PIC-SIC Relevant Questions

Here are the specific Q&As excerpted from the FAA's FAQs that you might find useful. The full text of the FAA's 2004 FAQs and can be found by clicking here. This is the original source of the information that follows. In addition, if you're an AOPA member, click here for additional information on logging PIC and SIC.



QUESTION: If a private pilot is acting as SIC in a complex airplane, does that pilot need the complex endorsement?

ANSWER 1: §61.31(e); No, the complex endorsement does not apply; The complex airplane additional training requirement is only for pilots who seek to act as a PIC in a complex airplane. §61.55 may apply, if the complex airplane requires an SIC. {Q&A-67}



QUESTION: Is it true that a qualified pilot can log pilot-in-command time for all flight time during which he acts as a required safety pilot per 14 CFR § 91.109?

ANSWER: Ref. § 61.51(e)(1)(iii); Yes, the safety pilot can log the time as PIC flight time in accordance with § 61.51(e)(1)(iii) which states “. . . regulations under which the flight is conducted . . . .” {Q&A-88}



QUESTION: I believe that questions Q&A 95 and 88 deal with a safety pilot logging PIC flight time. Our Regional Counsel says that if a private pilot logs flight time and uses it to meet the aeronautical certification requirements for an additional rating, that is compensation. As you might guess, there are a bunch of Private Pilots out here that are using that safety pilot PIC flight time to qualify for additional ratings. If a Private Pilot acts as a safety pilot in accordance with § 91.109(b)(1), and that pilot logs that time as PIC in accordance with § 61.51(e)(iii), are they now in violation of § 61.113(a) since they have received compensation (free flight time) for acting as pilot in command [i.e., § 61.51(e)(iii)]?

ANSWER: Ref. § 61.113(a) and § 61.51(e)(iii); Yes, the Private Pilot who is serving as a safety pilot and is acting as the PIC may log the time as PIC flight time. And yes, that Private Pilot may use that PIC flight time for the furtherance of a pilot certificate and rating under Part 61. And no, that Private Pilot is not “. . . . carrying passengers or property for compensation or hire;” nor is that Private Pilot acting as a pilot in command “. . . for compensation or hire, . . . .” when he serves as a safety pilot. In accordance with § 91.109(b)(1), it permits a person who holds a Private Pilot Certificate with a category and class rating appropriate to the aircraft being flown to serve as a safety pilot. And this answer has been reviewed by the FAA’s Washington HQ Chief Counsel Office (AGC-240), and they have agreed with this answer. {Q&A-273}



QUESTION: According to §91.109(b), a safety pilot must possess at least a private certificate with appropriate category & class ratings. Is it necessary for that safety pilot to be “current” in the aircraft (landings, etc.)? Requirements of 61.55 specifically exempt safety pilots [§61.55(d)(4)], but where are the safety pilot criteria actually spelled out. §61.57 refers to pilot-in-command requirements, but a safety pilot is not PIC, only a required crew member. Further, has there ever been an interpretation that the safety pilot must be Instrument Rated for that type of VFR operation?

ANSWER: Ref. §61.31(d)(1); §61.51(e)(1)(iii), §61.51(f)(2), §61.3(c); §61.56(c), §61.57(c); A safety pilot is a “required crewmember” and must hold at least a valid private pilot certificate with category and class ratings appropriate to the aircraft being flown per §91.109(b) and a valid medical certificate per §61.3(c). A valid pilot certificate is one which has not been revoked or under suspension. That person who is serving as a safety pilot may choose to act as the legal pilot-in-command (per 14 CFR part 1) and log the time as PIC [per §61.51(e)(1)(iii)], or otherwise log the time as SIC time [per §61.51(f)(2)], but is not even required to log the time at all. However, the safety pilot's name must be logged by the person practicing instrument flight [per §61.51(g)(3)(ii)]. If the safety pilot is going to act as the legal PIC for the flight that person must “. . . Hold the appropriate category, class, and type rating (if a class rating and type rating are required) for the aircraft to be flown;” [per §61.31(d)(1)]. ). And if the flight is conducted in a high performance, complex, tail wheel, etc. aircraft and the safety pilot is acting as the legal PIC that pilot must have the appropriate endorsements that are required by §61.31(e), (f) and/or (i), as appropriate. This could be a reason why a safety pilot might only be able to serve as an SIC and log it as SIC time. And assuming the operation is a simulated instrument flight (as in the case the flight is performed in VMC conditions under VFR), the safety pilot would not need to hold an instrument rating. If any portion of the flight were conducted on an IFR flight plan (e.g., in and out of the clouds and/or even on an IFR flight plan) at least one of the pilots must have an instrument rating and the §1.1 PIC must be instrument current in accordance with §61.57(c) and be Flight Review current in accordance with §61.56(c).



