Could you provide any guidance on this? I never logged Dual received in IMC as PIC until I had instrument privileges because that's what the reg says. Does anyone know of an AC on this?

If in doubt, call your local FSDO and ask to talk to an Aviation Safety Inspector, Operations. You may even call 2-3 FSDO's and compare answers.

This talk has gone on many many many times and I just have three things to say:

1) Read the article; EAA445 SAFETY PILOT

2) Check out the thread on this; http://www.airlinepilotforums.com/fl...-time-pic.html

3) 61.31(d)2. Limitations on operating an aircraft as the Pilot in Command. To serve as the Pilot in Command of an aircraft, a person must......
Be recieveing training for the purpose of obtaining an additional pilot certificate and rating that are appropriate to that aircraft, and be under the supervision of an authorized instructor.

I would recommend that everyone get a copy of the FARs explained by Kent S. Jackson It answers many questions that folks like to argure about.

Seems to me that according to this as long as the training is going towards their commercial pilot cert. they can log the time as PIC. As long as before they solo it or take it up with a non-instructor they get their endorsment there shouldn't be a problem.

That is a terrible article. There is no way that a safety pilot can EVER log SIC. SIC is a completely different reg and with misinformation like that, there is no way you can believe the rest of the article. Safety pilot is PIC, PERIOD! It has absolutely nothing to do with who gets violated or who the two pilots deem the sole manipulator of the controls. If I, an Instrument rated commercial pilot with a CFII, file an IFR flight plan and use a private pilot for a safety pilot to put the foggles on for practice approaches, and bust an altitude, he's gonna log every bit of it as PIC, and I'm gonna put every bit of my certificate in front of the Feds

FSDO is always a good idea, whatever they tell you is the word on that issue!

WRONG!

I once had a Fed tell me:

"Its funny, we looked through the regs and couldn't find anything that said a pre-private could not file an instrument flightplan. He just can't fly through a cloud."

seriously

RIGHT!!

Are you inferring that you know better than the FSDO. Walk into court with your opinion and lose. Walk into court with a defense of, I have a written interpretation of the rule right here from the FSDO, and win! You haven't a clue what you are talking about!

an obvious reg trumps anything a fed tells you. they might fire him, but that doesn't absolve you from reading and knowing the regs.

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