What your MOE training chapter must say for online training to be accepted

What must the Maintenance Organisation Exposition (MOE) say about training?

Name the training procedure, not the delivery method. Your MOE must say who is trained, against which syllabus, before when, on what interval, which providers you accept, how competency is assessed and where records live. Say that external and distance-learning providers are acceptable, and no course then needs a separate approval.

Our guide on whether online training is accepted answers that in principle: Part-145 prescribes no delivery method, so acceptance is decided by your own exposition. This is the practical half — where in the MOE the training procedure sits, what it must state, and a model paragraph to adapt.

Which MOE chapters carry training?

The exposition layout is guidance, not a form. AMC1 145.A.70(a) opens by saying so:

“This AMC provides an outline of the layout of an acceptable MOE. Where an organisation uses a different format […] the exposition should contain an index that shows where the subject matter can be found in the exposition.” — AMC1 145.A.70(a)

So the numbers below are the ones an auditor looks for first, not the only acceptable numbering; what is not optional is that the subject matter is findable. Within Part 3, the headings that carry training read:

3.6 Safety training (including human factors) and promotion

3.9 Certifying staff and support staff qualifications, authorisation and training procedures

3.10 Certifying staff and support staff records

3.14 Mechanics qualification and records

3.19 Competency assessment of personnel

3.22 Management system record-keeping

— AMC1 145.A.70(a), Part 3

One of those chapters gets named elsewhere in the rulebook, which is why it matters more than the rest. Appendix IV to AMC5 145.A.30(e) sends the fuel tank safety syllabus to it by number:

“Recurrent training: […] The syllabus of the training programme referred to in Chapter 3.9 of the maintenance organisation exposition (MOE) should include the additional syllabus for this recurrent training.” — Appendix IV to AMC5 145.A.30(e)

AMC 145.A.35(a), point 4, does the same for competency assessment, pointing at item 3.9 of the MOE as described in AMC1 145.A.70(a).

A map of what has to end up where:

Requirement	Where it comes from	MOE chapter it usually sits in
Safety training including human factors: who, syllabus, timing, 2-year cycle	AMC4 145.A.30(e), GM1 145.A.30(e)	3.6, with the procedure cross-referenced from 3.9
Certifying staff and support staff training programme and its elements	145.A.35(d), AMC1 145.A.35(d), 145.A.35(e)	3.9
Fuel tank safety and EWIS syllabuses, by phase and target group	Appendix IV to AMC5 145.A.30(e); AMC5 145.A.30(e)(b) and AMC 20-22	3.9, named in the appendix itself
Competency assessment procedure and its nine elements	AMC1 and AMC2 145.A.30(e)	3.19, cross-referenced from 3.9
Training and qualification records	145.A.55(d), AMC1 145.A.55(d)	3.10, 3.14 and 3.22

The unifying duty sits in the rule, not the AMC. The exposition must include:

“(12) the procedures specifying how the organisation ensures compliance with this Annex;” — 145.A.70(a)(12)

What must the training procedure state?

Six things, and a competent chapter covers all six in two pages.

Who is trained. AMC4 145.A.30(e)(a) requires every person to be assessed for the need for initial safety training, then names the groups who should receive it and the further training that follows — from nominated persons and supervisors down to stores staff and ground equipment operators. Map that list onto your own job titles.

Against which syllabus. Name the reference per subject: GM1 145.A.30(e) for safety training including human factors, Appendix A or B to AMC 20-22 for the relevant EWIS target group, and Appendix IV to AMC5 145.A.30(e) for fuel tank safety Phase 1 or Phase 2. GM1 145.A.30(e) lets you combine, divide or reorder its subjects, so a mapping table beats a copy.

Before when. The initial timing rule is stricter than most chapters admit:

“All personnel identified in accordance with point (a) of this AMC […] should receive initial safety training compliant with the organisation’s training standards prior to commencing the actual job function, unless their competency assessment justifies that there is no need for such training. New, directly employed personnel working under direct supervision may receive training within 6 months after joining the maintenance organisation.” — AMC4 145.A.30(e)(b)

Two conditions gate the six-month window: directly employed, and under direct supervision. Fuel tank safety Phase 1 carries its own version — before the person works without supervision, and not later than six months after joining.

On what interval. Up to four 2-year clocks can run at once, and the chapter should say which staff are on which. The safety training clock is scoped by your own findings:

“It should be of an appropriate duration in each 2-year period in relation to the relevant compliance monitoring audit findings and other internal/external sources of information available to the organisation on safety and human factors maintenance issues.” — AMC4 145.A.30(e)(c)

The certifying and support staff clock is in the rule itself:

“The organisation shall ensure that all certifying staff and support staff receive sufficient recurrent training in each 2-year period to ensure that they have up-to-date knowledge of relevant technologies, organisation procedures and safety management, including human factor issues.” — 145.A.35(d)

AMC1 145.A.35(d)(4) then ends with the sentence that makes this an exposition question rather than a purchasing one:

“The elements, general content and length of such training should be specified in the MOE.” — AMC1 145.A.35(d)(4)

EWIS runs on its own interval under AMC 20-22 section 8(b), fuel tank safety on the Appendix IV cycle quoted above. Our guide on how often human factors training is required unpicks the first clock; the due-date tool works out the dates.

