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121 IFR currency valid for 91 flying?

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Commercial Pilot, FAA Regulations, Instrument Rating

I'm a 121 first officer (SIC only) and was curious if my 121 training makes me IFR current for my recreational 91 flying. If so, how do I show that currency. 

I do understand that an approach is an approach no matter what plane I'm in, however it is possible to go 6 months without shooting 6 instrument approaches, holding, and intercepting and tracking of courses and radials in the 121 enviornment. For this exact reason all airline pilots enter recurrent training every 6 months where all of these requirements are fulfilled. 

This is where my question comes in (and why i emphasize 121 training). My airline (American Eagle) does not fill out log books for our initial or reccurent training. So in some cases there is no personal record of my 'instrument currency' if I needed to show currency for part 91. All I could say is I'm an airline pilot.

How would I show that I am IFR current for 91 purposes? Should I just log the approaches, holding, etc. that I do in the sim during my reccurent training? I am aware of the exemption in paragraph (e), but that is specifically for 121, 135 etc. not 91.

Thank you for your help!


3 Answers

  1. Nathan Parker on Feb 10, 2012

    <<How would I show that I am IFR current for 91 purposes? Should I just log the approaches, holding, etc. that I do in the sim during my reccurent training?>>
    In the very unlikely event you would ever have to demonstrate currency, the training record maintained by your airline would probably satisfy the requirements, assuming they record the particulars.  The FAA doesn’t really have a definition of a “logbook”.  If they don’t maintain any other record besides saying you completed the training, you could maintain your own logbook with the details, but you’d need someone to sign it, per 61.51(g)(4).

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  2. John D. Collins on Feb 11, 2012

    You have the responsibility to log the simulator time for the purposes of maintaining currency, not the airline.  As Nathan indicated, you make the log entry and get it signed by the person conducting the recurrent training. The simulator must be of the same category of aircraft, which would be “Airplane” in your case, so your simulator time could not be used for recurrency in a Helicopter. Emphasis is mine, see FAR 61.57 (c) (2) below:
    (2) Use of a flight simulator or flight training device for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in a flight simulator or flight training device, provided the flight simulator or flight training device represents the category of aircraft for the instrument rating privileges to be maintained and involves having performed the following–

    (i) Six instrument approaches.

    (ii) Holding procedures and tasks.
    (iii) Intercepting and tracking courses through the use of navigational electronic systems.

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  3. Stephen Wolpin on Feb 15, 2012

    seems if your approaches are part 121, you are pic and just need to log them to be current under part 91, no?  As long as you have your six you’re ok — no?

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