Safety Pilot Logging Explained: What You Can Log and Why 

Safety pilot time is one of those logbook topics that sounds simple until you actually try to fill out the logbook. Most pilots have heard that both pilots can log PIC time while one pilot is under the hood. That can be true, but it leaves out several details that matter. 

Both pilots cannot act as pilot in command at the same time. The safety pilot cannot automatically log the entire flight. The safety pilot also cannot copy the cross-country, simulated instrument, or approach entries from the pilot flying. Even though both pilots are sitting in the same airplane, their logbooks may look completely different when the flight is over. 

I think the easiest way to understand safety pilot time is to treat every column in the logbook separately. PIC, SIC, cross-country, simulated instrument, and instrument approaches all have their own requirements. Qualifying for one column does not automatically qualify you for another. 

What Makes Someone a Safety Pilot? 

When a pilot flies under a view-limiting device (typically foggles or a “hood”), that pilot cannot adequately see outside the airplane. Another pilot is therefore required to watch for traffic and help maintain the required outside visibility. That second pilot is the safety pilot. 

For the typical flight, the safety pilot must hold at least a private pilot certificate with the category and class ratings appropriate to the aircraft. The safety pilot must be seated at a control station with adequate vision forward and to each side, unless a competent observer supplements that view. The airplane must also have fully functioning dual controls unless it qualifies for the regulation's limited exception for certain throwover control wheels (14 C.F.R. § 91.109(c)). 

The important part for logging is that the safety pilot becomes a required pilot flight crewmember while the other pilot is operating under simulated instrument conditions. That requirement creates a legal way for the safety pilot to log flight time. 

However, the safety pilot is only required while the other pilot's vision is restricted. If the hood comes off and the airplane normally requires only one pilot, the second pilot is no longer a required crewmember. Sitting in the other seat and continuing to watch for traffic does not make the rest of the flight loggable. 

There is also a narrow exception in the current regulation involving certain flight instructors with a sport pilot rating who are providing training for a solo cross-country endorsement. That is not the normal safety pilot arrangement discussed in this article, but you can find it in the current rule (14 C.F.R. § 91.109(c)(1)(ii)). 

Acting as PIC and Logging PIC Are Not the Same Thing 

This is where most of the confusion begins. (Please read carefully) 

The acting PIC is the person who has final authority and responsibility for the flight. That person has been designated as PIC and must hold the appropriate category, class, and type rating when one is required (14 C.F.R. § 1.1, definition of “pilot in command”). The acting PIC is also directly responsible for the operation of the aircraft (14 C.F.R. § 91.3(a)). 

Only one person can fill that role at a time. 

Logging PIC time is different because the FAA provides more than one way to qualify for a PIC entry. A properly rated pilot may log PIC while acting as the sole manipulator of the controls (14 C.F.R. § 61.51(e)(1)(i)). A pilot other than a sport or recreational pilot may also log PIC while acting as PIC of an aircraft that requires more than one pilot under its type certificate or the regulations governing the flight (14 C.F.R. § 61.51(e)(1)(iii)). 

Those are two separate reasons to make a PIC entry. The pilot under the hood may log PIC as the sole manipulator of the controls. At the same time, the safety pilot may log PIC because the safety pilot is acting as PIC during a portion of the flight that legally requires two pilots. 

This does not mean they are both in command of the airplane. It means each pilot has a different legal reason for logging PIC. The FAA explains this distinction in the Hicks Legal Interpretation. Two pilots cannot act as PIC at the same time, but they may log PIC at the same time when each pilot meets a separate logging provision. 

Before the flight, both pilots need to agree on who will actually act as PIC. The person accepting that role is also accepting responsibility for the operation and safety of the flight. 

What Can Each Pilot Log? 

The pilot under the hood may log PIC while serving as the sole manipulator of the controls, as long as that pilot is properly rated for the aircraft (14 C.F.R. § 61.51(e)(1)(i)). This is true even when the safety pilot has agreed to act as PIC. 

The pilot under the hood may also log simulated instrument time, but only for the time spent operating the aircraft solely by reference to instruments (14 C.F.R. § 61.51(g)(1)). If the total flight is 1.6 hours but the hood is only worn for 1.3 hours, the simulated instrument entry is 1.3. The remaining time does not become simulated instrument time just because a safety pilot was on board. 

When an instrument approach is logged for recent instrument experience, the pilot must record the location and type of approach. The logbook must also identify the safety pilot when one is required (14 C.F.R. §§ 61.51(b)(1)(v) and 61.51(g)(3)). 

The safety pilot has two possible ways to log the required portion of the flight. 

If the safety pilot is acting as PIC, the safety pilot may log PIC while the other pilot is under the hood (14 C.F.R. § 61.51(e)(1)(iii); 14 C.F.R. § 91.109(c)). If someone else is acting as PIC, the appropriately rated safety pilot may generally log SIC instead because the safety pilot is still a required crewmember (14 C.F.R. § 61.51(f)(2)). 

The safety pilot should log PIC or SIC based on the role actually performed. The same time should not be entered in both columns. 

