How to Log Safety Pilot Time (and When It Is PIC)

A safety pilot is a required crewmember only while the other pilot is wearing the view-limiting device, and that one fact settles almost every logging argument about safety pilot time. The requirement comes from 14 CFR 91.109(c): no person may operate a civil aircraft in simulated instrument flight unless the other control seat is occupied by a safety pilot who holds at least a private pilot certificate with category and class ratings appropriate to the aircraft. Take the hood off and the safety pilot goes back to being a passenger. Nothing logged after that point belongs in the safety pilot's book.

The case treated here is the common one: a single-pilot airplane in VFR conditions, one pilot under the hood, the other watching for traffic.

Why the safety pilot is a required crewmember

The requirement in 91.109(c) has three parts: a safety pilot with at least a private pilot certificate and the right category and class ratings, adequate vision forward and to each side (or a competent observer who supplements it), and, except in lighter-than-air aircraft, fully functioning dual controls. A single throwover control wheel is allowed in a single-engine airplane under conditions the same paragraph spells out.

One trap for anyone reading older material: the Chief Counsel interpretations quoted below cite "91.109(b)". The paragraph has since been re-lettered, so the safety pilot rule now lives in paragraph (c). Cite what the current eCFR shows.

Because the regulation requires that second seat to be filled, the safety pilot is a required pilot flight crewmember for the hood portion of the flight. That is why 61.3(a) and 61.3(c) apply (pilot certificate and medical in the airplane), and why 61.51(b)(1)(v) makes the flying pilot write down the safety pilot's name.

Acting as PIC and logging PIC are two different things

Most safety pilot disputes come from treating "pilot in command" as one concept. It is two. 14 CFR 1.1 defines the pilot in command as the person who has final authority and responsibility for the operation and safety of the flight, has been designated as pilot in command before or during the flight, and holds the appropriate category, class and type rating for the conduct of the flight. That is acting as PIC, and there is one per flight.

Logging PIC is governed by 61.51(e), which lists several independent ways to do it. Two matter here. Under 61.51(e)(1)(i), a private or higher pilot may log PIC time when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated. Under 61.51(e)(1)(iii), a pilot other than a sport or recreational pilot may log PIC time when acting 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.

The FAA has interpreted the two as separate questions. In the Herman interpretation (2009) the Chief Counsel wrote that "there is a distinction between logging PIC time and acting as a PIC," and that "rated" in 61.51(e) means holding the aircraft category, class and type ratings, not the endorsements needed to act as PIC. Hold onto that split. The flying pilot logs under (e)(1)(i). The safety pilot, if logging PIC at all, logs under (e)(1)(iii).

When the safety pilot logs second in command

A safety pilot who is not the acting PIC logs SIC for the hood time under 61.51(f)(2), which requires the appropriate category, class and instrument rating, if a class or instrument rating is required for the flight, while more than one pilot is required under the regulations. The regulation requiring the second pilot is 91.109(c), so the condition is met for the minutes the other pilot is under the hood and no others.

Read the instrument-rating clause carefully. It bites only "if ... required for the flight." A VFR flight in simulated instrument conditions does not require an instrument rating, so a non-instrument-rated private pilot can sit right seat in a Cessna 172 and log SIC while a friend shoots practice approaches.

Logging it is legal. Whether an employer counts SIC time from a single-pilot airplane toward its hiring minimums is a question the regulation does not answer.

When the safety pilot logs PIC

The safety pilot may log PIC time for the hood portion of the flight when the safety pilot is the designated acting pilot in command and is qualified to act as PIC of that airplane on that flight (14 CFR 61.51(e)(1)(iii), as read in the FAA Chief Counsel's Gebhart interpretation (2009)).

The Gebhart letter is the cleanest statement the FAA has made. Two rated pilots fly 187 nautical miles between airports. Pilot A flies the whole 2.2 hours and spends 2.0 of them under the hood. Pilot B acts as PIC and safety pilot. The Chief Counsel wrote that Pilot A "may log the entire flight (2.2 hours) of PIC flight time" as sole manipulator. Pilot B "may log the portion of the flight during which Pilot A operated in simulated instrument flight and Pilot B acted as the safety pilot (2.0 hours)" because Pilot B was a required crewmember for that portion.

