I act as safety pilot for a student who is building hours towards his instrument rating. I have my IR but am not a CFI. We typically fly VFR with him under the hood as the "sole manipulator of controls" so we can both log PIC hours.

On an upcoming long flight, I'd like to file an IFR flight plan. We expect the conditions to be VMC, but we need to plan for the possibility being routed through some patches of light IMC. Are we permitted to both log the PIC time during which we are in VMC, and then just switch off "actual PIC" duties when we enter patches of IMC (during which time I would log "actual IMC" time, and he would log nothing)? In reality, it will be the autopilot doing most of the flying.


2 Answers 2


The FAA has a legal interpretation (Walker Letter, 2011) that addresses exactly this issue, and that's what I used for this answer. We also have this question and this one that cover very similar but slightly different scenarios.

First, PIC time. Since you're instrument rated and the other pilot isn't, only you can act as PIC under IFR. So, with that in mind, when can you both log PIC time per 61.51? You didn't mention the aircraft, but I assume it's a light single that only requires one crew member.

The key point here is that operating in simulated instrument conditions is an operation that requires more than one crew member. But operating in actual instrument conditions is not such an operation.

As long as you're in VMC and assuming that your friend is under the hood, you can both log PIC time. You're acting as PIC during an operation requiring more than one crew member (61.51(e)(iii)), he's the sole manipulator of the controls (61.51(e)(i)).

But when you enter IMC, your friend continues to log PIC time as sole manipulator, however you cannot log PIC time because you're not a required crew member while operating in IMC (see the penultimate paragraph of the legal interpretation above).

Second, instrument time. The only way to log instrument time (in your scenario) is described in 61.51(g)(1) (and see this question):

(g) Logging instrument time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

Assuming that only your friend controls the aircraft (manually or using the autopilot) then only he can log instrument time. If you take the controls in actual IMC then you would log instrument time but your friend wouldn't.

Third, putting it all together. Assuming that only your friend controls the aircraft throughout the entire flight and he stays under the hood while in VMC then you would log time as follows:

  • VMC. You: PIC (acting PIC while more than one crewmember is required). Your friend: PIC (sole manipulator), instrument (simulated IMC).
  • IMC. You: nothing. Your friend: PIC (sole manipulator), instrument (actual IMC)
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    $\begingroup$ While operating in IMC, it seems odd that the instrument-rated pilot, who is legally necessary for the plane to be flown there at all, now becomes "not required" whereas before, he was required. Is it correct that the instrument rating is separate from the "required crewmember" status? $\endgroup$
    – Ralph J
    Commented Jul 1, 2017 at 15:02
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    $\begingroup$ @RalphJ Remember that we're talking about logging PIC time here. The pilot with the IR remains acting PIC for the entire flight, regardless of flight conditions or who's controlling the aircraft. And AFAIK there's no link between an IR and being a required crewmember, it just so happens that simulated instrument flight is an operation that needs multiple crewmembers. If an aircraft's type certificate requires multiple crewmembers, they're required even under VFR. $\endgroup$
    – Pondlife
    Commented Jul 1, 2017 at 15:13
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    $\begingroup$ I would like to emphasize the part that states that there is no such thing as a safety pilot in IMC. $\endgroup$ Commented Jul 1, 2017 at 17:32
  • $\begingroup$ An IR student flying in VMC with you as safety pilot - both can log PIC. But in IMC (on an IFR flight plan listing you as the pilot), the student cannot log as a pilot of any sort -because you are not a CFI. $\endgroup$
    – Mike Brass
    Commented Apr 2, 2018 at 4:22
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    $\begingroup$ @MikeBrass If the student is rated in the aircraft then he can log PIC time whenever he's the sole manipulator of the controls - including in IMC - but he can't act as PIC because he isn't instrument-rated. I'm not sure if you read the interpretation I linked to, but it explains it in more detail. $\endgroup$
    – Pondlife
    Commented Apr 2, 2018 at 18:57

Your friend, who lacks an instrument rating, would be the sole manipulator of the controls of an aircraft conducting an operation (IFR flight). Since he is rated for the aircraft (not necessarily for IFR flight), he may log the time as the sole manipulator of the controls.

