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Management of Change (MOC) is a structured process for identifying, assessing, and controlling risks introduced by changes to operations, organization, equipment, or procedures. MOC is required by 14 CFR 5.51, which mandates that Safety Risk Management be applied whenever changes are made to existing systems. PlaneConnection’s MOC workflow ensures that no change is implemented without an appropriate level of safety review.

MOC Statuses

StatusAPI ValueDescription
DraftdraftChange request submitted. Basic details captured.
ScreeningscreeningChange is being evaluated against the 8-question screening checklist.
Risk Assessmentrisk_assessmentChange has been screened and requires a formal risk assessment.
ApprovalapprovalRisk assessment complete. Change awaiting management approval.
ImplementationimplementationChange approved and being implemented.
Post-Reviewpost_reviewChange has been implemented. Effectiveness and safety impact under review.
ClosedclosedMOC process complete. Record is immutable.

Status Lifecycle

Status Transition Rules

FromToPermitted RolesConditions
DraftScreeningSafety manager, adminAll required fields populated
ScreeningRisk AssessmentSafety manager, adminAt least one screening question answered “Yes”
ScreeningClosedSafety manager, adminAll screening questions answered “No”; rationale documented
Risk AssessmentApprovalSafety manager, adminRisk assessment completed with residual risk documented
ApprovalImplementationAccountable executive, safety manager, adminApproval signature recorded
ApprovalRisk AssessmentSafety manager, adminAdditional analysis reason documented
ImplementationPost-ReviewSafety manager, adminImplementation date recorded
Post-ReviewClosedSafety manager, adminReview findings documented
Post-ReviewRisk AssessmentSafety manager, adminNew hazards identified

Change Categories

CategoryAPI ValueDescriptionExamples
OperationaloperationalChanges to how operations are conducted.New routes, revised flight procedures, changes to dispatch practices, weather minima adjustments.
OrganizationalorganizationalChanges to structure, personnel, or responsibilities.Key personnel changes, department restructuring, outsourcing maintenance, new vendor relationships.
TechnicaltechnicalChanges to aircraft, equipment, or systems.Avionics upgrades, new aircraft type, software updates, ground support equipment changes.
RegulatoryregulatoryChanges driven by new or amended regulations.New airworthiness directives, revised OpSpecs, regulatory amendments, TSA security requirements.
ProcessprocessChanges to documented procedures or workflows.SOP revisions, checklist modifications, training curriculum updates, quality assurance process changes.

8-Question Screening Checklist

The screening checklist determines whether a proposed change requires a formal risk assessment. If any question is answered “Yes,” the MOC advances to Risk Assessment. If all are answered “No,” the MOC may be closed with documented rationale.
Covers direct and indirect effects on flight operations, airspace, or aircraft performance.
Covers conditions that could foreseeably cause or contribute to an aircraft accident.
Covers weakening, removal, or bypassing of current safety defenses.
Covers new skills, certifications, or training required to operate safely under the change.
Covers aircraft systems, maintenance tooling, dispatch systems, or safety-critical software.
Covers operating procedures that must be revised to reflect the change.
Covers ATC coordination, vendor relationships, interline agreements, or data system integrations.
Covers second-order effects — a change in one area may create risks elsewhere.

Emergency vs. Standard Timelines

Some changes cannot wait for the full MOC process. PlaneConnection supports two timeline modes.
AttributeStandard MOCEmergency MOC
TriggerPlanned change with lead time.Urgent change required by immediate safety concern, regulatory directive, or operational necessity.
ScreeningFull 8-question checklist.Abbreviated screening — minimum of questions 1, 2, and 3.
Risk AssessmentFull assessment with initial and residual risk.Expedited assessment focused on immediate hazards and interim controls.
ApprovalAccountable executive or designee.Safety manager can approve with post-facto executive review within 72 hours.
ImplementationAfter full approval.Immediate implementation with interim controls.
Post-ReviewWithin 30 days of implementation.Full retrospective review within 14 days. Includes completing any deferred screening questions and risk assessment steps.
Target Completion30 — 90 days depending on complexity.Implementation within 24 — 72 hours; full MOC closure within 30 days.
Emergency MOC safeguards: An emergency MOC that is not completed (full review and closure) within 30 days is automatically escalated to the accountable executive.

MOC Fields

FieldTypeRequiredDescription
codeStringAutoAuto-generated tracking code (e.g., MOC-2026-0008).
titleStringYesBrief description of the proposed change.
descriptionTextYesDetailed description of the change, its purpose, and expected impact.
categoryEnumYesoperational, organizational, technical, regulatory, or process.
timelineEnumYesstandard or emergency.
statusEnumAutoCurrent workflow status.
initiatorUser referenceAutoThe person who submitted the change request.
screening_responsesArrayAt ScreeningAnswers to the 8 screening questions with rationale.
risk_assessmentReferenceAt Risk AssessmentLink to the associated risk assessment record.
approval_dateDateAt ApprovalDate of management approval.
approved_byUser referenceAt ApprovalThe person who approved the change.
implementation_dateDateAt ImplementationDate the change was deployed.
review_findingsTextAt PIRPost-review findings and effectiveness evaluation.
review_dateDateAt PIRDate of post-review.
linked_reportsArrayNoSafety reports related to the change.
linked_cpasArrayNoCPAs generated from the MOC risk assessment.
created_atTimestampAutoRecord creation timestamp (UTC).
updated_atTimestampAutoLast modification timestamp (UTC).

Post-Review

The post-review (PIR) evaluates whether the change was implemented as planned and whether any unanticipated safety effects have emerged. The review covers:
Review AreaDescription
Implementation fidelityWas the change implemented as described in the MOC? Were there deviations?
Hazard validationDid the identified hazards materialize? Were there unanticipated hazards?
Control effectivenessAre the risk controls functioning as intended? Is the residual risk at or below the accepted level?
Operational impactHow has the change affected day-to-day operations? Any unexpected consequences?
Stakeholder feedbackInput from affected personnel on the change’s practical effects.
If the PIR identifies new hazards or ineffective controls, the MOC is returned to Risk Assessment for additional analysis.

Regulatory Alignment

Part 5 SectionRequirementMOC Component
5.51SRM applicability — changes to existing systemsMOC process triggers SRM for all qualifying changes
5.53System analysis and hazard identificationScreening checklist and risk assessment
5.55Safety risk assessment and controlIntegrated risk assessment with initial and residual risk
5.71Safety performance monitoringPost-review
5.97SMS recordsMOC records retained per policy

Manage Change

Initiate and manage an MOC.

Risk Assessment Matrix

Risk matrix used during MOC risk assessment.

CPA Lifecycle

Lifecycle for actions generated from MOC risk assessments.

FAA Part 5 Overview

Regulatory context for Management of Change requirements.
Last modified on April 11, 2026