Introduction
Here from Falcon Imagery and today I’m going to be going over the topic of safety pilot qualifications and how both the left seat and right seat pilot can both claim PIC time in their log books, while one’s acting as a safety pilot and while one is under the foggles or hood doing simulated instrument flying, so stay tuned, let’s get into this—safety pilot qualifications and how both pilots can earn PIC time.
Table of Contents
1. Purpose of Acting as a Safety Pilot
So the purpose of acting as a safety pilot, let’s just go into that a little bit. So, if you hold at least a Private Pilot certificate and want to build some simulated IFR flight time using foggles or a hood and flying in actual VFR conditions, you can do so if you meet the Safety Pilot Qualifications and have a fully qualified safety pilot with you on board and at the other control seat in the aircraft.
You can also use these types of simulated IFR flights to build cross-country flight time, at least for the person who is the sole manipulator of the controls of the aircraft, and in actually doing the simulated instrument flying. The safety pilot, however, cannot earn PIC time for that cross-country flight. You may also want to use a safety pilot if you’re an IFR-rated pilot and you want to maintain your currency, such as within the six months, getting your six required approaches in, your holds, and course intercepting and tracking tasks.
2. Qualifications for Acting as a Safety Pilot
So let’s go over the Safety Pilot Qualifications for acting as a safety pilot. So per 91.109(c), no person may operate a civil aircraft in simulated instrument flight unless one, the other control seats 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.
And there are some deeper caveats to that we’re going to get into in a few minutes. And then Part 61.3, the safety pilot must have a current medical to act as a required crew member on board during that flight.
And so they either need a Class 1, 2, or 3 medical or operate under BasicMed. It’s important to note that a Sport or Recreational Pilot doesn’t qualify as becoming a safety pilot because neither pilot license may act as a required pilot flight crew member in an operation requiring more than one pilot. So this operation of building the simulated instrument time requires a safety pilot, and so that in itself precludes a Sport or Recreational Pilot from acting as a safety pilot, not to mention 91.109(c) specifically calls out a Private Pilot certificate at least.
3. Logging PIC Time as a Safety Pilot
Let’s get into the qualifications for a safety pilot to log PIC time or piloting command time. So for the safety pilot to qualify to log pilot in command time while acting as a safety pilot, they should be fully legal to fly the aircraft, including category, class, and any required endorsements to fly the plane, such as a high performance, a complex, and/or a tailwheel endorsement. Also, before the flight, the two pilots need to decide which one is going to be the legal commanding pilot.
Normally, the safety pilot in the right seat is the legal pilot in command during the time the pilot in the left seat has the foggles and/or hood on, and the pilot in the left seat, during the time they are under the foggles or hood, is the acting PIC—provided the safety pilot qualifications are fully met by the right-seat pilot.
4. Who Logs What on a Cross-Country Flight
So, who logs what on a cross-country flight? Well, the pilot doing the takeoff and landings as the sole manipulator of the control gets to log the entire flight from the Hobbs start to stop, the entire time as acting PIC time, which is the whole Hobbs start to stop time, the cross-country flight, and the simulated instrument time while the foggles or hood were on—provided the safety pilot qualifications are met by the other pilot onboard.
The pilot acting as the safety pilot gets to log PIC time when the other pilot has their foggles or hood on. The safety pilot cannot log the cross-country time since they did not do the takeoffs and landings.
5. Example Logbook Entry: Pilot Under Foggles
So let’s look at a couple of examples of how the logbook would be filled out for this. So the logbook entry is for the pilot sitting in the left seat on the cross-country. This is the person who’s getting the simulated instrument time. So in this example here, we show them leaving on March 19th in a Piper Warrior, tail number 405C Bravo, with a safety pilot on board who meets all the required safety pilot qualifications.
They’re leaving a Leonian and going up to Bangor, Maine, and they’re going to make a remark that’s saying they’re doing simulated instrument flying with John Doe as the safety pilot, and they’re going to shoot two approaches up in Bangor and they’re going to do one landing. The total flight’s going to take 1.4 hours from start Hobbs to stop Hobbs.
The cross-country of course is 1.4 hours, it’s daytime flight, so 1.4 simulated instrument, the person here in the seat had their foggles on for 1.1 hours, so they get simulated instrument of 1.1 hours and they were the PIC either acting or legal PIC for the entire flight, 1.4 hours, and the total flight duration was the 1.4 hours. So, for the pilot left seat on a cross-country flight with foggles on for simulated IFR and cross-country time building, that’s what they would put in their logbook.
