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Currency And Logging Of Flight Time  
User currently offlineFlightSimFreak From United States of America, joined Oct 2000, 720 posts, RR: 0
Posted (11 years 3 months 3 weeks 6 days 9 hours ago) and read 3310 times:

Let me put a little scenario up: You have a pilot who is being asked to function as safety pilot (FAR 91.109 I believe.) Now, this pilot has his private pilot's license and a current medical, but has not had any flight time in the previous 90 days. Can he act as safety pilot in a plane for which he is rated? (ie: PPL ASEL acting as safety pilot in a 172).

Can the safety pilot log that time as PIC?

Now he has been asked by a pilot of a more complex aircraft: a turbo, retractable 182 (both complex and high performance). He does not have a complex or high performance endorsement. Can he act as safety pilot there?

Can he log that time as PIC?

Thanks.

25 replies: All unread, showing first 25:
 
User currently offlineJBirdAV8r From United States of America, joined Jun 2001, 4491 posts, RR: 21
Reply 1, posted (11 years 3 months 3 weeks 6 days 8 hours ago) and read 3284 times:

Ok, off the top of my head, I hope I get this right.

The short answer: Yes. You can log PIC time as a safety pilot. If you're a safety pilot, and you agree with the "left seat pilot" that YOU are the pilot-in-command (under the definition of being the pilot responsible for the operation and safety of the aircraft), you are Pilot in Command and thus can log the PIC time. The "left seat pilot" though must only log SIC time since the airplane in question (for you I assume) only requires one pilot. You can't both log PIC in a Cessna 172; it's you or the other.

You make the situation a little more complex by throwing the out-of-currency rule in there. Technically, you CAN'T log PIC in your exact scenario until you complete the 3 takeoffs and landings. Your left seat pilot, if you log PIC, is technically a passenger.

Okay, the endorsement deal. To be a safety pilot, you have to be certified in the appropriate category and class of airplane REGARDLESS of endorsements required (i.e. a Cessna 182 is still an Airplane Single Engine Land). However, you can't technically be pilot in command of a high performance airplane and/or a complex airplane until you receive the endorsement from a CFI.

That's the long and short of it. Don't forget: If in doubt, call your local FSDO  Smile/happy/getting dizzy



I got my head checked--by a jumbo jet
User currently offlineFlyf15 From , joined Dec 1969, posts, RR:
Reply 2, posted (11 years 3 months 3 weeks 6 days 5 hours ago) and read 3271 times:

There are two ways in which this whole "under the hood / safety pilot" thing works. They are determined by which pilot is the acting PIC.

According to 91.109(b)(1), the safety pilot is a required crewmember for the flight and must rated at least a private pilot with catagory and class (ASEL). That leads us over to 61.51(e)(1)(iii), which states that a pilot may log PIC time when acting as PIC "on which more than one pilot is required under ... the regulations under which the flight is conducted." (91.109(b)(1)). 61.51(e)(1)(i) states that a pilot may log pilot in command time when he/she is the sole manipulator of the controls for which the pilot is rated.

"Act as PIC" means that the pilot is legally certified and capable of being the pilot in command for the flight. ie: current medical, all appropriate ratings and endorsements, and required currency for the type of flight.

So...in simplified terms:

Situation 1:
Safety pilot chooses to be PIC and may log PIC time for the entire flight. Pilot under the hood may log PIC time for all time he is the sole manipulator of the controls (he's flying the plane) under the hood. Although, in this situation, it must be noted that if no passengers are being carried on the flight (there are only flying pilots aboard), the safety pilot need not meet landing currency per 61.57(a)(1). I personally wouldn't take it this far though, I feel its starting to strech the FARs a little much. And, your safety pilot still cannot act as PIC due to not having the appropriate endoresements

Situation 2:
Pilot under the hood chooses to be PIC and may log PIC time for the entire flight. Safety pilot may log SIC time for the portion of the flight for which the PIC is under the hood (61.51(f)(2)).

But, in your situation, the safety pilot is not capable of acting as PIC and therefore the pilot under the hood must be the PIC for the flight. Thus, situation 2 is the only possible way the flight could be conducted.

I encourage you to look at the FAR Part 61 FAQs on the FAA's website. They're great and loaded with answers to questions just like yours (look at pages 88 and 89 and you'll see).

http://afs600.faa.gov/srchFolder.asp?Category=640OtherFAQ&lev2=DPE

Also, I must write a little disclaimer that this is just my interpretation of the FARs and may not be correct.


User currently offlineRalgha From United States of America, joined Nov 1999, 1614 posts, RR: 6
Reply 3, posted (11 years 3 months 3 weeks 6 days 4 hours ago) and read 3265 times:

I'm assuming you're asking this because you will be involved with the situation presented, or a similar one, in some way. If this is the case, then this is NOT the place to ask such a question. You have 2 options. Call/talk to a flight instructor face to face, or call/go to your local FSDO.


