I have dealt with many surveyors down the years and my experience is that they are all different, each with his own take on the EASA 145 regulation. A few years ago I was assisting a very small component repair facility prepare for an audit by the authorities for which I felt they were well prepared. The auditors went through the regulation line by line and insisted that it be applied as it would be to a large aircraft maintenance facility. Needless to say, the manpower plan was one area that fell in for a non conformance.
To see exactly what the regulation says, see the 145 consolidated rulebook on the EASA website. The relevant sections are:
145.A.30(d)
AMC 145.A.30(d) items 1 to 8
The moral of this tale is that you cannot presume an auditor will choose not to apply the full regulation