QUESTION: I have two instrument students who wish to build time to credit for the 50 hours of cross-country PIC flight time required for the instrument and commercial certificates. They intend to fly cross-country flights together, trading off legs with one flying as safety pilot and the other manipulating the controls while under the hood. I've counseled them that the safety pilot may log the time as PIC only for the duration the manipulating pilot was under the hood and can not count the flight as cross-country towards the instrument and commercial rating requirements. Is it acceptable for the safety pilot PIC flight time to count towards these specific cross-country requirements?

ANSWER: Ref. §§61.1(b)(3)(ii), §61.51(e)(1)(iii); No. Your advice is good. The pilot performing the takeoff and landing, i.e., conducting flight in an appropriate aircraft per the definition of cross-country, is the person acquiring the cross-country credit. A safety pilot can not possibly log 100% of a flight since during visual operations [takeoff, landing, etc.] the safety pilot services are not required. The person that acts as safety pilot is no more than a passenger during the VFR portions of the flight. There is no logic, common sense or regulatory provision for a passenger, even a part time safety pilot, to log cross-country flight time. {Q&A-536}

QUESTION: In the December 1997 edition of “AOPA PILOT,” specifically page 22, “AOPA ACCESS,” the question was asked: “If I am flying as a safety pilot, can I log that time as pilot in command?” AOPA's answer is: “Yes. There had been talk during the rewrite process of changing this to specify only second-in-command time, but the final rule left log able safety pilot PIC flight time intact. Requirements remain being rated in category and class. You are allowed to log safety pilot PIC flight time because your eyes are required for aircraft safety and therefore you become a required crewmember. The pilot under the hood can also log PIC flight time as 'sole' manipulator of the controls.” §61.51(f)(2) seems pretty clear about safety pilots logging SIC rather than PIC flight time. What does AOPA know that we don't???

ANSWER: Ref. §61.51(e)(1)(ii): Yes, the time can be logged as PIC. Per §61.51(e)(1)(ii): The safety pilot, who meets the qualifications set forth in §91.109(b) may log it as PIC flight time because §61.51(e)(1)(ii) states, in pertinent part, “. . . the regulations under which the flight is conducted. Note, we say “may” but he “may” prefer to log it as SIC time. Your understanding is probably based on the preamble discussion on page 16250, middle column, of the Federal Register (62 FR 16250; April 4, 1997). We would highly recommend that you also read the preamble discussion on page 16250, first column, of the Federal Register (62 FR 16250; April 4, 1997). Per §61.51(e)(1)(i): The other pilot manipulating the controls, and who meets the qualifications set forth in §91.109(a)(2) and (b)(3)(ii) may log it as PIC flight time because §61.51(e)(1)(i) states, in pertinent part, “Is the sole manipulator of the controls of an aircraft for which the pilot is rated;” {Q&A-95}



QUESTION: Is it true that a qualified pilot can log pilot-in-command time for all flight time during which he acts as a required safety pilot per 14 CFR §91.109?

ANSWER: Ref. §61.51(e)(1)(iii); Yes, the safety pilot can log the time as PIC flight time in accordance with §61.51(e)(1)(iii) which states “. . . regulations under which the flight is conducted . . . .” {Q&A-88}



QUESTION: According to §91.109(b), a safety pilot must possess at least a private certificate with appropriate category & class ratings. Is it necessary for that safety pilot to be “current” in the aircraft (landings, etc.)? Requirements of 61.55 specifically exempt safety pilots [§61.55(d)(4)], but where are the safety pilot criteria actually spelled out. §61.57 refers to pilot-in-command requirements, but a safety pilot is not PIC, only a required crew member. Further, has there ever been an interpretation that the safety pilot must be Instrument Rated for that type of VFR operation?

ANSWER: Ref. §61.31(d)(1); §61.51(e)(1)(iii), §61.51(f)(2), §61.3(c); §61.56(c), §61.57(c); A safety pilot is a “required crewmember” and must hold at least a valid private pilot certificate with category and class ratings appropriate to the aircraft being flown per §91.109(b) and a valid medical certificate per §61.3(c). A valid pilot certificate is one which has not been revoked or under suspension. That person who is serving as a safety pilot may choose to act as the legal pilot-in-command (per 14 CFR part 1) and log the time as PIC [per §61.51(e)(1)(iii)], or otherwise log the time as SIC time [per §61.51(f)(2)], but is not even required to log the time at all. However, the safety pilot's name must be logged by the person practicing instrument flight [per §61.51(g)(3)(ii)]. If the safety pilot is going to act as the legal PIC for the flight that person must “. . . Hold the appropriate category, class, and type rating (if a class rating and type rating are required) for the aircraft to be flown;” [per §61.31(d)(1)]. ). And if the flight is conducted in a high performance, complex, tail wheel, etc. aircraft and the safety pilot is acting as the legal PIC that pilot must have the appropriate endorsements that are required by §61.31(e), (f) and/or (i), as appropriate. This could be a reason why a safety pilot might only be able to serve as an SIC and log it as SIC time. And assuming the operation is a simulated instrument flight (as in the case the flight is performed in VMC conditions under VFR), the safety pilot would not need to hold an instrument rating. If any portion of the flight were conducted on an IFR flight plan (e.g., in and out of the clouds and/or even on an IFR flight plan) at least one of the pilots must have an instrument rating and the §1.1 PIC must be instrument current in accordance with §61.57(c) and be Flight Review current in accordance with §61.56(c).



