More Safety Pilot Questions Answered

This month I thought I would answer some of the questions I routinely hear in connection with operations involving safety pilots, other than questions relating to how to log safety pilot time which was discussed in my January article Logging Safety Pilot Time.


Does a safety pilot need a current medical certificate? Yes. Section 91.109(b) requires a safety pilot for operations in simulated instrument conditions. And since 14 C.F.R. § 61.3(c) requires a person to hold a valid medical certificate in order to act in any capacity as a required pilot flight crewmember, a safety pilot must therefore hold a current, appropriate airman medical certificate.


Does a safety pilot need an instrument rating? No, an airman acting as a safety pilot under Section 91.109(b) does not need an instrument rating as long as the flight is being conducted in visual meteorological conditions. Additionally, an airman who possesses an instrument rating does not need to be instrument current under 14 C.F.R. § 61.57(c)(1) in order to act as a safety pilot because that section only applies to an airman acting as pilot in command, not an airman acting as a safety pilot.


Does a safety pilot need a high-performance endorsement prior to acting as safety pilot in a high-performance aircraft? Currently the regulations do not require a safety pilot to have a high-performance endorsement when acting as a safety pilot in a high-performance aircraft. However, the FAA does encourage those airman who act as safety pilots to be thoroughly familiar and current in the aircraft that is used. Presumably this would include operation of the components that make the aircraft a high-performance aircraft.


Does a safety pilot need a current flight review? No. The requirement in 14 C.F.R. §61.56(c) that a flight review be accomplished within the preceding 24 months only applies to airmen who act as pilot in command. As along as the safety pilot is not acting as pilot in command for any portion of the flight then he or she does not need a current flight review.


May a safety pilot log cross country time for a flight? A pilot only acts as a safety pilot during the time in which the other pilot is engaged in simulated instrument flight (e.g. wearing a view limiting device). Since simulated instrument flight does not include take-off and landing, a safety pilot is not a required crewmember during that portion of the flight. As a result, the safety pilot is not acting as a safety pilot for the entire flight and, thus, may not log cross country time for any portion of the flight.


Is a safety pilot a "second in command" for the flight? It is not uncommon for airmen to refer to their safety pilot as being "second in command." However, unless the aircraft being used is type certificated for operation by more than one pilot or the operation conducted by the pilots requires a designated second in command (e.g. an operation conducted under 14 C.F.R. 135.101 which requires a second in command for IFR operations), the designation of a safety pilot as an acting second in command crewmember is not accurate.


Under the regulations, an airman may "log" SIC time for the portion of the flight during which he or she was "acting" or "serving" as safety pilot because the safety pilot was a required flight crewmember for that portion of the flight under 14 C.F.R. § 91.109(b). In that situation, assuming neither the aircraft nor the operation requires two pilots, the airman is only "acting" or "serving" as a safety pilot, not as second in command for the flight.


Is a safety pilot required to share expenses with a private pilot for a simulated instrument flight? 14 C.F.R. § 61.113(c) provides that a private pilot may not pay less than his or her pro-rata share of the expenses of a flight with passengers. However, under Section 91.109(b), both the private pilot and the safety pilot are required crewmembers for the simulated instrument flight and neither is considered a passenger for the flight. As a result, assuming the only individuals on board the aircraft for the simulated instrument flight are the private pilot and the safety pilot, then Section 61.113(c)'s pro-rata expense sharing requirement does not apply to that flight.

As always, fly safe and fly smart.