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How to Log Safety Pilot Time

by Darren Smith, CFII/MEI
from IFR Checkride Reviewer, September 2004
Updated May, 2009

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One of the best training experiences you can get is to share time with another pilot.  It's a great way to build your flight time while sharing the costs with another pilot.  Generally, whoever is sitting in the left seat is paying for the flight time on that leg.


Jim & Ted are going on a cross country from ABC to XYZ.  Jim will fly the first leg in the left seat while Ted is the safety pilot.  Ted will fly the return leg in the left seat while Jim is the safety pilot.  Here's a look at Ted's logbook.

The first line represents Ted sitting in the right seat for Jim for a 2.1hr cross country flight, 1.8 of that was PIC for Ted while Jim was under the hood.  Jim can log PIC as the sole manipulator of the controls, while Ted (as safety pilot) can log PIC because he was acting as the PIC (he has the responsibility for the safety of the flight) for a flight that requires more than one crew member.  (FAR 61.51) 

Question:  Why doesn't Ted get credit for cross country time? 
Answer:  He does not log cross country for that leg because§61.1(b)(3)(ii)(B) defines cross country time as time acquired during flight "That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure." If Ted did not perform the landing at the destination, then Ted doesn't get credit for cross country time.

Question:  Why doesn't Ted get credit for the full 2.1 hours of the flight?
Answer: While Jim was under the hood, Ted was a required crewmember and can log PIC time during that time which Jim was under the hood.  Ted was not a required crewmember during that time Jim was not under the hood and therefore can't log PIC.

The second line represents Ted sitting in the left seat with Jim as a safety pilot for a 2.1hr cross country flight, 1.8 of that was under the hood.  Ted performed 3 ILS approaches to runway 27 at ABC airport.  Ted can log PIC as the sole manipulator of the controls, while Jim (as safety pilot) can log PIC because he was acting as the PIC (he has the responsibility for the safety of the flight) for a flight that requires more than one crew member.  (FAR §61.51)

Can they both log PIC like this?  Yes!  That's the reason you'd even get involved in being a safety pilot.  You want to build your PIC time towards your commercial (250hrs for airplane and 150 hrs for helicopter).  We don't do this for SIC time.

Safety Pilot is Required, Qualifications of  (FAR §91.109)
FAR §91.109 says a safety pilot is required for simulated instrument flight (as a required crew member) and that the safety pilot must have:

  • a valid private pilot certificate §91.109(b)
  • appropriate category & class ratings §91.109(b)
  • a current medical certificate §61.31(d)(1); § 61.51(e)(1)(iii), § 61.51(f)(2), § 61.3(c); § 61.56(c), § 61.57(c), & § 61.3(c)
  • and meet all the other pilot-in-command currency requirements §61.3. 
After looking at this simple list of requirements, one could conclude all that's required is category and class rated and current with a medical.  With all things, it ain't over until the fat lady sings right?  The last word is always the FAA Administrator's lawyers who interpret the FARs for any given scenario.  After reading some legal opinions and discussing this with the FAA's chief legal counsel there are some caveats to this rule.  In order to be a safety pilot you must be able to act as PIC regardless of if you will log it as PIC.  This means that if you are not SFAR73 compliant for Robinson helicopters, you can NOT act as safety pilot in a Robinson helicopter even if you are category & class rated (Rotorcraft - Helicopter).  It also includes acting as safety pilot in tailwheel, complex, high performance, or high altitude airplanes.  If you do not carry the appropriate endorsements, then you are not qualified to be the required crewmember that you would be if you are acting as safety pilot.  You can not log PIC time.  For most folks, this is the whole reason to be a safety pilot.

Responsibility and Authority of the PIC (FAR §91.3)

The PIC is directly responsible for and the final authority in determining the airworthiness and operation of the aircraft.  The PIC may deviate from any FAR to meet the requirements of an emergency.  If the PIC deviates from a FAR, he or she shall, if requested, send a written report of the deviation to the Administrator.

Be sure you talk with your safety pilot about who is PIC for that flight.  It is a statement that should be made every time you fly with another pilot.  “I am PIC for this flight, should an emergency arise, I would like you to handle the radios and any other duties I assign.”

If you’re a flight instructor or a higher rated pilot than the PIC, make the following statement to protect yourself from liability should the PIC commit a violation or other emergency.  “You are the PIC for this flight, should there be an emergency, would you like me to handle the radios?” 

Instrument flight time may be logged… (§61.51)

  • During the time the flight is conducted solely by reference to instruments under actual or simulated IFR conditions.  If simulated IFR conditions, you must log the location and type of each instrument approach and the name of the safety pilot or CFII.
  • By an instrument flight instructor (CFII) when acting as an instrument flight instructor in actual instrument weather conditions
  • Actual Instrument can not be undertaken without an Instrument Rated PIC or CFII thus cannot be logged when using a safety pilot.
NEXT: Working with a partner for your IFR ticket>>
Who Pays?

How does it work?  There are two methods:
  1. You only pay for time you're in the left seat. When you're observing backseat, you're not paying, and when you are a safety pilot for your training partner, you're not paying.  This is a good method when you are working on an instrument rating with a dependable training partner.  If one partner needs more flight time than the other, the other isn't burdened with the added cost.
  2. Split everything exactly 50/50.  This is a good method for similarly skilled pilots who care about flight time just as much as getting their rating done. 
Both methods assume a qualified, dependable training partner. 

Safety Pilot Tips

  • Be sure that safety pilots are engaged in good collision avoidance techniques at all times during these operations.  See collision avoidance section for further details.
  • Have your safety pilot make announcements on CTAF frequencies during the critical phases of your approach.
  • Be sure that your approach does not conflict with prevailing traffic. 
  • Remember right of way rules (lower aircraft has right of way FAR 91.113) and be sure to announce your attentions on CTAF as “low approach only, full stop” etc.
  • When reporting position on CTAF, consider non-rated pilots lack of knowledge about outer markers and other approach details.  Announce positions as 5 mile final rather than outer marker inbound on the ILS.
  • Do not attempt practice approaches to towered airports without contacting approach control as you might conflict with other approaches in progress.  Do not enter Class B, C, D airspace without a clearance.
  • Safety pilots work with the PIC to maintain situational awareness, share decisions to operate the aircraft safely, and checks the PIC.
  • Acting as a safety pilot is the beginning of additional responsibility as a pilot.  Its a sign of your ability to accept higher levels of responsibility in multi-pilot cockpits.  Such roles include first officer and flight instructor. 
  • When you are acting as safety pilot, your primary responsibility is to be visual with your eyes outside the cockpit 97% of the time.  The other 3% of your time should be monitoring the pilot flying (PF).  As such, it is your responsibility to challenge flying that doesn't meet standards such as off heading, off altitude, off course, etc.  Use the call-outs in the related article:  CRM in Training.

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