Originally Posted by
rickair7777
Yes, you're missing something.
Instrument instruction in VMC conditions can be done one a VFR flight plan, or with flight following, or in non-congested areas all on your own without talking to anyone. You do not have to actually file IFR to log instrument instruction or to do practice approaches. If you are not in IMC and are not on an actual filed IFR flight plan, then the PIC does not need an instrument rating, just a PPL. The PIC can be under the hood.
A safety pilot must be rated (PPL or better) in the aircaft...he does NOT need to be current in the aircraft or have any medical at all. See 61.109
Of course pilots-in-training often share safety-pilot time in order to log PIC...and you do need to be current with a medical in order to log SP time as PIC. It's kind of a regulatory oddity...you MAY be a PIC as safety pilot, but you do not HAVE to be a PIC.
When you read the regs, you generally have to take them literally. Do not assume that anything not stated is implied, unless an FAA advisory circular or legal opinion has been issued to modify the literal interpretation.
No, no, no! This is all wrong. There have been many rulings that state the safety pilot needs to be able to act as PIC, whether or not they are logging PIC. Otherwise, why can't anyone that can look out a window be a safety pilot? They need to be able to legally fly the airplane.
This is backed up by the regulations. 91.109 says that the safety pilot is a required crew member for simulated instrument flight:
(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.
61.3 says that a required crewmember needs to have a current medical
(a) Pilot certificate. A person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of a civil aircraft of U.S. registry, unless that person—
(c) Medical certificate. (1) Except as provided for in paragraph (c)(2) of this section, 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.
The exceptions in (c)(2) have to do with student pilots, sport pilots, gliders, and balloons. The safety pilot needs to be able to act as PIC, and for that they need a current medical.