Safety Pilot Logging and Cost Sharing
A practical interpretation of FAA legal opinion on how safety pilots log time and share expenses during simulated instrument flight.
Key Conclusion
A safety pilot can log SIC or PIC depending on role, and is not always required to share expenses.
Why It Matters
Common confusion:
- Safety pilot can always log PIC
- Safety pilot must always split costs
The FAA separates logging rules and expense rules based on roles.
Core Logic
1. Safety pilot is a required crewmember
During simulated instrument flight:
- A safety pilot is required by regulation
👉 This makes the safety pilot a required crewmember
2. When acting as safety pilot only
If Pilot A:
- Is PIC
- Is sole manipulator of controls
Then Pilot B (safety pilot):
👉 Can log SIC only, not PIC
3. When safety pilot acts as PIC
If Pilot B:
- Agrees to act as PIC during simulated instrument
Then:
- Pilot B can log PIC
- Pilot A can also log PIC as sole manipulator
👉 Both can log PIC under different provisions
4. Expense sharing depends on role
Under §61.113:
- A private pilot acting as PIC with passengers must share costs
However:
- During simulated instrument flight
- Both pilots are required crewmembers
👉 No passengers → no cost-sharing requirement
5. Key distinction
- Logging depends on who is PIC vs manipulating controls
- Cost sharing depends on whether passengers are carried
Common Misunderstandings
- ❌ “Safety pilot always logs PIC”
- ❌ “Safety pilot must always pay their share”
👉 Both depend on specific roles during the flight
One-Sentence Summary
A safety pilot’s logging and cost obligations depend on whether they act as PIC and whether passengers are involved.