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To be considered a safety pilot, must the aviator in question be able to manipulate the flight controls, or is see-and-avoid responsibility sufficient?

Asked another way, if the PIC wants to fly under simulated instrument conditions to maintain currency in a Cessna 172, is the lone pilot seated in the rear a safety pilot or a passenger? Did the PIC bring along one safety pilot or two?

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    $\begingroup$ I think the term "safety pilot" means you need to have access to the controls, not to mention you should have an unrestricted view of the sky to observe and perform the safety duties, which would be difficult from a rear seat. I think the only time this would be acceptable is in a two seat aircraft where you sit in line. $\endgroup$
    – Ron Beyer
    Apr 6, 2016 at 1:16
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    $\begingroup$ Also, if you are a rated pilot in a passenger seat you should not be logging any time as "pilot" since you don't have access to, or manipulate the controls. I'd hazard to say that even if the rear seat is occupied by a pilot rated passenger, that person is in fact, a passenger, and not performing any duties as a pilot. $\endgroup$
    – Ron Beyer
    Apr 6, 2016 at 1:18
  • $\begingroup$ @RonBeyer I would be careful trying to make the jump from needing to be a pilot to needing to have access to the controls. (Note that I agree with your answer below, but your comment above could be taken out of context and give the wrong impression.) $\endgroup$
    – Lnafziger
    Apr 6, 2016 at 22:56

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After looking through the FAR's, the answer is no, the rear passenger seat cannot be occupied by somebody claiming to be a "safety pilot".

FAR 91.109(c):

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

  (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

  (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(Emphasis Mine)

So the safety pilot basically has to be able to access the controls and have vision that supplements the pilot, meaning must be able to see as well as the pilot position would.

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    $\begingroup$ I find it interesting that while the safety pilot needs to be able to operate the controls, he doesn't actually need to be able to see anything, provided another person does the seeing for him. $\endgroup$
    – Jörg W Mittag
    Apr 6, 2016 at 11:51
  • $\begingroup$ @JörgWMittag The language seems to make the competent observer a required crewmember. $\endgroup$
    – Greg Bacon
    Apr 6, 2016 at 11:57
  • $\begingroup$ Does the competent observer need a medical? $\endgroup$
    – Someone
    Jun 17 at 17:21

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