Kevin Morisette, CFII
Sacramento Flight Lessons
Kevin Morisette, CFII

How to Log Safety Pilot Time

(Updated May 2017 for new FAA BasicMed rules now in effect)
How to Log Safety Pilot Time

A common question that often comes up is how to log time while acting as a safety pilot for another pilot who is flying under the hood in simulated instrument conditions. First, in order to act as a safety pilot, you must possess at least a Private Pilot certificate, have a current third class medical OR operate under BasicMed (with the exception below), and have the appropriate category and class rating (ie: airplane single engine land). See excerpts from FAR 91.109 and 61.3 below:

FAR 91.109(c)(1)

(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.

Under the new regulations you can operate under BasicMed and perform safety pilot duties as long as you are the acting Pilot-in-Command (PIC) as the rule only applies to the PIC for the flight. FAR 61.3(c) below still requires safety pilot's operating as a "required crewmember" (which would be SIC) to have a medical certificate.

FAR 61.3(c)

Medical certificate. (1) A person may serve as a required pilot flight crewmember of an aircraft only if that person holds the appropriate medical certificate issued under part 67 of this chapter…

Pilot in Command (PIC)

You can log the time during which the pilot flying is using a view-limiting device as either Pilot in Command (PIC) or Second in Command (SIC) time. Whether you can log PIC time depends on if you will be acting as PIC (and responsible) for the flight. This must have been decided with the other pilot before taking off and you must legally be able to act as PIC.

Legally being able to act as PIC includes having a current flight review and any required endorsements for the aircraft you’re flying (high performance, complex, etc). If you’re going to fly on an IFR flight plan and you don’t have an Instrument Rating, you won’t be able to act as PIC. However, if you're flying under VFR, you don't need an instrument rating. You also need to consider if you’re covered by insurance to act as PIC. If you’re flying in a friend’s plane, his insurance policy may only cover your friend or have other restrictions. FAR 61.51(e)(iii) below allows you to log PIC time since you will be “acting” as PIC and you as the safety pilot are required by the "regulations under which the flight is conducted" while the pilot under the hood will be able to log PIC as well since he is the “sole manipulator” of the controls under FAR 61.51(e)(i).

FAR 61.51(e)(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; …

If the safety pilot is PIC for the flight, they must also have the needed takeoffs and landings for the 90-day passenger carrying currency requirement per FAR 61.57. This is because even though the pilot under the hood is flying and logging time as the sole manipulator of the controls, they are a passenger in a plane that only requires one acting PIC.

Second in Command (SIC)

If you don’t meet the above requirements to act as PIC (or you decide not to), you may log SIC during the time the pilot flying is under the hood. In this case, you only need to possess at least a Private Pilot certificate, have a third class medical, and have the appropriate category and class rating. Operating under BasicMed does not allow you to fly as a "required crewmember" and not also be acting as PIC. You may also log SIC time if you're flying on an IFR clearance and the pilot flying is acting as PIC (such as if the pilot flying is the only one with an instrument rating and is instrument current).

FAR 61.51(f)(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.

Other Details

As a safety pilot you aren't able to log cross country time (to count towards another certificate or rating) as the definition of cross country in FAR 61.1 says the flight "includes a landing at a point other than the point of departure" and since the safety pilot doesn't normally make the takeoffs or landings, cross country time isn't logged.

Finally, when logging the flight, the pilot under the hood must log the name of the safety pilot in their logbook, as well as the usual information (date, flight time, location, type of aircraft, and the type of each instrument approach flown as specified in FAR 61.51).

- Kevin Morisette is a CFII providing flight instruction in the greater Sacramento area.

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