What is MAOS?
MAOS stands for Maintenance Approved Organisation Scheme. It is the means by which the MOD will assess the competence of civilian organisations providing airworthiness support to military registered aircraft.
The requirement for the scheme, which has been modeled on EC Regulation 2042/2003, is published in Defence Standard 05-130.
What Approvals are possible under MAOS?
Defence Standard 05-130 will contain 4 main parts:
Part 1 - Mil Part 145 - Maintenance Organisations.
Part 2 – Mil Part M - Continuing Airworthiness Management.
Part 3 – Mil Part 147 - Aircraft Maintenance Training Organisations.
Part 4 – Mil Part 66 - Aircraft Maintenance Personnel.
Approvals will be possible under Mil Part 145 (maintenance organisations), Mil Part M (continuing airworthiness management organisations), and Mil Part 147 (training organisations).
Currently only Part 1 of Def Stan 05-130 has been published (Mil Part 145), hence only maintenance organisations may seek approval under MAOS.
How do I propose a change to the regulation?
Any comments or proposed amendments to the regulation should be submitted using a MAFTR Form 24 and is available via the forms link. These forms will be reviewed as part of the Def Stan review process.
Is MAOS mandated?
MAOS Mil Part 145 has been mandated since Mar 08 for all new and future contracts/projects. By Mar 2010 all existing contracts/projects are to comply with the requirements of Def Stan 05-130 Part 1 (Mil Part 145).
Pending further study, the scope of this mandate is restricted to all on-aircraft contractor depth maintenance and that off-aircraft maintenance carried out on government establishments.
Can an organization bid for a contract before gaining MAOS approval, if so, how long after the contract award would the organization have to gain approval?
Organisations not MAOS approved may bid for contracts. There would need to be an action plan included as part of the contract submission detailing how the organization proposes to meet the requirements of Def Stan 05-130.
The organization must gain approval within 6 months once the contract has been awarded. This would mean a MAFTR audit within 3 months to meet this time scale. The provision of approved data, special to type tools and GSE should be part of the contract and should be available on commencement of work.
What will a MAOS approval cost and who will be responsible for payment?
MAFTR (unlike the CAA) do not directly charge organisations seeking an approval; however where external contractors are contracted to support the MOD in the approval process, the contractor’s costs will be will be levied directly to the organization seeking the MAOS approval.
Whilst it is recognized that any costs levied on an external contractor will ultimately be passed back to the MOD in the form of increased charges, this is consistent with DE&S policy, that project costs should be borne by the project gaining the ‘benefit’ from the activity that generated them.
In response to feedback from organisations that have gained MAOS approval, the charging mechanism will be changed. The current mechanism, utilising daily rates & expenses, is to be replaced with a predominantly fixed price scheme from the 1st April 2010. This new scheme of charges framework is consistent with that used within the Civil Aviation environment and the MoD Design Organisation Approval Scheme (DAOS). It will enable organisations to more accurately budget for initial approval costs and the annual continuation fees.
The total cost will be dependent upon the scale and complexity of the approval being sought. And can be calculated using the information contained within the MAOS Scheme of Charges page.
The applicability of the changes in the charging policy for the transition period are summarised below:
- Organisations seeking a MAOS initial approval from 1st April 2010 will be charged in accordance with the new scheme of charges.
- Organisations that currently have a MAOS approval will be charged under the new scheme for annual continuation surveillance activity being conducted after 1st April 2010.
- Organisations that have been accepted as candidates for MAOS approval and are currently undergoing assessment will be charged under the old scheme of charges (daily rate plus expenses etc) until the initial approval is granted. Please contact the MoD Airworthiness Regulator (MAOS Approvals) for details.
How long does it take to gain a maintenance organization approval?
It depends on the size, location and complexity of the organization. It is anticipated that for the majority of organisations seeking Mil Part 145 approval, the process will take approximately 3-6 months from the receipt of the MAFTR Form 2.
Who can apply?
Any organization involved with military aircraft maintenance in direct support of MoD contracts. However, at this time MAFTR are not in a position to consider applications from any organization that could potentially become involved with military aircraft maintenance.
What if an organization has a complaint or appeal?
Complaints or appeals against decisions made during the approval process should be passed to the lead auditor in the first instance. Any unresolved complaints or appeals should be directed to the MAOS team via email using the link on the MAOS home page.
What if an organization already has an EASA approval?
The organization will still be required to submit an exposition, however, MAFTR will focus on those elements of the organization relating to military registered aircraft. Consideration will be given to organisations wishing to include the military aspects of their maintenance organization as an Annex to their existing EASA Maintenance Organisation Exposition (MOE).
What are the benefits of MAOS?
To Industry: MAOS sets out a number of requirements that an organization must meet in order that an approval can be given. Unlike existing MoD regulations which are often perceived as prescriptive, MAOS allows an organization to choose how they meet these requirements. It follows the basic principles of the civil system and should enable the adoption of best practice from both systems.
To MoD: MAOS should not impose any significant additional requirements on an organization that is providing services to the MoD. However, what is does do is to apply a standard to which an organization must attain prior to accreditation. It will assure that an organization is capable of carrying out the tasks it proposes in its exposition and has underpinning processes and procedures in place. It should also assist the relevant IPT in their airworthiness assurance activities.
Why can’t we use existing procedures?
The current MoD framework does not cater for new and future arrangements with industry. However, in line with the civil model, it is possible to comply with a MAOS requirement by using current regulations as an acceptable means of compliance. An example of this is the use of JAP100A-01 Chapter 6.1.1 as a means of complying with the MAOS requirement for tool control.
Is MAOS recognized by the CAA/EASA?
EASA and the CAA do not formally recognize MAOS, however there has been extensive dialogue between the MAFTR and the CAA, and the CAA are aware of the MOD’s intentions.
Is it the same as ISO certification?
No, in order to gain MAOS accreditation an organization will not only have to demonstrate that it has procedures in place but they are effective.
If we have an ISO certification, do we need MAOS?
Yes, however, many of standards used by ISO should complement MAOS and reduce the effort required for MAOS accreditation.
Will it impose additional audits?
Not necessarily, one of the aims of MAOS is to rationalize the amount of audits the MoD impose on organisations. Wherever possible, audits will be combined so that one audit may satisfy a number of requirements.