Both pilots log PIC for the same two hours. That follows from (e)(1)(i) and (e)(1)(iii) describing different things.

The price of logging PIC is that you must be able to act as PIC, which means everything the regulations attach to that role. The ratings from 1.1. The 61.31 endorsements that Herman says are required to act but not to log. A flight review within the window in 61.56(c), and a medical that supports acting as PIC under 61.23. Designate the acting PIC before engine start and write it in both logbooks. A designation made after landing to improve someone's totals is not what the 1.1 definition ("designated ... before or during the flight") describes.

What the pilot under the hood logs

The flying pilot has the simplest entry. PIC for the whole flight as sole manipulator (61.51(e)(1)(i)). Simulated instrument time for the hood portion under 61.51(g)(1), which allows instrument time only when operating "solely by reference to instruments under actual or simulated instrument flight conditions." And, if the approaches are to count toward 61.57(c) currency, the location and type of each approach plus the safety pilot's name, which 61.51(g)(3) requires.

Cross-country time, if the flight meets the 61.1 definition, belongs to the flying pilot alone. Gebhart again: "a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight," because the safety pilot was a required crewmember for only part of it. Pilot A logged 2.2 hours of cross-country; Pilot B logged none.

The currency post walks the 61.57(c) calendar, and the IPC post covers what happens when it lapses.

Which medical the safety pilot needs

A safety pilot is a required pilot flight crewmember, so 61.3(c)(1) applies: a person may serve as a required pilot flight crewmember only with the appropriate medical certificate (or other documentation acceptable to the FAA) in the aircraft. For a pilot exercising private pilot privileges that means at least a third class under 61.23(a)(3)(i), unless the flight is operated under BasicMed, which is the 61.113(i) carve-out in the same paragraph.

BasicMed has a wrinkle. The FAA's own BasicMed FAQ, question 25, asks whether BasicMed can stand in for a medical when acting as safety pilot. The answer: "Only if you're acting as PIC while performing the duties of safety pilot," and BasicMed "cannot be exercised by safety pilots who are not acting as PIC but are required crewmembers." A BasicMed safety pilot takes the acting-PIC role, with everything it carries, or does not fly as safety pilot at all.

Two worked logbook entries

Suppose two private pilots fly a 1.8-hour practice session out of KRDU in a Cessna 172, with 1.4 hours under the hood and three approaches at KRDU and KTTA. The entries below are examples in standard logbook form, not a record of a real flight.

The column figures follow 61.51(e)(1)(i), 61.51(e)(1)(iii) and 61.51(f)(2), and the hood-time-only rule for the safety pilot follows the Gebhart interpretation (2009). The 0.4 hours before and after the hood went on belong to the flying pilot only.

The dispute an examiner will raise

The entry a DPE or an interviewer questions is the safety pilot's PIC column, and the question is who was in command, not the arithmetic. A line in both logbooks naming the acting PIC, written on the day, ends the conversation. A verbal agreement recalled two years later does not.

The second dispute is cross-country. Instrument applicants need 50 hours of cross-country as PIC under 61.65(d)(1), and safety pilot hours are tempting. Gebhart closes that door: the safety pilot "may not log any cross-country flight time for the flight." Leave the column blank.

The third is the IMC trip where a non-instrument-rated friend flies a leg. The FAA addressed it in the Walker interpretation, which answers a request dated August 11, 2011. Pilot A, instrument rated and acting PIC, lets Pilot B hand-fly a half hour in actual conditions. Pilot B may log PIC and actual instrument time as sole manipulator. Pilot A logs nothing for that half hour, because "Pilot A is not acting as a safety pilot" in actual conditions and no regulation requires a second pilot. The hood is what makes a safety pilot.

These are the Chief Counsel's readings of the regulation, not the regulation itself. If your logbook is headed for an airline interview or a certificate action, talk to an aviation attorney or AOPA's Pilot Protection Services about your situation. For everyone else: agree on the acting PIC before engine start, log only the hood time as safety pilot, and write the other pilot's name in the remarks every time.

This article is educational and is not a substitute for the current regulations, the AIM, official weather briefings, or instruction from a CFI. Check the current text at the linked sources before you rely on any detail.