ACTING as an SIC and LOGGING SIC time are two different things and you do not necessarily need to be the SIC to log SIC time. Much like how you can log PIC time in a complex airplane without a complex endorsement when receiving training toward the endorsement with a CFI. You are not legally allowed to ACT as the PIC however, you ARE allowed to LOG PIC time.

I quoted the EXACT words from 14 CFR 61.51(f)(2) that state it doesn't matter if you NEED an SIC to fly the plane or not. Since the OP is not able to log PIC time (no HP end), he may choose to log SIC time instead and if he does, all that matters is if the OP ..."Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted." 14 CFR 61.51(f)(2) Since he does meet both of those aspects, he may log SIC time. Again, you are NOT the SIC and you are NOT ACTING as an SIC AT ALL, you are simply acting as a safety pilot and logging SIC time instead of the normal PIC time that you would be allowed if you were able to act as PIC.

I know this practice may not sound proper and airline interviewers may question your SIC time in a Baron but if you read the rule quoted above, it is pretty much clear whether it is allowed or not. Explaining the situation and why you logged it the way you did to the interviewer should suffice.

Now, your referenced FAA interpretation about not logging XC time or the Taxi/TO/and LDG, that is totally understandable and proper because once you stop flying under the hood, you are no longer required to be there thus, no logging time.

 

That's the best part about the whole thing. Punish the people who understand the regulations as written by the FAA. Amazing how that works.

 

Fly Boy Knight is absolutely correct.

61.51(f)(2) says that one can log SIC when one

==============================
Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.
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Logical or not (and like it or not) the FAA has consistently put 91.109(b) and 61.51(f) together to say that simulated instrument flight with a safety pilot is a flight operation that requires more than one pilot.

The FAA Chief Counsel has said so as early as 1993

http://www.faa.gov/about/office_org/...1993/Hicks.rtf

and mentioned it in passing as recently as 2009.

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

That the safety pilot is an SIC also finds its way into other regulations. For example, the 61.55 rules on who may "act" Not to confuse with "log") as SIC refer to 91.109 safety pilots not requiring the familiarization training requirements in 61.55(b), although the other parts of 61.55 do apply.

 

When people bring up the "interview problem," it always leaves me wondering and a little frightened - if the airlines really don't understand (or don't like) the FAA's rules on how to keep time in logbooks, what other FAA rules don't they understand (or refuse to follow because they don't like them).

I'm not talking about employers who will discount that (or any other legitimate) time because they don't think it's valuable experience-wise. That's perfectly ok.

But this idea that the airlines insist that the FARs don't allow this time to be kept and counted toward FAA requirements for qualification and currency, if true, is very worrisome.

 

That's just the way it is...

The airlines have a somewhat limited understanding of a lot of these FAR's. Their screening is done by non-pilots and/or airline pilots who often spent relatively little (or zero) time in part 91. An entry-level pilot can CFI for a couple of years and move onto the airlines without ever getting into the depths of the regs that we do here on APC. If that guy gets involved in hiring ten years later, he is operating off of half-remembered, dated, limited knowledge of part 91.

That's why I advocate conservative time logging for the airline-bound folks. It may save you a difficult confrontation at an interview, and it may keep you from getting sent home. Even if you are legally right, you may not get the opportunity to explain yourself.

Airlines like these kinds of flight time...

Actual PIC (you signed for and flew the airplane)
Actual Dual Given (from a control station, not the back seat)
Actual SIC in an airplane certified for an SIC, or required under 135/121.

Anything gets a little doubtful, and in the past some airlines discriminated against SP time...they would give preferential treatment to someone with actual PIC.

 

I should start keeping 2 separate logbooks. An FAA one and an Airline one. My favorite example is suppose pilot pete worked for regional X for a certain amount of time on an ERJ-145 and eventually made captain with a PIC type. But he switches to regional Y and is an FO. He still is typed in the ERJ-145. So anytime he is the sole manipulator of the controls (on say, his leg), he should be able to log PIC since he is type rated and sole manipulator of the controls. Would anyone accept that? Never. Is it legal? Yes. But when the stuff hits the fan, who is the final authority? The guy in the left seat. My favorite example of logging vs acting.

 

Only 2? I've hung out in enough forums where this stuff is discussed to figure out that when employers and even individual interviewers make up their own rules about what they consider proper logging (as opposed to what they think is valid experience for the job) you might need a dozen logbooks.

My favorite example of logging for the airlines is the CFI at a small rural airport that gets an opportunity to do the FBO's check run or small on-demand operation. The employer knows the CFI and could care less about anything other than making sure that the pilot meets the FAA's requirements for a Part 135 PIC.

Too bad. The pilot "logged for the airlines" and, for that reason, lacks enough documented PIC and cross country flight time to meet the minimum requirements.

 

It might make sense to log "actual PIC" and "other PIC".

Seriously. It's a little late for me, but if I were starting out, knowing what I know now, that is exactly what I would do. It will save you some migraines filling out airline apps.

 

It's not that unusual for people to have a separate column to separate one from the other. The most common title I've heard is "Part 1 PIC" to differentiate "logged" PIC from "acting as" (Part 61)PIC. The problem, of course, is that "Part 1" PIC includes safety pilot time. But the concept works even though the defiitions might not.