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Safety Pilot Qualifications

Posted by on November 10, 2008 16 Comments Category : Flight Instructor Blog Tags : , ,

This question comes from Sylvia:

This came up recently at the airfield coffee shop: what qualifies a pilot to act as a safety pilot? Specifically in terms of the 3 take-offs and landings every 90 days in order to stay current … is it ok to take a pilot with you for safety? Or do you have to do have a qualified instructor if you are nervous about doing your circuits solo, having gone out of date?

Safety Pilot.  As you hang around an airport, you’ll hear this term quite a bit and if you listen to how this word is used you’ll notice that the term has taken on a life of it’s own.  Some people use it to define flying around the pattern with another pilot friend or has someone who works the radios on a cross country flight.  If you are looking for a safety pilot, there is even a Safety Pilot Club website!  However,  I think it is important to begin with the official definition and designation from the FAA.

A safety pilot is mentioned only in a couple of places in the regulations.  The primary reg being 14 CFR 91.109 .  In this reg. you find the official definition and designation of a safety pilot.  The reg says:

(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.

The only other regulation that mentions a safety pilot is 61.51 which deals with logging of instrument time.  In summary this reg says that you have to record the name of the safety pilot if required by the aforementioned 91.109.

So basically, a safety pilot has one purpose:  Look out the window for traffic when the other pilot isn’t!

So getting back to the question from Sylvia.  It would be my interpretation that you cannot use a safety pilot to get current on landings.  Why?  Because unless they are required for flight in simulated instrument conditions they are not a required crewmember and then would fall into the category of passenger, not pilot.  And in order to fly passengers, you of course, need to meet the requirements of 61.57 – recent flight experience.

Some may argue that you could use a Safety Pilot if the Safety Pilot was fully qualified and current to be PIC and allowed the pilot to take the controls for the 3 required landings.  My question however is then, how would that time be logged?  You couldn’t log it as PIC in your log book (only one crewmember required) and you couldn’t log it as dual received or SIC.

I think the only answer the regulations provide is that you either have to fly by yourself or take a CFI in order to meet the recency requirements of 61.157.   I promise I’m not just saying that because I am a CFI 🙂  Again, this is just my humble interpretation and that a $.50 still won’t buy you a coffee.

I think this stresses the need to stay current and the continuing maintenance aspect of becoming a pilot, whatever your level.  I don’t know about you, but I get rusty after not flying for two weeks, I can’t imagine how rough it would be after 3 months!

So make sure you are flying frequently and always



  1. Paul on Nov 10, 2008

    And somewhat related…. how about if you are not instrument current (but not yet at the 1 year mark requiring an IPC) – does the safety pilot have to be instrument current? instrument rated? if Private only do they need to be PIC current?

    Safety pilot stuff hurts my head.

  2. instructor on Nov 10, 2008

    Ok. Let’s give a couple situations when the pilot is not instrument current:

    If in actual instrument conditions:

    The safety pilot must be instrument rated, current AND have a valid medical because he is the ACTING PIC (and can log it)

    If in simulated instrument conditions:

    The “pilot” must meet the PIC requirements (recent, medical, etc.). The safety pilot does not need to have a instrument rating, only be at least a private pilot with appropriate category and class ratings. The safety pilot also does not need to be current because he is serving only as SIC and is only a required crewmember when the “pilot” goes under the hood.

    It can get cloudy. The key to remember is that someone always has to be fully qualified to be PIC.

  3. Jim McCord on Nov 10, 2008


    Although I’ve never heard of the term “safety pilot” used except as you’ve described (i.e. look outside while another pilot is under the hood), I believe that the regulations would allow a “non-current” pilot to do 3 takeoffs and landings, with another qualified pilot, and log that time as PIC per 61.51:

    61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—

    (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

    Of course the other pilot, if not a CFI, would NOT be able to log the time that he or she is not the sole manipulator of the controls as PIC time, even though they would need to be fully qualified to act as PIC (and would be the acting PIC for the flight).

    Since I am also a CFI, I’d support the notion that if you are that rusty that you feel you need to take someone along, you should likely take a CFI along as they have the experience from the right seat to help you improve your proficiency in a safe manner.

  4. instructor on Nov 10, 2008


    I can definitely see your point. And your right, that would not be a “safety pilot” (as defined by the FARs). I actually thought several times about endorsing that position and even now can see both sides of the argument for a qualified current pilot to help a qualified non-current pilot gain recent flight experience.

    It might be worth it for me to email a FSDO and get their take on the issue.


  5. Sylvia on Nov 14, 2008

    I found a reference in Lasors 2006 for the UK CAA that actually mentions this, to my surprise. Section F, under Carriage of Passengers, specifically refers to the 3 take-offs and landings in 90 days and then says:

    A pilot who has not met the experience criteria above will be required to complete the above requirements either as Pilot-in-Command of aeroplanes/helicopters as apppropriate or with a flight instructor, providing that the instuctor does not influence the controls at any time. The carriage of a safety pilot is not permitted to satisfy this requirement.

