The Scenario:

An instrument-rated private pilot files and flies IFR while accompanied by a non-instrument-rated private pilot who is otherwise fully certified and endorsed to act as PIC in that aircraft under VFR flight rules. While in VMC, the instrument rated pilot uses a view limiting device in order to practice IFR scan and procedures towards maintaining currency, while the other pilot acts as safety pilot. Both pilots meet all medical and currency requirements for the flight.

The Question:

Can the safety pilot in the previous scenario log as PIC that time during which he/she acted as safety pilot?

Note: This question differs from the question, How should time as safety pilot be logged?. This question is not answered there; this question concerns whether or not a non-instrument-rated pilot is qualified as required crew during simulated instrument flight in VMC while operating on an IFR flight plan, and whether that pilot is qualified to act as PIC in the given scenario.

  • 3
    $\begingroup$ "A safety pilot does not have to have an instrument rating if the flight is being conducted under the visual flight rules. However, if the aircraft is operated under instrument flight rules, even in VFR conditions, whoever is acting as pilot in command of the flight must hold an instrument rating appropriate to the aircraft being operated" Source $\endgroup$ – Ron Beyer Dec 19 '15 at 20:27
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    $\begingroup$ So I believe that if you are on an IFR flight plan, a VFR pilot cannot act as a safety pilot since you would be operating under IFR in VFR. $\endgroup$ – Ron Beyer Dec 19 '15 at 20:31
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    $\begingroup$ @RonBeyer, the AOPA article you quote goes on to say, "If the pilot under the hood is instrument rated and acting as pilot in command, even though the flight is IFR, the safety pilot is not required to have an instrument rating or be instrument current." I think the answer is that the non-instrument rated pilot can act as safety pilot, but not as pilot in command, and therefore cannot log pilot in command time. $\endgroup$ – J Walters Dec 19 '15 at 21:50
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    $\begingroup$ I don't see how this can be a duplicate; the other question is specifically about VFR and this one is about IFR. $\endgroup$ – Pondlife Jan 19 '16 at 14:47
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    $\begingroup$ @rbp Actually, a safety pilot is required if operating under VMC and the PIC is using a view limiting device (at any time). It doesn't matter if it is operated under IFR or VFR rules. $\endgroup$ – Lnafziger Apr 5 '16 at 20:03


The way that both pilots can log PIC is that the pilot using a view limiting device is logging PIC as sole manipulator and the safety pilot is logging PIC because he is acting PIC and a required crew member.

If the flight is operating under an instrument clearance then the acting PIC must be instrument rated. If only the pilot with the view limiting device is rated then he is acting PIC and is the only one eligible to log PIC. The safety pilot is also not allowed to log SIC as a required crewmember without an instrument rating while operating under IFR.

If you are in actual IMC then you shouldn't be logging anything and they other guy shouldn't be wearing a view limiting device.

If you want the PIC time ask your friend to fly VFR or get yourself an instrument rating.

  • 1
    $\begingroup$ @JonathanWalters 91.109 requires the safety pilot needs to have category and class ratings appropriate for the airplane. Id consider this a bit vague in arguing no instrument rating is required for safety pilots under IFR but id hope to find a legal interpretation out there before making such an argument. $\endgroup$ – casey Dec 19 '15 at 21:51
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    $\begingroup$ This answer is correct in that the safety pilot can't log acting PIC time (which was the specific question), but he can log PIC as the sole manipulator if he takes the controls. And interestingly, in actual IMC if the safety pilot takes the controls then he can log PIC but the rated pilot can't. Legal interpretation here. $\endgroup$ – Pondlife Jan 20 '16 at 15:39
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    $\begingroup$ @Lnafziger if the flight is operated under IFR (as the question assumes), 61.51(f)(2) requires an instrument rating to log SIC if the flight requires an instrument rating, which it does if the PIC accepted an IFR clearance.. $\endgroup$ – casey Apr 5 '16 at 21:46
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    $\begingroup$ What happens if both Pilot A and Pilot B are instrument rated? Pilot A wants to be under the hood to practice in an IFR flight and Pilot B is the safety pilot. Does the rule of safety pilot also logging PIC time still apply? $\endgroup$ – Francesco C Aug 12 '16 at 4:30
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    $\begingroup$ @RyanMortensen - Although you and AOPA are correct in saying that the safety pilot in this situation isn't required to have an instrument rating, that has nothing to do with whether or not the safety pilot is eligible to log PIC. $\endgroup$ – Steve V. Aug 14 '16 at 9:25

The safety pilot can't log any acting PIC time but he could still log PIC time as sole manipulator of the controls (if he ever takes the controls, that is).

That's from an FAA legal interpretation (based on this previous one) that clarifies logging PIC time under IFR without an instrument rating. The interpretation discusses an instrument-rated pilot ("Pilot A") flying with a non-instrument-rated pilot ("Pilot B").