Which providers you accept. This is the sentence that decides whether an online course is accepted:

“Safety training may be conducted by the maintenance organisation itself, independent trainers, or any training organisations acceptable to the competent authority.” — AMC4 145.A.30(e)(d)

“The safety training procedures should be specified in the MOE.” — AMC4 145.A.30(e)(e)

AMC1 145.A.35(d)(4) gives certifying staff the same latitude, offering a Part-147 organisation, an aeronautical college, the Part-145 organisation itself or another training organisation as examples. Nothing prefers a classroom. Where the guidance addresses delivery it permits distance learning: Appendix IV allows fuel tank safety Phase 2 by e-learning or computer-based training on four conditions, and AMC 20-22 section 8(a) lists computer-based training alongside classroom discussion and hands-on practical training.

How competency is assessed, and where records go. AMC2 145.A.30(e) asks the competency assessment procedure to specify nine things, from who is responsible to how results are recorded; the 145.A.30(e) clause page sets them out. Point 145.A.55(d) fixes retention: as long as the person works for the organisation, and at least three years after they leave.

A worked clause: acceptance of external and distance-learning providers

The italic paragraphs below are a drafting template written by MOST.AERO. They are not regulatory text, not an approved wording, and no authority has reviewed them. Adapt the chapter numbers, criteria and job titles, then agree the result with your competent authority through your normal amendment route.

3.9.x Acceptance of external and distance-learning training providers

Training required by this chapter may be delivered by the organisation itself, by an independent trainer, or by any external training organisation accepted under this procedure. Part-147 approval is not a condition of acceptance for safety training including human factors, fuel tank safety or EWIS training.

Delivery may be in a classroom, in a live online session, or by self-paced distance learning. The delivery method is not itself a criterion of acceptance. Before a course is first used, the Compliance Monitoring Manager records: (a) a mapping of its syllabus onto GM1 145.A.30(e), Appendix A or B to AMC 20-22, or Appendix IV to AMC5 145.A.30(e), as applicable, with any gap covered by internal training; (b) confirmation that any examination required by that reference is present at the required pass mark; and (c) the certificate specimen and the issuer’s legal identity. Accepted courses are listed in the controlled register named in this chapter, which is amended without amending this exposition.

A distance-learning course used for fuel tank safety Phase 2 is accepted only where it provides continuous evaluation, intermediate questions before the trainee proceeds, recording of examination content and results, and access to an instructor, and concludes with a multiple-choice examination at the pass mark stated in Appendix IV to AMC5 145.A.30(e). A certificate is accepted only where it states the course name, the reference it serves, whether the training is initial or continuation, the learner’s name, the completion date, the issuer’s legal identity, and the examination result where one is required; certificates are filed under Chapter 3.10 or 3.14 and retained in accordance with 145.A.55(d).

Content specific to this organisation — audit findings, hazards, internal occurrences and changes to this exposition — is delivered by the organisation and recorded separately. An external course does not discharge this element.

What do surveyors check?

That the chapter exists, and that it is the approved version. Amendments are not optional housekeeping:

“The initial issue of the MOE shall be approved by the competent authority. It shall be amended as necessary so that it remains an up-to-date description of the organisation.” — 145.A.70(b)

Point 145.A.70(c) routes amendments through the procedures at 145.A.70(a)(10) and (a)(11), with anything outside the agreed scope going to the competent authority.

That the text matches practice. The gap here is rarely an unacceptable course; it is a chapter describing classroom delivery by a named provider while the records show self-paced online courses from three suppliers.

That the six-month allowance was applied to the right people. Expect the surveyor to pick a recent joiner, check whether they were directly employed and under direct supervision, and compare the start of the job function with the training date. Contracted staff sit outside the allowance.

That records carry the fields the AMC lists. AMC1 145.A.55(d) sets the minimum information for certifying staff and support staff: basic training, task or type training, continuation training, experience, qualifications, scope of the authorisation and its dates. AMC1 145.A.30(e) adds a record of each individual’s qualifications and competency assessment.

That the competency assessment is a decision, not a filing step. AMC1 145.A.30(e) requires staff to be assessed before unsupervised work commences and competency to be controlled continuously, and says the assessment determines the scope of tasks the individual may perform, supervise or sign off, and whether further training is needed. A certificate is an input to that decision; your chapter should say who makes it and how it is recorded.

Related courses. EASA Part-145 Regulatory Training – Initial covers the exposition mechanism this guide relies on, including where training procedures sit in the MOE. EASA Part-145 Safety Training including Human Factors – Initial follows the GM1 145.A.30(e) syllabus that your Chapter 3.6 has to reference.