EASA Part 147 Maintenance Training Organisation Exposition (MTOE)

1.     Scope

The purpose of the Maintenance Training Organisation Exposition (MTOE) compliance checklist and user guide is to assist organisation wishing to obtain EASA Part-147 approval (MTO).  This document is complementary to the requirements of Implementing Rule (IR) - Regulation EU 2042/2003 Annex IV, Part-147 “as amended” and does not supersede or replace the information defined within the IR.

The checklist includes suggested subject headings and all the relevant information as detailed in 147.A.140 and its AMC, the format of which may be modified to suit the organisation preferred method. The checklist should show compliance by referring in the “MTOE reference / comment” where the information in the MTOE is located and explanation if not applicable.

This checklist, when completed, should be submitted with the initial draft MTOE.

2.     Important warning

This user guide is designed to be used by: 

Ø  Part-147 MTO - To assist them in the production and/or maintaining of their own MTOE

Ø  - As a comparison document for MTOEs submitted to them for approval; and

The user guide is provided for guidance only and should be customised by each organisation to demonstrate how they comply with Part-147.  It is the responsibility of the organisation to ensure compliance with the IR. The organisation may choose to use another format as long as all the applicable sections of the regulation are addressed and cross-referenced. 

For each detailed procedure described within the MTOE, the MTO should address the following questions:

What must be done?  Who should do it?  When must it be done?  Where must it be done? How must it be done? Which procedure(s)/form(s) should be used?

The MTOE should be written in the English language.

3.     Exposition format

The MTOE may be produced in hardcopy or electronic format;  

Ø  Hardcopy:  Company does recommend using white paper (format A4); The MTOE shall be provided in a binder with section dividers. (recto/verso can be used)

Ø  Electronic Format:  The Exposition should be in Portable Document Format (PDF) but a printed copy shall be delivered to the Company to facilitate the document study.

4.     Structure of the Maintenance Training Organisation Exposition

The MTOE may be produced in the form of a single document or may consist of several separate documents.

Ø  Single document:  The standard MTOE produced i.a.w. Appendix I to AMC 147.A.140 is a unique and complete document. It must contain all the information required to show compliance with the regulation including detailed training and examination procedures and detailed training system quality procedures (see 147.A.140, AMC 147.A.140 and Appendix I to AMC 147.A.140).

Ø  Several documents: The MTOE must contain at least the information as detailed in Appendix I to AMC 147.A.140 Part 1.1 to 1.11 (Management).  The additional material may be published in separate documents which must be referenced from the MTOE. In this case:

 The MTOE should cross refer to the associated procedures, documents, appendices and forms which are managed separately.

These associated documents must meet the same rules as described for the MTOE.

This/these associated document(s), procedure(s) and form(s) etc. must be provided to the for approval, as Part of the MTOE.

For some organisations certain sections of the headings defined within Appendix I to AMC 147.A.140 may be ‘not applicable’.  In this case they should be annotated as such within the MTOE.

5.     Exposition pages presentation

Each page of the MTOE should be identified as follows (this information may be added in the header or footer; 

Ø  the name of the organisation (official name as defined  on the EASA Form 11 approval certificate) 

Ø  the issue number of the MTOE

Ø  the amendment/revision number of the MTOE

Ø  the date of the revision (amendment or issue depending on the way the organisation has chosen to revise the MTOE)

Ø  the chapter of the MTOE

Ø  the page number

Ø  the name of the document " Maintenance Training Organisation Exposition” 

At the beginning of the volume, the Cover page should specify: 

Ø  Maintenance Training Organisation Exposition;

Ø  The name of the organisation  (the official one defined  on the EASA Form 11 approval certificate)

Ø  The approval reference  of the MTO 

Ø  The copy number from  the distribution list

6.     Corporate commitment by Accountable Manger

Prior to submission of the ‘draft’ MTOE to the for approval, the Accountable Manager must sign and date the Corporate Commitment statement (Management 1.1).  This confirms that they have read the document and understand their responsibilities under the approval.  In the case of change of Accountable Manager the new incumbent should sign the document and submit a suitable amendment the for approval.

