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Old 01-26-2010, 04:01 AM
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Default Are you legal to act as a safety pilot?

I'm sure this question gets asked all the time, but as a safety pilot, do you have to be current in the aircraft such as your three takeoffs and landings in the last 90 days? Under 91.109 it just say appropriately rated in category and class, but now you're logging pic time and as per 61.57 you need to be current, correct? Stop me if I'm wrong but this is my interpretation of it.

Thanks for your thoughts.
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Old 01-26-2010, 04:34 AM
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61.57 applies to PIC flying passengers

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and --
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Old 01-26-2010, 07:40 AM
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Originally Posted by gestrich19 View Post
61.57 applies to PIC flying passengers

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and --
Not really correct, this one is complicated and confusing...



1. First off the SP is a required crewmember for the flight operation being conducted...he is not a "passenger". This means that neither pilot needs LDG currency.

2. Assuming the flying pilot is ACTING as PIC and the SP is LOGGING PIC, then the SP does not need any currency (FR, IPC, LDG). But as a required crewmember, he does need a medical (unless he is CFI, logging dual given in which case he is not a safety pilot).

But not everyone in aviation (including potential employers) are up to speed on all of the nuances of safety pilot logging. Safest thing to do is just to be 100% current to avoid any confusion down the road.
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Old 01-26-2010, 04:48 PM
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Originally Posted by rickair7777 View Post
Not really correct, this one is complicated and confusing...



1. First off the SP is a required crewmember for the flight operation being conducted...he is not a "passenger". This means that neither pilot needs LDG currency.
That's not completely accurate, Rick. A safety pilot is only a required crewmember when the flying pilot is under the hood. Unless the flying pilot is taking off and landing under the hood, whichever pilot is acting as PIC needs to be current.
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Old 01-26-2010, 04:50 PM
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Originally Posted by rickair7777 View Post
Not really correct, this one is complicated and confusing...



1. First off the SP is a required crewmember for the flight operation being conducted...he is not a "passenger". This means that neither pilot needs LDG currency.

2. Assuming the flying pilot is ACTING as PIC and the SP is LOGGING PIC, then the SP does not need any currency (FR, IPC, LDG). But as a required crewmember, he does need a medical (unless he is CFI, logging dual given in which case he is not a safety pilot).

But not everyone in aviation (including potential employers) are up to speed on all of the nuances of safety pilot logging. Safest thing to do is just to be 100% current to avoid any confusion down the road.
Agreed- That was what I implied when underling "passengers". Nice clarification though
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Old 01-26-2010, 04:54 PM
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Originally Posted by athlete526 View Post
I'm sure this question gets asked all the time, but as a safety pilot, do you have to be current in the aircraft such as your three takeoffs and landings in the last 90 days? Under 91.109 it just say appropriately rated in category and class, but now you're logging pic time and as per 61.57 you need to be current, correct? Stop me if I'm wrong but this is my interpretation of it.

Thanks for your thoughts.
It's complicated but ultimately pretty straightforward. As gestrich pointed out, the currency regulation applies to the pilot who is acting as PIC.

The place that people often get confused is that either the safety pilot or the flying pilot can be the pilot in command (forget logging for a moment; we're talking about acting as PIC). If the safety pilot is the one acting as PIC then the safety pilot must meet all the requirements for acting as PIC. Period.

If the safety pilot is not acting as PIC, then none of the PIC-specific requirements apply. SIC requirements will apply - some of them the SIC reg deals with it.

Back to logging - what the safety pilot may log depends on his status as PIC. If the safety pilot is acting as PIC, the safety pilot may log his flight time as PIC time. If the flying pilot is acting as PIC, then the safety pilot may log SIC time.
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Old 01-26-2010, 06:15 PM
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Originally Posted by NoyGonnaDoIt View Post
That's not completely accurate, Rick. A safety pilot is only a required crewmember when the flying pilot is under the hood. Unless the flying pilot is taking off and landing under the hood, whichever pilot is acting as PIC needs to be current.
I think the fact that he is required for any part of the flight means he is required for the entire flight. That rule does not change based on what phase of flight you are in...
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Old 01-27-2010, 04:26 AM
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Originally Posted by rickair7777 View Post
I think the fact that he is required for any part of the flight means he is required for the entire flight. That rule does not change based on what phase of flight you are in...
No but it does change based on whether the safety pilot is in fact a safety pilot, which is only when the hood is on.

Read the FAA Chief Counsel's analysis in the recent opinions about safety pilot not being able to log cross country time and see what you think. They are all primarily based on the the fact that a safety pilot is only a required crewmember for a portion of the the flight - when the hood is on the other pilot.

For example.

==============================
Pilot B was a required flight crewmember while acting as the safety pilot, but Pilot B may not log cross-country time for any portion of the flight because Pilot B was not a required flight crewmember for the entire flight
==============================

http://www.faa.gov/about/office_org/...is%20Glenn.pdf

In addition to the result that time builders don't particularly like, the Glenn letter and its companion Gebhart letter are a pretty good review of the safety pilot rules.

http://www.faa.gov/about/office_org/...09/Gebhart.pdf
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Old 01-27-2010, 07:38 AM
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Originally Posted by NoyGonnaDoIt View Post
No but it does change based on whether the safety pilot is in fact a safety pilot, which is only when the hood is on.

Read the FAA Chief Counsel's analysis in the recent opinions about safety pilot not being able to log cross country time and see what you think. They are all primarily based on the the fact that a safety pilot is only a required crewmember for a portion of the the flight - when the hood is on the other pilot.

For example.

==============================
Pilot B was a required flight crewmember while acting as the safety pilot, but Pilot B may not log cross-country time for any portion of the flight because Pilot B was not a required flight crewmember for the entire flight
==============================

http://www.faa.gov/about/office_org/...is%20Glenn.pdf

In addition to the result that time builders don't particularly like, the Glenn letter and its companion Gebhart letter are a pretty good review of the safety pilot rules.

http://www.faa.gov/about/office_org/...09/Gebhart.pdf
I've read it before and am familiar with it. The SP can't log XC time because XC is an end-to-end evolution, and the SP is (theoretically) not participating during the entire process. This actually makes sense to some degree.

But that does not make him a pax for TO and LDG...if he is a required crewmember for any part of the flight, he is required for the entire flight since it is impractical to have him leave the airplane after the hoodwork is done. What are you you going to do, give him a parachute?

Same thing with a check airman/CFI who needs to go up for a hop to observe a certain manuever. He's going to og the entire flight, even if his duties only required involvement in a particular phase of flight.

I think we'd have to ask the FAA to know for sure, but I think required for any part of the flight = required for the entire flight.
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Old 01-27-2010, 11:16 AM
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Originally Posted by rickair7777 View Post
I've read it before and am familiar with it. The SP can't log XC time because XC is an end-to-end evolution, and the SP is (theoretically) not participating during the entire process. This actually makes sense to some degree.

But that does not make him a pax for TO and LDG...if he is a required crewmember for any part of the flight, he is required for the entire flight since it is impractical to have him leave the airplane after the hoodwork is done. What are you you going to do, give him a parachute?
Of course not. But what's impractical about becoming a passenger instead of leaving the airplane?

If you want to ask the Chief Counsel feel free but if I were a betting kinda guy, I'd bet on the answer as pretty close to a sure thing.

Edit: I take that back. I forgot that the cross country thing was strictly policy considerations so there's no good way of predicting whether the Chief Counsel would be consistent.
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