09 F9 11 02 9D 74 E3 5B D8 41 56 C5 63 56 88 C0
User currently offlineM717 From United States of America, joined Dec 2002, 608 posts, RR: 4
Reply 4, posted (11 years 3 months 3 weeks 6 days 4 hours ago) and read 3263 times:

2 suggestions so far to call the FSDO. The FSDO, or any inspector, has no legal authority to interpret the regulations. They will give you their opinion, just as others have done on this thread. Their opinions carry no more weight than the other opinions posted here. In fact, if you were to call 5 FSDOs, you are likely to get 5 answers. None of which are binding.

User currently offlineFlyf15 From , joined Dec 1969, posts, RR:
Reply 5, posted (11 years 3 months 3 weeks 6 days 4 hours ago) and read 3262 times:

My feeling about how you should get your answers about this. Ask people as you have done here, pilots you know, flight instructors, the FSDO, etc. Don't take any nonoffical sources to be the correct answer -- just as advice and guidance. Also, spend some quality time with the FARs and decide how you feel it should be interpreted. Make sure your final decision makes sense and is very clearly within the FARs, so that if you ever have to back it up, you can.

When in doubt, always error to the safe/legal side.

[Edited 2003-05-30 21:07:04]

User currently offlineShaun3000 From United States of America, joined Mar 2002, 445 posts, RR: 0
Reply 6, posted (11 years 3 months 3 weeks 5 days 16 hours ago) and read 3192 times:

The 90 day currency rule only affects your ability to carry passengers. If you are flying with another pilot (and he's not a passenger) then you're fine. Now is it a good idea? Maybe not...

User currently offlineJBirdAV8r From United States of America, joined Jun 2001, 4491 posts, RR: 21
Reply 7, posted (11 years 3 months 3 weeks 5 days 10 hours ago) and read 3179 times:

M717,

The general consensus is that the FSDO guys have a better understanding and interpretation of the FAR's than most pilots...that's why I mentioned them. Some FSDOs have the bad habit of just telling pilots to RTFF (read the F'ing FARs), though.

If you do call the FSDO though, I believe it will be in their records. So should you have a problem (i.e. an inopportune ramp check), you can show that you did call and seek a professional opinion.

My advice to you: If you have to ask such a detailed FAR question, it's better to err on the side of safety and maybe just go without logging this flight.



I got my head checked--by a jumbo jet
User currently offlineJetguy From , joined Dec 1969, posts, RR:
Reply 8, posted (11 years 3 months 3 weeks 5 days 9 hours ago) and read 3178 times:

Calling, better yet writing or e-mailing the FSDO so that you'll have a written record it the least that I'd do. Back when I was a Life Flight pilot I had a couple of coworkers get into a LOT of trouble with the FAA because they relied upon an opinion from our local FSDO and a different FSDO didn't agree. That FSDO pressed the issue and before you knew it licenses were suspended, attorneys were involved - it took tens of 1000s of dollars before the dust settled and my friends were exonerated. Unfortunately, when it come to stuff like this, many FAA inspectors feel that this these are the perfect type of situations for them to justify their existence and their paycheck. M717 hit it spot on - "...The FSDO, or any inspector, has no legal authority to interpret the regulations. They will give you their opinion, just as others have done on this thread. Their opinions carry no more weight than the other opinions posted here. In fact, if you were to call 5 FSDOs, you are likely to get 5 answers. None of which are binding..." True, how very true! A wise man once explained to me that you could ask 5 different FSDOs if the sun normally rose in the east and usually set in the west. You would get 5 different opinions and none of them would be willing to put their opinion in writing.

If I were Alex Archer and wanted to log the time I think I'd simply go rent an airplane for .4 or .5 and get the landings - that way, there's absolutely no question.

This kind of falls under my "2nd Universal Rule of Aviation". What is safe isn't always legal; what is legal isn't always safe. When you start dealing with the FAA, you need to also mention logical.  Innocent

Jetguy


User currently offlineFlightSimFreak From United States of America, joined Oct 2000, 720 posts, RR: 0
Reply 9, posted (11 years 3 months 3 weeks 5 days 9 hours ago) and read 3173 times:

Thanks guys, this has answered my question pretty well. Yes, I am the one in that situation. I do think that I will call the FSDO, and look on the FAA site just to be sure though. Thanks again.

User currently offlineRalgha From United States of America, joined Nov 1999, 1614 posts, RR: 6
Reply 10, posted (11 years 3 months 3 weeks 5 days 6 hours ago) and read 3148 times:

I agree completely that FSDO just gives their interpretation of the FARs, but my point is that here, you have no idea whether I or anyone elses is who we say we are. I could be a raving lunatic who runs around town with a chainsaw at night and gets off by telling other people how to kill themselves while making them think that I'm giving them good advice.

On the chance that you do get in trouble with the FAA for something, what's going to have the better chance? Records that you called a FSDO or two and at least tried to get it right? Or some post and respose on a random internet board? Sure the FSDO route may turn out to bite you also, but it's a much better risk than here.