Content	IR reference
Cover page
Maintenance Training Organisation Exposition
The official name of the organisation as defined on EASA Form 11
The approval reference of the MTO
The copy number from  the distribution list
Introduction
Foreword
Table of content
List of effective pages
List of issues / amendments or record of revision
ICAA Letter of Approval (LOA)
Internal organisation approval  page signed by QM and TM
        Internal approval statement
        Title, name, date and signature (QM and TM)
Revision highlights / Summary of changes
Effective date of the current revision
        The effective date is the date that the amendment introduced in this amendment takes effect
        The effective date can be established just prior to the final approval of the MTOE by ICAA or just after. This is in order to obtain the necessary time to incorporate the amendment e.g. to train personnel, print forms etc.
Distribution list
        MTOE copy number
        Location of copies
        Holders of the copies
        Format of copies (CD-ROM, Paper etc.)
Abbreviation, terminology and definitions
Cross reference list from the MTOE to Appendix I to AMC 147.A.140, if applicable
Organisation information i.e.:
·         Address of approved locations (Head Office)
·         Mailing Address(es)
·         Telephone number(s)
·         Fax number(s)
·         E-mail address of the Head Office
Part 1 Management
1.1          Corporate commitment by the accountable manger	147.A.140(a) 1.
When the AM is not the CEO of the organisation then such CEO shall countersign the statement
1.2          Management personnel	147.A.105(a)(b)(c)(g)
        Accountable Manager (AM) – insert name
        Training Manager (TM) – insert name
        Quality Manger (QM) – insert name
        Knowledge Examiner(s) – insert name(s)
        Practical Assessor(s) – insert name(s)
        Other (as required) – insert name(s)
1.3          Duties and Responsibilities of management personnel, including matters on which they may deal directly with the competent authority on behalf of the maintenance training organisation	147.A.105(a)(b)(c)
        Duties and Responsibilities (job functions)
o    Accountable Manager (AM)
o    Continuing Airworthiness Manager (TM)
o    Quality Manager (QM)
o    Instructors
o    Knowledge Examiners
o    Practical Assessor
1.4          Management personnel Organisation Chart	147.A.140(a) 4.
        Management personnel organisation chart showing associated chains of responsibility of management personnel
A flow chart should provide a comprehensive understanding of the whole training organisation. It should give further details on the management system, and should clearly show the independence of the quality monitoring system, including the links between the Quality assurance dePartment and the other dePartments.
This flow chart may be combined or subdivided as necessary, depending on the size and the complexity of the organisation.
1.5          List of instructional and examination staff	147.A.140(a) 5.
        List of the training instructors - insert name(s)
        List of the knowledge examiners - insert name(s)
        List of the practical assessors insert name(s)
1.6          List of approved addresses	147.A.100 / 147.A.140(a) 11. / 147.A.145(b)
This paragraph should list those address(s) at which instruction and/or practical training are to be carried out for the duration of the Part-147 course.
The names, address(s) and approval numbers of any proposed Aircraft Maintenance Part-145 Organisation at which it is proposed to carry out student practical training in order to fulfil the requirements of PART-147 may be kept in another document or procedure and cross referenced here.  This arrangement should include writted agreements with relevant Part 145 MO.
1.7          List of sub-contractors as per 147.A.145(d)	147.A.100 / 147.A.140(a) 12. / 147.A.145(b)
        List name of subcontractor(s)
        List address of subcontractor(s)
This paragraph should list name of organisation and those address(s) at which training beyond the capacity of the Part-147 Organisation may be carried out.
Part-66 Modules 1 to 6 inclusive and 8 to 10 inclusive may be sub-contracted to organisations not specialising in aircraft maintenance and where the Part-147.A.200 practical training element does not apply.
1.8          General description of facilities of paragraph 1.6 addresses	147.A.100 / 147.A.140(a) 6. / 147.A.145(b)
        General description of facilities of paragraph 1.6 addresses
        General description of facilities of paragraph 1.7 addresses
        Location of facilities
        General description
o    Layout of premises and size
o    Office accommodations
o    Classrooms for the instruction of theory
o    Library
o    Practical training workshop
o    Knowledge Examinations rooms
o    Type/task training facility
o    Secure storage facilities
Include here the facilities such as desks, chairs, lockers, overhead projectors, other teaching aids etc. for each of the offices, classrooms, practical training workshops and examination rooms provided.
1.9          Specific list of courses and type examinations approved by the competent authority	147.A.140(a) 7.
This paragraph must contain a list of the Part-147 course(s) and type examination for which approval is held.
This should also include “Differences” courses.
E.g. Airbus A319/320/321 (CFM 56) B1 - differences to A319/320/321 (V2500) B1.
1.10        Notification procedure regarding changes to the organisation	147.A.150 / 147.A.130(a)
        Changes
o    Organisation name and location
o    Organisation additional location
o    The group of person as specified in 1.2
o    Operation, facilities, procedures, work scope, staff and arrangements, as far as they may affect the approval
        Notification before such changes take place
