Logging PIC time as Safety Pilot


When acting as a safety pilot for an instrument training flight, when can you log the time as PIC?

I have gotten two different answers for this question from different CFIs.

**1. **Only 1 pilot can log PIC time at a time, because unless you are flying with a CFI logging dual, there is only 1 PIC. Thus, the left seat pilot can log PIC time until “under the hood” or foggles, at which time the right seat, safety pilot assumes PIC responsibilities.

For example, if the flight was 2.0hrs and 1.5 was simulated instrument, the left seat pilot would’ve had .5 PIC and the safety pilot would’ve had 1.5 PIC. Both log 2.0hrs total flight time


**2. ** The left seat pilot logs the entire flight as PIC, and the safety pilot logs PIC for the time that the left seat pilot was “under the hood”.

For example, the flight was 2.0hrs and 1.5 simulated. The left seat pilot logs 2.0hrs PIC and the safety pilot logs 1.5hrs PIC. Both log 2.0hrs total flight time.

Is the correct answer #1 or #2 or am I wayy off.


My .02c is the safety pilot would log only 1.5 in either case since he/she is not a required crewmember when the “trainee” is not under the hood.
I’m not a CFI but as far as I remember, and I’m not going to look it up, I’ll leave that to Dami :smiley: , the sole manipulator of the controls and the person ultimately responsible for the flight can both log PIC time. As long as both are otherwise qualified to be PIC of course.
I’ll throw another possibility out there too. That would be the sole manipulator gets the PIC time and the safety pilot gets SIC time since he is a required crewmember for the time spent under the hood.

One thing I can almost guarantee is you will get more than one opinion here too.

John in Saudi


Question… You’ve labeled this as an “instrument training flight”, so is the pilot going “under the hood” instrument rated?


I was under the impression the safety can log 1.5 hours for ONLY the time the pilot was under the hood and the pilot doing simulated instrument would log the entire 2 hours. All my training was with a CFI so I really never paid any attention WRT a non CFI safety pilot.

I do know when I act as safety (NOT a CFI) MYSELF and I am not out for any additional ratings, I don’t log any time since I didn’t feel like I was “sole manipulator” of the controls, just keeping my eyes out the window for avoiding sharing airspace with another airborne object (bird, plane or clouds). The pilot needing me as safety does write my name down in his logbook as safety and claims the entire flight as PIC.

It would seem to me it would defeat the purpose of using a safety pilot vs a CFI to build hours if the pilot needed those hours toward a rating and couldn’t claim them especially in my situation where only .5 hour would be claimed by the “hooded pilot” if he couldn’t use the hood time as PIC?


Yes, he is instrument rated, but in this scenario I am assuming we are VFR for the entire flight, so instrument rated or not he can log PIC. However, if the flight was IFR and the left seat pilot is not instrument rated, to log PIC he/she would have to be logging dual with a CFII in the right seat.

I think you’re correct Allen… After talking with two of the instructors at the flight school today this is the same answer they gave me. The left seat pilot logs PIC for the total flight time, safety pilot only logs PIC for the time the left seater was under the hood.

I originally poised this question because I was flying safety pilot for my dad today. He wanted to get a few approaches in to maintain instrument currency. He’s a CPA so he’s going into “busy season” with work so he won’t have time to fly much in the next few months.


A “safety pilot” may not log any PIC as they are not the sole manipulator of the controls. They are merely present in a safety capacity and not a required crew member, nor the responsible party for the aircraft under the definitions of Part 1.

A CFI may log PIC even when not the sole manipulator of the controls if they providing instruction.


Ding, Ding, Ding! We have a winner! 8)


Who is PIC, and who may log PIC time are 2 seperate issues. Here is a good read for those of you who do not believe that both can log PIC time. In short, both can log PIC time, provided that the safety pilot is PIC, and the pilot under the hood is the sole manipulator of the controls. tinyurl.com/nzej9r


Excuse me while my head explodes…http://www.freesmileys.org/smileys/smiley-think001.gif



Not necessarily… And not in the OP’s scenario…because the aircraft/operation in question does not require more than one pilot/crew-member.

Taken from your own reference:

However, two pilots may not simultaneously log PIC when one pilot is sole manipulator of the controls and the other is acting as pilot-in-command if the regulations governing the flight do not require more than one pilot.


I initially thought the same Az, but in order to fly under the hood, the flight requires a second pilot based on regulations governing simulated instrument?

Wouldn’t that fit the bill?