First, acting as PIC and logging PIC are different things, and only Pilot A can act as PIC under IFR:

The FAA has previously stated that there is a distinction between logging PIC time and acting as a PIC. See Herman Interpretation. To act as a PIC (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a pilot must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. In your example of an IFR flight, being properly rated and authorized would include having an instrument rating. Accordingly, only Pilot A may act as the PIC, and Pilot A has final authority and responsibility for the safety of the flight regardless of who is manipulating the controls.

But you don't need an instrument rating to log PIC time, as long as you're rated for the aircraft. That means that in simulated instrument conditions the safety pilot ("Pilot B") can't log any time as acting PIC under 61.51(e)(iii) but he can still log PIC time if he's the sole manipulator of the controls, under 61.51(e)(i):

for the purpose of logging PIC time under §61.51(e), a pilot must hold ratings for the aircraft rather than for the conditions of flight. Accordingly, Pilot B may log PIC time for the portion of the flight during which Pilot B was the sole manipulator of the controls.

In other words, Pilot A can log PIC time for the entire flight but Pilot B can log it only for the time spent as sole manipulator. If Pilot B never touches the controls then he can't log any PIC time at all.

In actual IMC, 61.51(e)(iii) doesn't apply because a safety pilot is only required in simulated IMC. The FAA's conclusion is that if Pilot B takes the controls in actual IMC then he can log both PIC and instrument time, but Pilot A can't log anything:

Pilots A and B are flying in actual IMC conditions, not simulated instrument flight conditions, and the aircraft operation is not one for which "more than one pilot is required under ... the regulations under which the flight is conducted." Speranza Interpretation (Dec. 4, 2009). Therefore, Pilot A is not acting as a safety pilot and, as was the case in the Speranza Interpretation, being the PIC in this context is not a basis for Pilot A to log flight time under § 61.51 for the portion of the flight being logged by Pilot B as PIC flight time while the sole manipulator of the controls.

Pilot A is still acting as PIC in that case, he just can't log the time.

Finally, remember that the FAA interpretation is only about the legality of logging PIC time under IFR. Unless you're a CFII, letting someone without an instrument rating fly under IFR would be very risky, even in VMC. There's a good chance that if something went wrong then the FAA would go after both pilots on the basis of 91.13 (careless and reckless operation).

  • $\begingroup$ no pilot logs "acting PIC" time. "acting PIC" is a role. "logging PIC" is an administrative function. $\endgroup$ – rbp Jan 26 '16 at 17:26
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    $\begingroup$ @rbp 61.51(e)(1)(iii) says that you can log PIC "When the pilot [...] acts as pilot in command..." if more than one pilot is required for the flight. Acting PIC is indeed a role, and being in that role on a flight requiring more than one pilot is one possible reason for logging PIC time. $\endgroup$ – Pondlife Jan 26 '16 at 18:53
  • $\begingroup$ glad you agree! $\endgroup$ – rbp Jan 26 '16 at 18:54
  • $\begingroup$ @RBP Lots of pilots, and more importantly, hiring companies differentiate between Flight Time spent as the acting PIC vs Flight Time that was loggable as PIC time. The former is more restrictive and valuable; the latter is often discounted, especially—as I understand—by the airline industry. For example, I flew BE-20 as a required crewmember and was able to log SMoTC time as PIC time. This time is not recognized by lots of hiring companies as true PIC time. My logbook has columns for Acting PIC time and for PIC time loggable under §61. The difference can be useful. $\endgroup$ – J Walters Jun 9 '20 at 18:12

The issue for me is 91.109(c)

No person may operate a civil aircraft in simulated instrument flight unless—

The word simulated seems to me that while on an IFR flight plan the flight isn't simulated hence there is no need for a safety pilot. As a result, the other pilot irregardless of whether or not they are capable of acting as the legal pilot in command cannot log PIC time.

They are not a required crew member so they cannot log SIC time either.

While in VMC conditions on an IFR flight plan it is prudent for all pilots to see and avoid other aircraft. If one is wearing a view limiting device, the other pilot is still not required due to being on an IFR flight plan.

  • 4
    $\begingroup$ IFR refers to flight rules not meteorological conditions. IFR flight can be conducted in VMC or IMC and that may be further separated into simulated IMC and actual IMC. So yes, you can fly under instrument flight rules in simulated instrument meteorological conditions if you have a safety pilot. You always need a safety pilot if you have a view limiting device (even under IFR) as you are still responsible to see and avoid while visibility allows (e.g. VMC or simulated IMC) $\endgroup$ – casey Dec 20 '15 at 2:58
  • $\begingroup$ Also if you are wearing a view limiting device a safety pilot is a required crew member and if properly rated may log SIC or even PIC if both pilots agree the safety pilot is the acting PIC. $\endgroup$ – casey Dec 20 '15 at 3:00

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