Originally Posted by
Bowersbum
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. § 61.55(d)(4); § 61.3(e);§ 91.109(b);A safety pilot who is not acting as the PIC is not required to meet the instrument rating requirements of § 61.3(e). The instrument rating requirements of § 61.3(e) are PIC requirements.
As per § 61.55(d)(4), the rule provides an exception to the SIC pilot qualification requirements of § 61.55(a)(2) for being required to hold an instrument rating.
However, for the purpose of clarifying an incorrect statement in your question, you stated the person is not acting as either the pilot in command or as a second in command. That is not possible. A safety pilot is a required pilot flight crewmember [See § 91.109(b)]. Therefore, a safety pilot must either be acting as the PIC or as the SIC.
Additionally, 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 . . . .”
Look at the SIC reg that you mentioned so many times. The reg says that an SIC is only required by type certification or by regulations under which the flight is being conducted. These regulations have to do with OpSpecs, nothing to do with simulated instrument flight.
Simulated instrument flight requires a safety pilot. Since the safety pilot is required under this reg, he logs PIC. PERIOD. The pilot conducting the flight may also log PIC. Both people log PIC, just as an instructor logs PIC even when the student does.
SIC has NOTHING to do with safety pilot. Even if you could interpret the SIC reg to include safety pilot time, why would you when there is obvious guidance as to the ability of a safety pilot to log PIC?
look here
http://www.airlinepilotforums.com/fl...-logs-pic.html