    So it’s specifically mentioned and done away with in the UK. I think your analysis is correct.

    I think the point is that in Jim’s example, the other pilot is a passenger and thus disqualified from travelling with the out of date pilot.

    And yes, I agree that from a point of view of improving and of safety, an instructor is the better choice. I can look out the window and spot problems but taking control and correcting is a whole ‘nother skill!

  6. Ryan Harvey on Apr 08, 2011

    What about complex ratings? I would like to serve as a safety pilot in a friend’s Columbia 400 while he practices IFR under the hood. I am a private pilot rated for single-engine land airplanes. The Columbia 400 is a single-engine land airplane. However, it is a complex airplane, an endorsement I do not possess.

    I see conflicting answers in the above — the regulations seem to state that I just need to be rated in the “category and class,” but someone commented that “the safety pilot needs to be fully qualified to be PIC.”

    I appreciate the help! I’ve read the FAR/AIM and remain confused.

  7. Fred on Sep 25, 2011

    Don’t feel bad (about knowing the answer). I recently asked the FAA:
    When flying under the hood a “safety pilot” is required.

    1. Does this (safety) pilot have to be current (90 days current)?

    2. Does this (safety) pilot have to have a current medical?

    It’s been nearly two weeks and no answer. Which tells me that they don’t know either (and they write the regs) LOL

  8. Jim on Jun 05, 2012

    On a related issue, may a CFI with a current instructor rating, but an expired medical, sit in the right seat in order for a private pilot to get the 3 takeoffs and landings in the past 90 days required by 61.57? Is the CFI then really a passenger, since the CFI can’t act as PIC, so the private pilot couldn’t take the CFI as a passenger?

  9. Kal on Jun 21, 2012


    I believe that the CFI would be considered invalid with an expired medical, since a CFI would need a third class medical to practice instructor privileges. As you have mentioned he would be considered a passenger.


  10. Kevin on Jul 05, 2012

    Kal, a CFI does not need a current medical to instruct.

  11. Mark Edwards on Sep 21, 2012

    I have to disagree with some of the comments listed here:

    1. To fly in simulated instrument conditions, the flight requires a safety pilot. To be a safety pilot, that person must hold a certificate for the category, class, and if appropriate, type of the aircraft being flown. Since the safety pilot becomes a part of the minimum required flight crew when the other pilot is in simulated conditions, he is exercising the privileges of his pilot certificate. When exercising the privileges of one’s certificate, the pilot must have a current flight review and medical. Since neither pilot is a “passenger” here, the three take offs and landings may not be necessary.

    2. If a pilot is not current to carry passengers (lacks the three landings in 90 days), he can fly with another pilot who is current. The pilot who isn’t current would be the passenger. It is legal for the passenger to take the controls and do three landings. Since the “passenger” is rated for category and class, he may log the flight time and landings when he is the “sole manipulator of the controls”. As such, he may regain his currency with a non-CFI pilot.

    3. Logging PIC time as a safety pilot: If the two pilots agree beforehand that the safety pilot is PIC during the instrument flight, both pilots may log PIC time while the one pilot is under the hood. One is responsible for the safe/legal operation of the flight and the other is the sole manipulator of the controls. If the safety pilot doesn’t want PIC responsibility while someone else is flying, he may choose to not be PIC. As such, he may log SIC time. If he chooses to be PIC, he may be responsible for any violations, such as airspace violations or incursions.

  12. Mark Edwards on Sep 21, 2012

    4. A CFI is not required to have a valid medical to give instruction if the pilot receiving the instruction is fully qualified, current and holds a medical. He may not give instruction to student pilots, or pilots who don’t hold a rating for the category/class being flown.

  13. Captain Bill on Nov 25, 2012

    A safety pilot is a required crew member but can only log SIC, not PIC, no matter what was discussed or agreed upon on the ground. The safety pilot is only required for the portion of the flight that the pilot is “under the hood”.
    A current medical is required for anyone that is part of the required flight crew, including instructor.
    It is true that a medical is not required for a flight instructor when s/he is not PIC, or part of the required flight crew.

    Safety pilot is a passenger during take off and landing as the pilot is NOT under the hood during that phase of flight. Safety pilot does not need to be 90 day current but needs medical.

    Blue Skies,


  14. David Craig on Oct 08, 2013

    I certainly don’t agree that a safety pilot needs a current medical. According to your definition there might as well not be a term “safety pilot” at all…the regs by your standard should just say “when you are under the hood buddy you need another current pilot at the controls.” The intent of the regulation is just to make sure that the person looking out for traffic has some ability to take evasive action and some experience looking out for traffic. That’s it! Some of you guys really get carried away with the rules. Like a pilot isn’t safe to be your watch just because his medical expired yesterday? Are you a nut?

  15. Bert on Feb 24, 2014

    Best explanation I have seen to date on this topic:


  16. Tom on Jun 10, 2016

    Here’s a fairly recent explanation about safety pilot requirements from legal counsel @ AOPA

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