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Let's take a classic example. An instrument rated pilot is flying a C-172 and wants to maintain instrument currency. The pilot goes flying and performs some approaches, holding and intercept/tracking to maintain that currency, all while under the hood. In order to maintain a safe condition, a safety pilot is brought along to maintain VFR conditions.

The question is, how should the safety pilot log this time? In this condition the safety pilot is a required crew member, but is this time technically SIC or is it PIC?

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The rules for safety pilots are spelled out in 91.109c but don't specifically state how the safety pilot should log the hours.

However, the common consensus I've heard from friends is that you can indeed log safety pilot time as PIC time. The August 2015 Flight Training magazine had an article about this actually. Here is what they said:

What is implied but not specifically stated in the regulation is important. Because safety pilots are responsible for determining the safety of the flight, they can log their right-seat time when the left seat pilot is wearing a view-limiting device as PIC time. This transforms time spent serving as a safety pilot into a truly valuable educational experience that will also expand the flight time totals in your logbook

Edit: I did some more research into this.

PIC time is defined in Part 61.51(e). Safety pilots can qualify as PIC under bullet iii:

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted

There are some other things to be aware of when logging PIC time as a safety pilot (in addition to the requirements of 91.109c):

  1. The two pilots must agree that the safety pilot is the acting PIC.
  2. PIC time may be logged only while the other pilot is "under-the-hood."
  3. If something goes wrong you are the one that will be held responsible. I wouldnt take the responsibility lightly.
  4. The pilot logging instrument time must record the safety pilots name in their logbook under 61.51(g)(3)
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    $\begingroup$ Point 3 is by far the most important. Imagine logging PIC time for many flights as the safety pilot. When an accident or incident (airspace infraction) occurs the FAA will ask who the legal PIC was. No doubt fingers may be pointing to the other pilot. The FAA would review the logbooks to see if the safety pilot logged PIC time on previous flights to determine who was probably the legal PIC on the flight in question. $\endgroup$ – wbeard52 Jul 23 '15 at 4:15
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In a single-pilot aircraft like the C172 there are basically two scenarios. The key difference between the two is: who is acting as PIC? As background, keep in mind the following:

  1. Acting as PIC and logging PIC are two different things
  2. Per 91.109(c), a safety pilot is required for simulated instrument flight
  3. 14 CFR 61.51 has the complete rules on logging PIC and SIC time

Scenario 1: the safety pilot acts as PIC

In this scenario, the safety pilot (SP) acts as PIC while the pilot flying (PF) actually controls the aircraft. That means the SP can log PIC time per 61.51(e)(iii) because they are acting as (emphasis mine):

[...] pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted

Meanwhile, the PF can also log PIC time per 61.51(e)(i) as long as they are the "sole manipulator of the controls", i.e. they are actually flying the aircraft.

Scenario 2: the pilot flying acts as PIC

Here, the SP cannot log PIC time. They are not acting as PIC, nor are they the sole manipulator of the controls. However, they are still a required crewmember per 91.109, so they can log SIC time per 61.51(f)(2). The PF can log PIC time as the sole manipulator of the controls.

In practice1, what usually happens is that the pilots agree that the SP will act as PIC. The reason is that it allows both pilots to log PIC time, which is usually desirable for both of them. But that means the SP must be authorized to act as PIC, i.e. valid medical, qualified to act as PIC for the aircraft type, current etc. If the SP is qualified to be a safety pilot but not PIC, then only scenario 2 above is possible.

We have a lot of questions on this site about logging PIC time in various scenarios, so please search and review them carefully before asking a new question that may already have been answered.


1 What really happens most of the time in practice is that the pilots don't discuss any of this and they just both log PIC time for the flight. That's not ideal, but if something goes wrong the FAA will ask "so, who was acting as PIC?". If the pilots can't answer that clearly, things probably won't go so well for either of them. And if the SP logged PIC time without being qualified to do so, it's likely to go even worse.

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