How do you log time when flying with a Safety Pilot?

That question is probably one of the most asked questions about flying. First, let’s discuss the regulatory requirement that requires a safety pilot when flying simulated instrument flights. FAR part 91.109 (c) states in part:

FAR Part 91.109 (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

Second, it is important to realize there is a difference between “Acting as PIC” and “Logging PIC”.

Acting PIC

In order to be the “Acting PIC” on a flight involving a safety pilot, a pilot must hold at least a private pilot certificate with appropriate category and class ratings, meet recent flight experience requirements as stated in FAR Part 61.57, have a current medical ertificate as stated in FAR Part 61.23. The “Acting PIC” must also be properly endorsed for the aircraft (high performance, complex, etc.) as stated in FAR Part 61.31. Basically, all the normal requirements to be an Acting PIC. Although this is not necessarily a regulatory requirement, it is worth pointing out insurance related issues when “Acting PIC”. If Pilot A and Pilot B decide to go practice some simulated instrument flying, and Pilot A rents the aircraft from Aviator FBO, the FBO may require Pilot A to be “Acting PIC” since Pilot A most likely completed the required check out. So, if Pilot B wants to be “Acting PIC”, Pilot B might be required to be checked out by the FBO and be the one renting the aircraft.

Logging PIC

Not necessarily obvious, simply being the “Acting PIC” does not in itself give you any ability to log the time as PIC. FAR Part 61.51 (e) describes the provisions for “Logging PIC”.

For the sake of flying with a safety pilot, I’ll cover the two most appropriate logging provisions. FAR Part 61.51 (e)(1) in part states:

FAR Part 61.51 (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;
(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

When a pilot is flying in Visual Meteorological Conditions (VMC), visual contact must be kept with the ground, clouds, and other aircraft. The job of the safety pilot is to provide visual contact, and possibly take control and make evasive maneuvers should an emergency situation arise. When a pilot is flying with view restricting goggles on, this makes a safety pilot a required crew member.

So, how do you log the time?

Before the flight takes place, both pilots must discuss who is capable and willing to be the “Acting PIC”. This person assumes all responsibility for the safe outcome of the flight. There are two main scenarios.

Scenario 1: Safety Pilot is the Acting PIC If the safety pilot is capable (rated, endorsed, current, etc.) and willing to be “Acting PIC”, both pilots may log the time as PIC for the portion of the flight which the sole manipulator is wearing view restricting goggles using the provisions listed earlier. For the portion of the flight where the sole manipulator is not wearing goggles, only the sole manipulator may log the time as PIC (there is only one required pilot for this portion of the flight, so the one logging provision is no longer applicable). The pilot flying with the goggles on is the sole manipulator, and the safety pilot is the Acting PIC of a flight requiring more than one pilot.

Scenario 2: Sole Manipulator is the Acting PIC If the safety pilot is unable to be the Acting PIC for any reason, then there are no provisions which allow the safety pilot to log PIC time. This means that the sole manipulator may log PIC for the entire duration of the flight. The safety pilot, however, is able to log the time as SIC. This does not mean the safety pilot is “Acting SIC”, but there are provisions for “Logging SIC”. FAR Part 61.51(f) describes the requirements for “Logging SIC”.

FAR Part 61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. When the safety pilot is not acting as the PIC, the safety pilot is only a “required crew member”, meaning they must have a medical certificate, but does not need to be current or have a current flight review. This also means that they only need to be rated for category, class, and type for the aircraft being used, and does not need additional endorsements such as high performance or complex.

One last Logging detail to keep in mind:

When making the log book entries, don’t forget to include the name of the safety pilot. This is required by FAR Part 61.51 (b)(v).

Conclusion

It would be extremely difficult to try to address every possible scenario and question about simulated instrument flight and having a safety pilot so I have compiled the following Legal Interpretations which all help address various questions other pilots have asked the FAA Chief Counsel about acting as a safety pilot and how to log time. I recommend reading all of them to try to gain a full, thorough understanding.

Chief Counsel Interpretation - Beaty 2013

Chief Counsel Interpretation - Trussell 2012

Chief Counsel Interpretation - Glenn 2009

Chief Counsel Interpretation - Gebhart 2009

Chief Counsel Interpretation - Roberts 2012

Chief Counsel Interpretation - Walker 2011