Actually the safety pilot is a required crew member, and as such is allowed to log the time as PIC as well, but only for the time when the other pilot is under the hood.

When I was flying in our 141 school, this was actually school practice to assist with building time. In order to have the total time needed to take instrument and commercial checkrides, we would often fly in groups of two, with one flying under the hood, and the other acting as safety pilot.


That’s the way this layman read it, until my head exploded of course.


A safety pilot required under Part 91.109(b)(1) doesn’t automatically make them eligible to log PIC time. They are still not the “sole manipulator of the controls”, and the aircraft does not require two pilots under its TC.

The ONLY way the “safety pilot” can log PIC during simulated conditions is if the “safety pilot” is designated as PIC under Part 1. Which is probably the way davysims’ 141 school did it. The “safety pilot” would be the one to sign for the aircraft and assume all responsibility (thereby eligible to log PIC during the simulated portion of the flight), while the “sole manipulator of the controls” logged the rest.


If I read correctly, if it doesn’t make it automatically under part 91, then it can be done?

In order for me to be a safety, I have to be rated for the plane (I.E high performance or complex for which I am not) so there has to be some merit under part 91 for me to be able to be PIC as safety?

After reading the reference, the way I understand it, the PIC part of the safety would be for cloud clearance requirements, dodging other flying objects and any airspace considerations. Since a non pilot passenger can’t do this legally or understand the regs, hence the PIC part for the safety pilot aspect?

In your situation Az, if I let somebody fly my plane, can I be PIC as safety since I am responsible and assuming all responsibility for my plane?

Not trying to be argumentative, but trying to see where the difference between part 141 and 91 would be for which I really am not seeing a distinction in the regs.


Like I said earlier in the thread, and by reference to skyshark’s FAA link. No.

You can act as a safety pilot if you are qualified in category and class regardless of HP/complex. But being a “safety pilot” doesn’t make you PIC, nor does it qualify you to log PIC.

No. The only way to “be” PIC is to be responsible for the flight. The only ways to “log” PIC is to be the sole manipulator of the controls in an aircraft that only requires one pilot, or in an aircraft that requires two pilots…be the responsible party of the flight while not manipulating the controls.

Yes…a pilot in an aircraft that requires two pilots that is the designated PIC under Part 1 may log PIC while not being the sole manipulator of the controls. Part 61.51(e)(iii)

Also keep in mind that although the activities under 91.109 may require a safety pilot…that does not make that pilot a “required crew member”. Again, two very different things.

In this case you would “be” the PIC, but could not “log” as PIC if you were not manipulating the controls.

Part 141 has nothing to do with this other than under davysims’ scenario at the 141 school they have to “sign” for the aircraft and designate a PIC under the definitions in Part 1. And still (in a single pilot airplane) only the sole manipulator of the controls would be eligible to “log” PIC, unless the non flying pilot was a CFI giving instruction.

Remember, as skyshark150 said…

Who is PIC, and who may log PIC time are 2 seperate issues.


Tongue in cheek on this one Az as I fully understand the manipulation of the controls (mentioned in my original post as to why I don’t even log the time I am safety myself)

Gotta luv the FAA in a scenario that I would be PIC but can’t log it. :wink:


Caugh, Caugh it’s called “Parker Pen time”…


azav8r doesn’t have it quite right.

In the OP, Hood guy gets 2.0 PIC, 2.0 total, safety pilot gets 1.5 Total, and 1.5 PIC or SIC, his choice based on what the pilots agreed too. As soon as the hood comes off, the safety pilot is no longer a required crew member.

91.109 (b)(1) makes the safety pilot a required crew member as soon as the hood goes down. If ahead of time, both pilots agree that the safety pilot is PIC during the hood time, 61.51 (e)(1)(iii) applies and the safety pilot can log PIC.

This is 61.51 (e)(1)(iii):

The first part is what azav8r is saying is that you can’t log PIC if the airplane doesn’t require 2 crewmembers, and he’s right. However he missed the part I bolded about the regulation you’re flying under also triggering additional required crewemembers.

14 CFR 91.109(b)(1) says safety pilot is required, MAKING THE SAFETY PILOT A REQUIRED CREWMEMBER and 14 CFR 61.51 (e)(1)(iii) says if you’re required, you can log PIC if you act as PIC. So both pilots can log PIC while the hood is on.

Don’t take my word for it, take it from the FAA:

faa.gov/about/office_org/fie … 20TIME.pdf

–Carlos V.


A good flow chart as to when you can log PIC, with citations:


–Carlos V.