1.11        Exposition amendment procedure	147.A.140 / Appendix I to AMC
Exposition Amendment Procedures (including, delegated procedures)
        Person responsible for amending the Exposition.
o    Normally the Quality Manager is responsible for the monitoring and amendment of the Exposition, including associated procedures manuals, and the submission of proposed amendments to the ICAA
        Sources of proposed amendments within the organisation
        Internal approval process
o    Verifying and validation of amended procedures before use
o    Training Manager and Quality Manager sign the internal approval page, see introduction
        Approval process with ICAA
        Revision acknowledge receipt process
        Definition of minor amendments to the Exposition that can be amended without the prior approval of the ICAA, if applicable and agreed
o    In case of minor amendment the Quality Manager may be delegated for indirect approval provided the appropriate procedure within this paragraph of the MTOE is approved by ICAA. Such a delegation is to be based upon the ability of the Quality System to deal adequately with the Part-147 requirements. This ability cannot be therefore demonstrated at the time of the initial approval. Therefore an indirect approval procedure cannot be detailed in the MTOE before the first 2 year period has been completed. In any case the ICAA must continue to receive a copy and acknowledge receipt of all such minor changes when “indirectly” approved.
        Summary of documents, including "lower order" documents, constituting the total Exposition, if applicable
        Effective date of the amendment
        MTOE Review
After ICAA has approved the amendment the date when the amendment will take effect need to be determine, sometime to allow time to train personnel, print forms and/or distribute the revision so all personnel needed at different locations have received the revision at the date it is effective
PART 2  TRAINING AND EXAMINATION PROCEDURES
2.1          Organisation of courses	147.A.200
In this paragraph the organisation should detail the procedures in place in order to organise the courses and to ensure that all necessary means are available to deliver in good conditions and by appropriately qualified staff all the course elements as required by the Part-66 syllabus.
Such procedures may include a formalised review of the availability of required appropriate training rooms, materials, STDs, specialists... and resulting in tuition programme.
2.2          Preparation of course material	147.A.120
Training material should meet the requirements of Part-66. It should also state how the approved company produces a course for a new aircraft type. This would typically include the production of the Training Needs Analysis i.a.w. Part 66 appendix III
For Basic training ICAA Form LHD 430 needs to be completed and submitted with training material for each module in order to demonstrate compliance with Part 66 Appendix I.
In order to get the course approved a set of multi-choice questions/and or essay questions must be submitted.
This procedure should also be utilised to list the responsibilities by Part-66 module for the production, review & amendment of lecture notes.
2.3          Preparation of classrooms and equipment	147.A.115
Cross reference to any procedures for the preparation of classrooms and reporting of faults to any classroom equipment, general maintenance procedures and the control of the teaching environment.
2.4          Preparation of workshop/maintenance facilities and equipment	147.A.100
Cross reference to any procedures for the reporting of faults to any workshop equipment, general maintenance procedures and the control of the teaching environment.
Cross reference to procedures for the ordering and storage of aircraft release standard consumable materials used in the production of practical tasks, and for the ordering and acquisition of any new equipment required to complete the tasks.
Cross reference to the procedures for ensuring that all test equipment and/or tooling requiring calibration are correctly forecast and expedited. Also cross reference to the procedure for ensuring that all electrical equipment power supply feeder cables (from wall socket to equipment) throughout the organisation are tested as required.
2.5          Conduct of Basic/Type knowledge and practical training	147.A.200
Describe the method utilised in teaching the Basic/Type knowledge and practical training courses for which the organisation is approved.
Cross refer to the low level document referred to in 2.1 above.
2.6          Records of training carried out	147.A.125
Cross refer to procedures for the production, maintenance and security of student files.
These should include details of all student attendance´s, final knowledge examinations, practical assessments and any re-examination carried out and their results by Part-66 complete module for Basic Licence courses and for Type Training, information of those courses completed, their content and at which levels at which they were instructed and examined.
There should be reference to the Basic work experience records required to be kept by the student whilst he is undergoing his live operating aircraft experience.
The use of an “Aircraft Maintenance Engineers Log Book” is a good example.
2.7          Storage of Records	147.A.100
Cross refer to procedures for the storage of staff and students records.
These may be electronically based provided that adequate safeguards are in place to prevent unauthorised access and alteration.
2.8          Training at locations not listed in paragraph 1.6	147.A.145
Should the Management wish to contract out Part of the practical training (not including live operating aircraft experience), control procedures must be in place. These procedures should effectively reflect those of the Part-147 Organisation.