QUESTION: Another scenario, two pilots are out flying with one of the pilots serving as a safety pilot and that person has agreed to act as the PIC (i.e., §1.1) and log PIC while the other pilot uses a view limiting device. The other pilot is under the “hood” and is the sole manipulator of the controls while performing instrument tasks. No passengers are being carried. Which pilot has to be §61.57(a)(1) takeoff and landing current?

ANSWER: Ref. §61.57(a)(1); and §61.31(e), (f) and (i), as appropriate; I noticed you said no passengers are being carried. So the answer would be: at least one of the pilots has to be §61.57(a)(1) takeoff and landing current. As per §61.57(a)(1), it states, in pertinent part, “. . . no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and” Emphasis added “. . . of an aircraft carrying passengers . . .” In this scenario, you said no passengers are being carried. It is just two pilots out flying with one pilot under the “hood” performing instrument tasks and the other pilot is a crewmember acting as safety pilot. This safety pilot may act as the PIC and log PIC even if he does not have the §61.57(a)(1) takeoff and landing currency. (This may or may not be prudent in today’s litigation environment.) But, if a passenger were also on board, then the safety pilot must have the §61.57(a)(1) takeoff and landing currency and also be Flight Review current in accordance with §61.56(c) in order to be PIC and log PIC. {Q&A-377}



QUESTION: Is a person who is serving as a safety pilot for a flight under simulated instrument flight on an IFR flight plan required to hold an instrument rating if that person is merely only acting as a safety pilot? Notice, I did not say the person is acting as a pilot in command or as a second in command. The person is only onboard to act as a safety pilot. But the flight is going to be performed under IFR (instrument flight rules) and the pilot has filed an IFR flight plan.

ANSWER: Ref. §61.3(e)(1) or (2); §61.55(a)(2); §91.109(b)(1); The rating requirements to serve as a safety pilot are addressed in §91.109(b)(1). This rule requires a person who serves as a safety pilot in simulated instrument flight to hold “. . . at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.” Now, §91.109(b)(1), states “. . . No person may operate a civil aircraft in simulated instrument flight unless--(1)The other control seat is occupied by a safety pilot . . . .” This rule, in effect, requires the safety pilot to be a required “flightcrew member.” And, per §1.1, there are only 3 kinds of “flightcrew members, “ pilot, flight engineer, and a flight navigator [see §1.1 under “flightcrew member”]. One kind of required “flightcrew member” is a pilot [see §1.1 under “flightcrew member”]. The designations of a pilot “flightcrew member” is either a pilot in command (PIC) or a second in command (SIC). Another kind of required “flightcrew member” is a flight engineer [see §1.1 under “flightcrew member”]. And the other kind of “flightcrew member” is a flight navigator [see §1.1 under “flightcrew member”]. In the preamble discussion in the “Pilot, Flight Instructor, Ground Instructor, and Pilot School Certification Rules; Final Rule” on page 16237, middle column, of the Federal Register (62 FR 16237; April 4, 1997), the FAA stated that a safety pilot is a required crewmember. The FAA stated the following in that preamble discussion: “. . . In response to AOPA’s comment regarding instructors who act as safety pilots not being required to have a medical certificate, the FAA notes that §91.109 specifies that a safety pilot is required to conduct simulated instrument flight, which makes the safety pilot a required crewmember . . . .” Therefore, a safety pilot is either a PIC “flightcrew member” or an SIC “flightcrew member” and either way “. . . makes the safety pilot a required crewmember . . . .” [see “Pilot, Flight Instructor, Ground Instructor, and Pilot School Certification Rules; Final Rule” on page 16237, middle column, of the Federal Register (62 FR 16237; April4, 1997)]. So, when a safety pilot is ACTING as the pilot in command “flightcrew member” under IFR and the flying pilot is conducting simulated instrument flight, then in accordance with §61.3(e)(1) or (2), the safety pilot would be required to hold the appropriate instrument rating (or an airline transport pilot certificate with the appropriate instrument privilege). or So, when the safety pilot is ACTING as a second in command “flightcrew member” under IFR and the flying pilot is conducting simulated instrument flight, then in accordance with §61.55(a)(2), the safety pilot would be required to hold the appropriate instrument rating. {Q&A-529}



QUESTION: Is an airman who serves as safety pilot in accordance with 91.109(b) required to have a current medical certificate in their possession, and indeed, be medically qualified even if the “Safety Pilot” is not going to act as the PIC?

ANSWER: Ref.§61.3(c)(1). Yes. The safety pilot is a required crew member per 91.109(b) and is therefore required to hold at least a current 3rd class medical certificate per §61.3(c)(1) even if he/she is not acting as the PIC. {Q&A-293}; {Q&A-232}

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