SAFETY PILOT OPERATIONS

SAFETY PILOT OPERATIONS

During training for an instrument rating in an airplane, the applicant is required to obtain 40 hours of instrument flight time, but only 15 of those hours must be with an instrument instructor. It is common for a pilot in training to recruit another pilot (not an instructor) to serve as “safety pilot” to allow the trainee pilot to fly with a view-limiting device (“under the hood”) and thus acquire some of the required instrument flight time without having to pay an instructor. Questions frequently arise as to the requirements for conducting this kind of operation and how the time may be logged by each pilot.

The operation is authorized by FAR 91.109(b):

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(b) No person may operate a civil aircraft in simulated instrument flight unless --

(1) The other control seat 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.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and [minor provisions snipped out]

Several observations on this regulation are in order:

1. Under this regulation, the safety pilot becomes a “required crew member” “under the regulations under which the flight is conducted”. This has implications in how other parts of the FARs apply.

2. It imposes no requirement on qualifications of the Pilot Flying (PF), only on the Pilot Not Flying (PNF) or safety pilot. Thus the PF may hold only a Student Pilot Certificate, or no pilot certificate.

3. The safety pilot must be in a “control seat”, which means a seat from which he has full access to flight controls.

4. The safety pilot must be at least a private pilot and be rated for the aircraft, meaning only that he have appropriate category and class ratings on his private, commercial, or ATP certificate.

5. There is no requirement that the safety pilot be qualified to act as Pilot In Command of the airplane. For one thing, this means that the safety pilot need not have endorsements for tailwheel, high performance, complex, or pressurized aircraft. For another, it means that the safety pilot need not be current in the sense of FAR 61.57 pertaining to flight reviews, instrument proficiency checks, or takeoffs and landings.

6. There is no requirement that the safety pilot have an instrument rating.

7. There is no requirement in just this regulation that the safety pilot have a current medical certificate. However, FAR 61.3 says:

(c) Medical certificate. (1) … a person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of an aircraft, under a certificate issued to that person under this part, unless that person has a current and appropriate medical certificate that has been issued under part 67 of this chapter, or other documentation acceptable to the Administrator, which is in that person's physical possession or readily accessible in the aircraft.

Therefore, since the safety pilot is a required crewmember, he is required to have a current medical.

Another question that arises is whether the safety pilot must be the acting PIC. The answer is no, either pilot can act as PIC as long as he is qualified to do so by his certificate, ratings, endorsements, medical, and currency. The pilots should agree who is acting as PIC at all times during the flight. Only one pilot can be the actual PIC at any given time, and there should be no confusion as to who that is. The role of acting PIC may change during the flight by agreement.

But who is acting PIC does not determine who is able to log the flight time as PIC time. Logging of PIC time is explored in a separate treatise, but one can see FAR 61.51(e) and numerous questions and answers in the Part 61 FAQ. Basically, one can log PIC time if he is rated for the aircraft and is the sole manipulator of the controls, if he is a required crewmember and is acting as PIC, or if he is the sole occupant of the aircraft.

Still another question that arises is whether the two pilots can log the time as instrument time. Sayeth FAR 61.51:

(g) Logging instrument flight time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

(2) An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions.

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of §61.57(c) of this part, the following information must be recorded in the person's logbook --

(i) The location and type of each instrument approach accomplished; and

(ii) The name of the safety pilot, if required.

Subparagraph (1) uses the phrase “operates the aircraft”. The FAA intends this as a hands-on requirement, that is, you must be actually manipulating the controls. Just using your eyes for collision avoidance and to maintain VFR does not qualify, so a safety pilot cannot log instrument time. Neither can an instructor, except for the time that instruction is being given in actual instrument flight conditions.

The Part 61 FAQ contains numerous questions and answers on these topics. Search for “safety pilot”.