Any training carried out at address not listed at 1.6 above must be approved by the ICAA and control procedures must be in place to ensure that the proposed contract organisation is in compliance with the requirements of Part-66 & Part-147.
A contract must be in place with the proposed organisation in which it is agreed that access is granted to the ICAA for the purpose of auditing.
Note: the “APPLICATION TO CONDUCT TRAINING/EXAMINATIONS* AT A LOCATION REMOTE FROM THE Part-147 APPROVED SITE” Form should be annexed to the MTOE.
2.9          Organisation of examinations:	147.A.135/147.A.205
For Aircraft Maintenance Licence (AML) course a High level document detailing the course examinations, when each Part-66 module is to be examined and to what Part-66 level. This should include the knowledge, practical and ´on job ‘training elements and how the number of hours of each comply with the percentage requirements of AMC 147.A.200.
For aircraft type training, the course syllabus should be used to prepare an examination schedule. The examination schedule should detail the examinations to be set at the end of each major phase within the syllabus. A final examination should be conducted at the end of the type training course. The final examination should be recorded. Refer to applicable part to Part 66 Appendix III.
2.10        Security and preparation of examination material	147.A.100/135
For AML courses detail the preparation and security of Examination papers. Number of Questions and Timing must be in accordance with Part-66 Appendix II.
Cross reference to procedures for the production of examination questions, their validation and security of the data bank.
For Type training it is sufficient to detail the preparation and security procedures in place for the production and storage of examination papers
2.11        Preparation of examination rooms	147.A.100b
Cross refer to procedure to be followed by the Examiner and Invigilator in preparing the examination room for examinations.
An invigilator´s ready reference sheet for briefing the candidates prior to the examination should be available in procedures and cross referenced here.
2.12         Conduct of examinations	147.A.135/205
Any student found during a knowledge examination to be cheating or in possession of material pertaining to the subject of the examination, other than that supplied for the examination, will be disqualified from passing the examination and may not then retake the examination for at least 12 months.
Any examiner/invigilator found to be providing answers to examination questions to any student will be immediately disqualified from acting as an examiner/invigilator, and the ICAA will be informed within 1 calendar month.
Candidates should only be identified by a numbering system, the only identifying document being held by the nominated Examiner.
Examination paper security should be assured by a numbering system, e.g. “1 of 15”etc.
A procedure should be in place for checking that all the pages of each examination paper are complete at examination completion and that all examination papers are accounted for. Both the written element and the multi-choice question elements should be marked to 75% with no penalty marking. Ref Annex III (Part-66) Appendix II.
Nothing other than the actual examination/answer paper is permitted to be on the candidate´s desk.
All wall charts and/or other visual teaching aids should be removed from the examination room.
2.13Conduct of Basic/Type practical assessments	147.A.210/305
Cross refer to procedures used for assessment of student hand skills, and the standard tasks set throughout the course. A set number of mandatory tasks should be assessed to have been completed to a satisfactory standard.
2.14Marking and records of examinations	147.A.100/125
Cross refer to procedures for the marking of completed examination papers and the recording of results.
Cross refer to a procedure for practical assessments and recording of results.
2.15Storage of examination results	147.A.100/125
A copy of each examination paper, the student number/identification list, a practical task results list, an examination results list and all examination papers for each complete module must be stored for a period of five years.
Electronic means of storage may be utilised as required, provided the usual computer security systems are in place.
2.16Examinations at locations not listed in paragraph 1.6	147.A.100/140/145)
Cross refer to the control procedure in common with Part 2.8 above. This location must comply with the requirements of 2.10, 2.11, 2.12, 2.13, 2.14 and 2.15 above.
Consideration is needed for the security/control of examinations and their completed examination papers and/or practical assessment results.
2.17         Preparation, control and issue of Basic/Type training course certificates	147.A.145
The certificates should be prepared to reflect that illustrated in Annex IV (Part-147) appendix III and tightly controlled prior to issue, with a system in place to ensure that each copy is numbered as Part of a sequence and recorded as issued to a candidate by name.
2.18Control of sub-contractors	147.A.100 and 147.A.145)
Cross refer to procedures for the control of sub-contractors as appropriate.
PART 3 TRAINING SYSTEM QUALITY PROCEDURES
3.1          Audit of training	147.A.130
As per the AMC Part 147.A.130 (2), an external auditor may be contracted by the smaller organisation for the purposes of the quality audit.
The purpose of the audit plan is to meet Part of the needs of the Part-147 approval.
The approved organisation should develop a form/audit checklist to be used by the auditor that would demonstrate that all the requirements of Part-147 have been reviewed during the audit process. The audit plan should indicate applicability of the various activities to be monitored and more than one list may be necessary (rolling audit). Each list should be shown against a timetable to indicate when the particular item is scheduled for audit and when the audit was completed. A complete audit of the Part-147 organisation must be completed every 12 months.
