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12 Answers

Can a safety pilot log the time as PIC when the other pilot is under the hood?

Asked by: 11010 views FAA Regulations, General Aviation

Can a safety pilot log the flight time that the other pilot is under the hood as PIC?

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12 Answers



  1. John D. Collins on Feb 11, 2012

    If the safety pilot is acting as the PIC they may log the time as PIC, otherwise they may log the time that they are the safety pilot as second in command time.  A flight instructor may log the time as PIC as long as they are providing instruction.  An example of the safety pilot needing to act as PIC would be they hold an instrument rating when the pilot under the hood does not and the flight is conducted under IFR rules. There are other possible examples, say the pilot does not have a complex or high performance endorsement, the aircraft is a complex or high performance aircraft, and the safety pilot is qualified to act as PIC.

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  2. Kris Kortokrax on Feb 13, 2012

    It is not required that there be a need for the safety pilot to act as PIC.  All that is needed is agreement between the two pilots that the safety pilot will act as PIC.  He may do so if he is qualified to act as PIC.
     
    Interestingly enough, in John Lynch’s FAQ, he opined that the safety pilot need not hold a U.S. private pilot certificate.  It may be from any country, so long as it is at the private level or better.
     

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  3. Derek Schwalenberg on Feb 13, 2012

    Acting as PIC and logging PIC are two different things. You can log PIC by definition whenever you either
     
    A) Sole manipulator of the flight controls [The guy under the hood]
    or
    B) Responsible for the safety of flight. [The safety pilot]
     
    So yes, you can both log PIC for the time period one pilot is under the hood. There have already been interpretations done on this.

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  4. Kris Kortokrax on Feb 13, 2012

    Derek,
    The stipulation in your option B is not sufficient to log PIC.  61.51 (e)(1)(iii) allows one to log PIC while acting as PIC of an aircraft requiring more than one pilot under the regulations governing the flight (91.109).  One may only act as PIC, if (as I said earlier) that person has been designated (by the agreement between the two pilots) and holds appropriate category/class, etc. (see FAR Part 1)
     
    The mere fact that one occupies the safety pilot seat does not guarantee the ability to log PIC (as might be the case where the safety pilot does not hold complex / high performance / high altitude endorsements).  He would meet the requirements of 91.109, but not the requirements of 61.31 to act as PIC and hence could neither act as PIC nor log PIC.

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  5. Derek Schwalenberg on Feb 15, 2012

    If one guy is under the hood and the other guy hasn’t agreed to be responsible for the safety of flight than your doing it wrong.

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  6. Derek Schwalenberg on Feb 15, 2012

    BTW Kris http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/daa4c54debeb6dca86256f3400626ab0/15c90b07303160f48625793b0068f317!OpenDocument
     
    61.31 is type rating requirements…

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  7. Nathan Parker on Feb 16, 2012

    Kris is correct in that the safety pilot isn’t automatically able to log PIC.  His comment agrees with John’s above and both are consistent with dozens of legal interpretations.  While a safety pilot might be in practice responsible for the safety of flight, he isn’t necessarily legally responsible for the safety of flight.
     
    However, if an accident occurs or a regulation is broken, the FAA will make its own determination about who was PIC, regardless of the agreement beforehand.

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  8. Ahmed Sheikh on Feb 26, 2012

    Thanks for the info everyone.  I’m flying with a buddy who is instrument rated, I am as well, and I am his safety pilot.  If we are flying and encounter IMC conditions, I can not log safety pilot time during the IMC portion of the flight, correct?

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  9. Drew Smith on Aug 10, 2012

    Jumping in late here, but John, are you saying an instructor can log PIC time if he giving instruction to a student under the hood? I’m not sure it’s so cut and dry. can you provide a source? I would think if you are on a VFR flight plane, your student (under the hood) would log PIC time and you would log DUal given. thanks for the help in advance.

    not at john, but to the general audience, since a safety pilot is a required crew member (per the FARs), the airplane is now a 2 crew airplane, the safety pilot must be fully qualified to fly the airplane, and the safety pilot by definition is responsible for the safety of the flight, i would claim he can log PIC time.

    your’s respectfully,
    johnny come lately

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  10. Josh on Feb 01, 2013

    61.51(e).

    No safety pilot cannot log pic 61.51(e)(1). A flight instructor can always log pic and dual given. when instructing a student 61.51(e)(1)(iv).

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  11. Florent on Jul 21, 2013

    Both can log PIC:
    – FAR 61.51(e)(1)(i) allows the person under the hood to log PIC time (if he’s rated on the category and class), as he is the sole manipulator of the controls of the aircraft.

    – FAR 61.51(e)(1)(iii) allows the safety pilot to log PIC time (if he’s rated on the category and class), as he’s in an aircraft requiring more than one pilot under the regulations the flight is conducted, and this regulation is FAR 91.109(c)(1).

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  12. Florent on Jul 21, 2013

    By reading the FARs, I would say that if two private pilots (or higher) with instrument ratings fly an aircraft, with one under the hood and the other as a safety pilot, both can log PIC time since:
    – FAR 61.51(e)(1)(i) states: “When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated”: This is the case for the pilot under the hood

    – FAR 61.51(e)(1)(iii) states: “When the pilot […] acts as pilot in command of an aircraft for which more than one pilot is required under […] the regulations under which the flight is conducted.”
    The regulation in question is FAR 91.109(c)(ii). As two pilots are required as per FAR 91.109(c)(ii), the safety pilot may elect to act as PIC, and thus log PIC time as per FAR 61.51(e)(iii).

    FAR 61.51(e)(3) states: “A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.”.
    Therefore, a CFI can always log PIC time when instruction is given.

    If I’m wrong, please let me know but with correct references to the FARs.

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