This is a frequent question, and there are numerous resources addressing it. https://www.aopa.org/training-and-safety/learn-to-fly/legacy-pages/aviation-subject-report-logging-pilot-in-command-pic-time

Addendum #1

A plain language reading of 14CFR61.51(e)(1)(i), which states: "(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights- (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;"

There are no other limitations which require the sole manipulator to have an instrument rating.

Furthermore, the pilot, acting as PIC, who is responsible for the safe conduct of a flight in IMC, and is rated in the aircraft, with a valid medical, and is current, is able to log time acting as PIC, whether or not they are the sole manipulator of the controls.

Therefore, the sole manipulator may log as PIC time they are the sole manipulator, and the pilot acting as PIC may also log time they are acting as PIC.

This topic frequently comes up and DPEs and Flight Instructors are fielding this question frequently. Not everyone gets it right all the time. Personally, I have had scores of instrument students take flight tests with DPEs and FAA Ops Inspectors, and I believe everyone of them has logged time in the manner the OP asks. I urge pilots to add details in their log book remarks, describing the situation and conditions, and while it might not be required to also include the name and cert # of the other pilot in shared duty flights.

Some clubs, and FBOs may have issues with who is responsible for flights, and you might consider memorializing your agreement prior to your flight. Also note that there is no reason why the acting PIC could not switch during a flight one or more times.

There are quite a few assumptions in this answer, such as there is no type certificate requiring multiple crew members, etc.

BTW, if the manipulator in this example, stays under the hood, they could continue to log as simulated instrument flight, even though the conditions are actual. Otherwise they may log instrument time, and since they are not rated, in this case, I would very strongly urge that the remarks section record the name and cert of the pilot acting as PIC, who would be required to have current instrument rating (and who could not log instrument time for that portion of the flight, or log any approaches, as they did not operate the aircraft for the approach).

  • $\begingroup$ I'm not sure that your comment about acting as PIC is correct for the specific scenario in this question. 61.51 lists various scenarios in which you can log PIC, but just acting as PIC by itself isn't sufficient. The Speranza interpretation states that explicitly. $\endgroup$
    – Pondlife
    Commented Jul 1, 2017 at 20:02
  • $\begingroup$ If the manipulating pilot remains under the hood the acting as PIC pilot is required by regulations, and by agreement is acting as PIC, and because he is required by regulations, he may log the acting time as PIC time. $\endgroup$
    – mongo
    Commented Jul 1, 2017 at 23:51
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    $\begingroup$ In VMC, I completely agree with you, but this question is about IMC too. I'm not sure if you read the two interpretations I linked to, but in Walker the FAA said that acting as PIC doesn't automatically mean you can log PIC: "being the PIC in this context is not a basis for Pilot A to log flight time". And the Speranza interpretation says that actual IMC is not an operation for which more than one pilot is required, therefore the acting PIC can't log time under 61.51(e)(1)(iii). So there's no way I can see that the acting PIC can log PIC during actual IMC time, unless he takes the controls. $\endgroup$
    – Pondlife
    Commented Jul 2, 2017 at 14:58
  • $\begingroup$ @Pondlife. Can aciting PIC log PIC during actual IMC, if not manipulator? I submit the following: 1. We accept that a non-instrument pilot may log time manipulating the controls, with a safety pilot, who can be acting PIC or SIC depending upon the agreement of the parties, and with some other assumptions. 2. There is no regulation which prohibits simulating instrument flight with a view limiting device, while in IMC conditions. 3. If the pilots agree that the manipulator shall fly with a view limiting device, then the rules require that there be another pilot, CONTINUED $\endgroup$
    – mongo
    Commented Jul 2, 2017 at 15:42
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    $\begingroup$ Well, all I can tell you (and the OP) is that your question "Can acting PIC log PIC during actual IMC, if not manipulator?" is exactly what the FAA addressed and they said no. How much weight you attach to that - or any other FAA legal interpretation - is indeed up to you. $\endgroup$
    – Pondlife
    Commented Jul 2, 2017 at 16:55

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