Cross refer to the various procedures required for quality auditing, reporting findings and levels with any corrective actions required. A management control and follow up system must also be in place and may not be contracted out.
Cross reference to any quality procedures manual if available is permitted, but this system must relate to and make reference to the relevant Part-147 paragraphs.
3.2          Audit of examinations	147.A.130
Must be audited annually, but may be Part of the rolling audit procedure.
3.3          Analysis of examination results	147.A.130
Examination results should be analysed on completion of each examination and any questions amended as necessary. Cross refer to procedures detailing responsibilities.
3.4          Audit and analysis remedial action	147.A.130
Cross refer to procedures for the reporting of findings and for corrective actions.
3.5          Accountable Manager annual review	147.A.130
Points discussed on a set date should include:
·         Projects requiring financial support
·         Sufficient staff employed to meet foreseen training program.
·         Part-147 organisation review.
·         Examinations and assessments.
·         Student achievements.
·         Student support.
·         Quality Assurance review.
3.6          Qualifying the Instructors	147.A.105)
List acceptable staff qualifications*:
Include procedures for the induction of inexperienced instructors as required.
Where relevant include procedures for the employment of part time or contract instructors.
All staff should have an appreciation of the contents of Part-66 and Part-147.
Cross refer to the list of present staff/qualification. Note: Staffs employed prior to Part-147 application who´s qualifications were previously acceptable, will continue to be accepted.
Cross refer to procedures for staff development.
*Note: Guidance for acceptable qualifications is proposed in the Annex I to the present MTOE guidance.
3.7          Qualifying the Examiners/Assessors	147.A.105
Examiners should have a full understanding of all the requirements of Part-66 and Part-147.
Cross refer to procedures for staff development.
Cross refer to the list of staff/qualifications.
Practical work assessors should be assessed as being competent in accordance with an approved process.
3.8          Records of qualified Instructors, Examiners and Assessors	147.A.110
The company must maintain a record of all training staff which must include details of the scope of their authorisation.
Training staff must be provided with evidence of the scope of their authorisation.
The following minimum information should be kept on record in respect of each instructor:
·         Name
·         Date of Birth
·         Personnel Number
·         Experience
·         Qualifications relevant to the approval
·         Training History (before entry)
·         Training (Basic Training, Type Training, Continuation Training)
·         Scope of activity
·         Date of first issue of the authorisation
·         If appropriate - expiry date of the authorisation
·         Starting date of employment
The records may be kept in any format (hard copy or computer based) subject to the usual security requirements.
Persons authorised to access the system should be maintained at a minimum to ensure that records cannot be altered in an unauthorised manner or that such confidential records become accessible to unauthorised persons.
The instructor should be given reasonable access on request to his/her own records.
The authorisation document should be in a style that makes its scope clear to instructors and any authorised person that may be required to examine the document. Where codes are used to define scope, an interpretation document should be readily available.
Instructional staffs are not required to carry the authorisation document at all times but should produce it within a reasonable time of a request from an authorised person. Authorised persons, a part from the organisation´s department must include EASA and the ICAA.
Any member of the ICAA is classed as an authorised person when investigating the records system for initial and continued approval or when the ICAA has cause to doubt the competence of a Particular instructor.
PART 4 APPENDICES
4.1          Examples of documents and forms used	Appendix I to AMC 147.A.140
This section should include examples of all documents and forms used by the organisation in the conduct of its Part-147 function.
Some examples are listed below:
·         Student attendance record
·         Course certificate(s)
·         Certificate(s) of training
·         Classroom plan (exam purposes)
·         Course critique
·         Course results
·         Course design/change plan
·         Exam answer sheet
·         Exam results
·         Internal audit procedure
·         Internal audit schedule
·         Internal audit report
·         Application to conduct courses/examinations at a remote location
·         Interview report form
·         MTOE amendment request
·         MTOE amendment request log
·         Staff training record.(to include qualifications, history and subjects taught).
·         Staff terms of reference
·         Student training/examination and assessment form
·         Training course review
·         Quality system
·         Aircraft visit form
4.2          Syllabus/Training Needs Analysis (TNA) of each training course	Appendix I to AMC 147.A.140
This section should contain the signed approval document issued by the Agency for each approved course.
4.3          Cross reference Index - if applicable	Appendix I to AMC 147.A.140
Self explanatory.