross-reference.
- Part 0, General organization, safety policy and objectives
- Safety policy and accountable manager statement, scope, management personnel and chart, and the procedures for changes with and without prior approval.
- Part 1, Continuing airworthiness management procedures
- The aircraft technical log and records system, MEL application, AMP development, amendment and approval, records, airworthiness directives, AMP effectiveness analysis, non-mandatory modifications, repairs and modifications, defect reports, engineering activity, reliability programs, and pre-flight inspections.
- Part 2, Management system procedures
- Hazard identification and risk management, safety reporting, change management, compliance monitoring (including monitoring of contracted maintenance), competency, record-keeping and occurrence reporting.
- Part 3, Contracted maintenance
- How maintenance contractors are selected and how a product audit of the aircraft is done.
- Part 4 and Part 4B, Airworthiness review and permit to fly
- Review staff, the documented records review, the physical survey, and issue or extension of the airworthiness review certificate; and, where the organization has the privilege, permit to fly procedures.
- Part 5, Supporting documents
- Sample documents, lists of review staff, subcontractors, contracted maintenance organizations and contracts, approved maintenance programs, and alternative means of compliance.
Comparisons
Against the FAA Manuals and the Maintenance Program
FAA repair station manual and quality control manual. A Part 145 repair station owes the FAA a repair station manual (14 CFR 145.207) and a quality control manual (145.211(c)), which may be combined into one manual system. EASA asks for one exposition per approval, and the MOE carries the maintenance procedures, management system procedures and compliance procedures in it. The approval language also differs: Part-145 has the authority approve the initial MOE, where the FAA rule asks for a manual acceptable to the FAA. For an organization with both approvals, Part 7 of the MOE layout is reserved for the FAA supplementary procedures, to be based on the Maintenance Annex Guidance. The FAA side is in repair station manual vs quality control manual.
The aircraft maintenance program (AMP). The AMP is a document for the aircraft, not for the organization. M.A.302 requires each aircraft to be maintained to an AMP, and the AMP and its amendments to be approved by the competent authority. Where a CAMO or CAO manages the aircraft, M.A.302(c) allows approval through an indirect approval procedure, which the CAMO or CAO establishes as part of its CAME (or CAE) and the competent authority approves. It may be used only when the CAMO or CAO is under oversight of the Member State of registry, unless a written contract transfers responsibility for approving the AMP to the competent authority responsible for the CAMO or CAO. Indirect approval is not permitted for escalating safety-related tasks (M.A.302(e)).
The CAME is where the two meet. Its layout has a section on AMP development, amendment and approval, one on analyzing the effectiveness of the program, and a list of the approved programs for aircraft under contract. CAMO.A.315(b)(1) requires the CAMO to ensure the AMP, with any reliability program, is developed and controlled, and the guidance says “control” includes presenting the AMP and its amendments to the authority unless an indirect approval procedure covers it. What an AMP is and how it is built is covered in the aircraft maintenance program guide, and the manufacturer data it starts from in the maintenance planning document guide.
Writing Them
Who Writes and Revises These Manuals
An MOE or CAME is a controlled document with a named owner, an amendment procedure, and a regulator who reads it against the Annex. Shakewell writes and revises EASA organization manuals, including the MOE and CAME. Read the rule text, the acceptable means of compliance and your authority's expectations before you rely on this page for a specific manual; it is not legal advice.
FAQ
Questions We Hear
Are the MOE and the CAME the same document?
No. The MOE is required by 145.A.70 in Part-145 (Annex II) for maintenance organizations. The CAME is required by CAMO.A.300 in Part-CAMO (Annex Vc) for continuing airworthiness management organizations. They are separate approvals. The acceptable means of compliance for each says an organization may use a different format, for example to serve more than one approval, as long as the exposition carries an index that shows where each subject is found.
Who approves the MOE?
The competent authority approves the initial issue (145.A.70(b)). The organization must then keep it up to date. Amendments inside the scope of the organization's own procedure for changes not requiring prior approval are managed and notified under that procedure; every other amendment, and any amendment tied to the prior-approval changes listed in 145.A.85(a), goes to the competent authority for approval (145.A.70(c)).
Does the CAME work the same way?
Yes, in the same pattern. CAMO.A.300(b) has the competent authority approve the initial issue, and CAMO.A.300(c) has amendments managed under the organization's own procedures for changes not requiring prior approval and for CAME amendment, with everything outside that scope, and anything tied to the changes listed in CAMO.A.130(a), approved by the competent authority.
What is indirect approval?
It is the term M.A.302(c) uses for the maintenance program, not for the exposition. When a CAMO or CAO manages an aircraft, the AMP and its amendments may be approved through an indirect approval procedure that the CAMO or CAO sets out in its CAME (or in the combined airworthiness exposition for a CAO) and that the competent authority approves. Escalation of safety-related tasks cannot go through indirect approval (M.A.302(e)). Read the full conditions in the text before relying on it.
Is the maintenance program part of the CAME?
No. The AMP is its own approved document for the aircraft. The CAME holds the procedure for developing, amending and getting the AMP approved, and a list of the approved maintenance programs for the aircraft under contract (CAMO.A.300(a)(12)). Under CAMO.A.315(b)(1) the CAMO must ensure the AMP is developed and controlled.
Is there an EASA template for the MOE or CAME?
There is an outline, not a filled-in manual. AMC1 145.A.70(a) and AMC1 CAMO.A.300 each give the layout of an acceptable exposition, part by part. The content of each section is the organization's own procedures, written for its approvals, locations and aircraft.
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Organization Manuals That Match the Rule
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