One thing I would make very clear before the flight is that agreeing to act as PIC comes with real qualification requirements. The acting PIC must hold the proper ratings and endorsements and meet the applicable flight review, medical, and recent-experience requirements (14 C.F.R. §§ 61.3, 61.23, 61.31, 61.56, and 61.57). If the flight is operated under IFR or in weather below VFR minimums, the acting PIC must also be instrument rated and meet the applicable instrument recency requirements (14 C.F.R. §§ 61.3(e) and 61.57(c)). 

The safety pilot cannot log simulated instrument time. That time belongs to the person who is actually operating the aircraft solely by reference to instruments. The safety pilot is looking outside, which is the exact opposite of what is required to log instrument time (14 C.F.R. § 61.51(g)(1)). 

The safety pilot also cannot log an instrument approach just for watching someone else fly it. Having your name written in the other pilot's logbook does not give you credit for that approach (14 C.F.R. § 61.51(g)(3)). 

Actual instrument conditions do not automatically create safety pilot time either. The safety-pilot requirement applies when another pilot is operating in simulated instrument flight. If the airplane normally requires only one pilot, a second pilot does not gain loggable time merely by monitoring a flight in actual instrument conditions. That pilot would need a different legal basis for logging the time. 

Why the Safety Pilot Cannot Log Cross-Country Time 

This is where pilots often make the wrong connection. They see legal PIC time in the safety pilot's logbook and assume the same time can go in the cross-country column. It cannot. 

Cross-country time has its own definition. In general, the flight must include a landing somewhere other than the departure point and involve the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or another navigation system to reach that landing point (14 C.F.R. § 61.1(b), definition of “cross-country time,” paragraph (i)). 

When the time is used toward a private pilot certificate, commercial pilot certificate, or instrument rating, the flight generally must include a landing more than 50 nautical miles straight-line distance from the original point of departure (14 C.F.R. § 61.1(b), definition of “cross-country time,” paragraph (ii)). 

The distance is not what prevents the safety pilot from logging cross-country. The problem is that the safety pilot is only required during the simulated instrument portion. The safety pilot is not performing a required crewmember role for the complete flight, including the takeoff, en route flight, and landing. 

The FAA addressed this exact issue in the Gebhart Legal Interpretation. The FAA concluded that a safety pilot who is only a required crewmember for part of the flight cannot log cross-country time for that flight. This remains true even when the safety pilot acts as PIC and legally logs PIC during the hood portion. 

This is especially important for pilots building time toward an instrument rating. The instrument-airplane rating requires 50 hours of cross-country flight time as PIC, including 10 hours in an airplane (14 C.F.R. § 61.65(d)(1)). Safety-pilot PIC time does not meet the cross-country portion of that requirement. 

The Gebhart Example 

The example used in the Gebhart letter makes this much easier to see. 

Pilot A and Pilot B fly between airports that are 187 nautical miles apart. Pilot A operates the controls for the entire 2.2-hour flight and spends 2.0 hours under simulated instrument conditions. Pilot B acts as PIC and serves as the required safety pilot during those 2.0 hours. 

Their logbooks would look like this: 

Pilot A may log the full 2.2 hours as PIC because Pilot A was the sole manipulator of the controls. Pilot A may also log the qualifying cross-country flight and the simulated instrument time actually flown. 

Pilot B may log 2.0 hours of PIC because Pilot B acted as PIC while serving as a required crewmember. Pilot B cannot log the other 0.2 because a safety pilot was not required during that part of the flight. Most importantly, Pilot B cannot log cross-country time. Acting as PIC during the hood portion does not turn that partial crewmember time into a complete cross-country flight. 

If Pilot B had served as the safety pilot without acting as PIC, Pilot B would not log PIC. Pilot B could generally log the 2.0 hours as SIC if the requirements of the SIC logging rule were met (14 C.F.R. § 61.51(f)(2)). 

The Gebhart letter was issued in 2009 and refers to the safety-pilot requirement as § 91.109(b). The same requirement is located in § 91.109(c) in the current regulation (14 C.F.R. § 91.109(c)). The paragraph number changed, but the FAA's conclusion about cross-country time did not. 

Decide Before You Fly 

Before starting a safety-pilot flight, both pilots should know exactly what their roles will be. I would want both pilots to answer these questions before starting the airplane: 

The two logbooks do not have to match in every column. In most cases, they should not match. They should simply tell the same story. 

The pilot flying might record the actual hood time and write, “Simulated instrument. Safety pilot: [name].” The safety pilot might write, “Safety pilot, acting PIC,” and record PIC under the applicable rules (14 C.F.R. §§ 91.109(c) and 61.51(e)(1)(iii)). If the safety pilot was not acting as PIC, the entry may instead show SIC under the SIC logging rule (14 C.F.R. § 61.51(f)(2)). 

Final Thought 

A safety pilot is not simply a second person who gets to copy time from the pilot flying. The safety pilot can log time because the regulations make that pilot a required crewmember during simulated instrument flight. Whether that time is logged as PIC or SIC depends on who is acting as PIC. 

That time does not automatically qualify as cross-country, simulated instrument, or an instrument approach. Every column has a separate requirement. If you cannot explain which regulation allows a particular entry, take the time to look it up before putting it in your logbook. 

The regulations linked in this article were reviewed in August 2026. Always check the current eCFR before relying on a citation.