6. Example Logbook Entry: Safety Pilot
Now, for the safety pilot, the person sitting in the right seat, for example, here, the same information goes in: the date, the make and model, the aircraft, the identifier from/to particular airports. But now they’re saying safety pilot for, let’s say, Jane Doe. Now, where they get to claim PIC time is when they’re flying an airplane, single-engine land, 1.1 hours, daytime flight, 1.1 hours, pilot command 1.1, and total flight 1.1—assuming they meet all the necessary safety pilot qualifications.
So that 1.1 is the time that the guy in the left seat was wearing the goggles. You notice this particular right seat person is not putting any landing in, not doing approaches, but in the end, do they get to get this 1.1 hour of PIC time, 1.1 hour flight that they can put in their logbook? Now I put in green here: safety pilot has to be fully rated to fly the aircraft and can only log the time as the PIC when the left seat pilot is foggles or hood on.
So again, not only have to be category and class, but if they’re flying now a complex plane as the safety pilot, they had better have their complex endorsement to be able to count this PIC time, otherwise they have to do something different, which we’re going to talk about next.
7. Logging SIC Time as a Safety Pilot Without Endorsements
And here we go—qualifications for a safety pilot to log SIC time or second-in-command time. So the safety pilot can log second-in-command time that can be counted towards, for example, an ATP aeronautical experience per 61.51(f)(2). And this is again—get to count this as SIC time if you don’t have the proper endorsements to fully fly the aircraft, even if you meet the basic safety pilot qualifications.
For example, you are flying in the proper category in the proper class, airplane single engine land, but you don’t have the complex endorsement. In that case, you could log this, your safety pilot time, as second-in-command time, and it could go toward your aeronautic experience toward, let’s say, an ATP rating.
ATP rating requires per 61.159 a total of 1500 hours of total time as pilot, that includes at least 500 hours cross-country, 100 hours of night flight time, 50 hours of flight time in the class of airplane for the rating side, 75 hours of instrument flight time in actual/simulated instrument conditions, and overall 250 hours of flight time in an airplane as PIC or as SIC performing the duties of PIC while under the supervision of a PIC or any combination thereof.
8. Recommendation: Be Fully Qualified as a Safety Pilot
So if you notice at the top here in this section, you need a total time, total time of 1500 hours. That total time could be some PIC time, could be some SIC time, and so your time as a safety pilot only operating as a second-in-command could be applied toward meeting the ATP aeronautical experience. Now that said, I’m not a big fan of accruing SIC time for safety pilot, partly just for the safety perspective.
You know, I would rather have somebody as a safety pilot who is fully capable of flying the aircraft in the event I have a problem and am incapacitated or whatever.
So I want to make sure that person knows how to operate a complex aircraft or a high-performance aircraft if that’s what we’re flying in. And so I always suggest, if at all possible, get your endorsements that you need to fly the aircraft that you plan to be a safety pilot in, so you’re legal.
9. Final Thoughts
I’ll say one other point here—you noticed that it says 500 hours of cross-country time, that is for a full ATP. You can go to the airlines with a restricted ATP with 200 hours. So, just a kind of a side note there. So those are the requirements for being a fully qualified safety pilot, and how both you as a safety pilot and the person as a sole manipulator of the controls can earn PIC time while flying, as long as all safety pilot qualifications are met.
I think the most important thing to remember here, though, is to make sure if you’re going to be the safety pilot that you’re fully qualified to fly that aircraft as if you were flying it yourself. So not only the category and the class, but if there’s any required endorsements for that aircraft for you to legally fly—such as high performance or complex, or tailwheel endorsement—have those too before you actually go out and act as a safety pilot.
This way, there’s no doubt you’re fully qualified and capable of being the PIC in that aircraft in the event something needs to be done to safely fly that airplane, as long as you meet all the required safety pilot qualifications.
1. What are the basic requirements to act as a safety pilot?
You need at least a Private Pilot certificate with category and class ratings matching the aircraft, and a current medical certificate (Class 1, 2, 3, or BasicMed).
2. Can both pilots log PIC time during a simulated instrument flight?
Yes, the pilot under the hood logs PIC time for the entire flight (including cross-country time), while the safety pilot logs PIC time only when the other pilot is under the hood.
3. What should a safety pilot do if they lack endorsements for the aircraft (e.g., complex, high-performance)?
They can log the time as Second-in-Command (SIC) instead of PIC, though it’s recommended to get the necessary endorsements to be fully qualified.