 Big thumbs up



09 F9 11 02 9D 74 E3 5B D8 41 56 C5 63 56 88 C0
User currently offlineB747skipper From , joined Dec 1969, posts, RR:
Reply 11, posted (11 years 3 months 3 weeks 5 days 5 hours ago) and read 3143 times:

Be aware that pilots working with airlines dont even "log" the time they fly, other than for pay purpose, and the way we get paid, deadheading somewhere (in the first class cabin and a bottle of wine), I am paid (I "log") half of the time on that flight... my "log book" is pages of my "salary sheet"...
xxx
Flown also on "double crews"... 2 captains, 2 first officers, 2 engineers, well there, two keep the plane going, everyone logs "all the time" spent in the air, couple of years ago, we flew the Argentina soccer team to Japan... we only stopped at LAX for short refueling, one crew flew, the other slept...
xxx
Ask me "how many hours you got...? - Honest, I dont know... I assume that my average flying is some 700 - 800 hours a year... I had over 2,000 hours joining PanAm in 1969... 34 years ago... give or take 5,000 on total time, must be over 25,000 hours, wild guess...
xxx
A close friend of mine, Clay Lacy (ex UAL, and owner of a executive jet operation in Van Nuys, California, is estimated having 45,000+ hours logged).
xxx
(s) Skipper


User currently offlineJetguy From , joined Dec 1969, posts, RR:
Reply 12, posted (11 years 3 months 3 weeks 5 days 5 hours ago) and read 3146 times:

Ralga...
You're absolutely correct. My point is to just make sure that you have something in writing from them showing that you've made a good faith effort to do things right. Otherwise it's your word against theirs and you would have absolutely no defense. Even that won't always protect you (my buddies at Life Flight will testify to that) but it's better than nothing. Like I said in my post, under circumstances like this, the smart thing to do would simply to go rent an airplane for .4 or .5 and get the landings - that way, there's absolutely no question. Besides, if you're not current don't you want to be?

Jetguy


User currently offlineM717 From United States of America, joined Dec 2002, 608 posts, RR: 4
Reply 13, posted (11 years 3 months 3 weeks 5 days 5 hours ago) and read 3133 times:

Some of us "airline pilots" with 10s of thousands of hours do log our time. I have a very nice computer program that does it for me. It imports my schedule directly from my airline, and keeps track of all flight time, all conditions of flight, deadhead time, pay, legalities, etc., plus I can go in and extract whatever report I choose. I can ask it to give me totals in any combination, or one specific aircraft or type of operation. I too, have flown with augmented crews, and I can tell you time aloft, as well as time in seat. It's all very simple, and kept on computer. On top of that, it prints nice paper printouts in the typical logbook style, which I keep in plastic sheets, and file in a binder.

User currently offlineFlightSimFreak From United States of America, joined Oct 2000, 720 posts, RR: 0
Reply 14, posted (11 years 3 months 2 weeks 6 days 17 hours ago) and read 3052 times:

I've decided that I am just going to go get current... I have some friends that I want to go take flying. It is still an interesting question and I would still like to know the answer.

Thanks


User currently offlinePPGMD From United States of America, joined Sep 2001, 2453 posts, RR: 0
Reply 15, posted (11 years 3 months 2 weeks 6 days 15 hours ago) and read 3047 times:

Just noticed this thread.

Logging time: You can log what ever you want, all you need is a pen.  Big grin

But logging SIC command in an aircraft that doesn't require SIC accord to it's type certificate is a real stretch of 61.51, and I highly doubt that most airlines would favorably of the time. But also 61.55 says that the SIC must be current too.




At worst, you screw up and die.
User currently offlineM717 From United States of America, joined Dec 2002, 608 posts, RR: 4
Reply 16, posted (11 years 3 months 2 weeks 6 days 8 hours ago) and read 3035 times:

"But also 61.55 says that the SIC must be current too."

If you read all of 61.55, paragraph (d)(4) says that this does not apply to a person who is designated as a safety pilot for purposes required under FAR 91.109; which is what this thread is about.

Also, you mention logging SIC time in an aircraft that doesn't require an SIC according to the type certificate is a stretch of 61.51. Again, if you read it all, 61.51(f)(1) says "... in an aircraft that requires more than one pilot by the aircraft type certificate. AND (2) "...or the regulations under which the flight is being conducted.



User currently offlineJhooper From United States of America, joined Dec 2001, 6204 posts, RR: 12
Reply 17, posted (11 years 3 months 2 weeks 6 days 8 hours ago) and read 3028 times:

Flyf15,
You nailed it best. You are exactly correct as far as I understand. Yes, definitely read the FAR 61/141 FAQs, while this is not a "legal interpretation" whatever that means, it's the interpretation of the folks who wrote the regs.

To reiterate what you said, both pilots can log PIC if certain conditions are met. The left-seat pilot can log pic because he's the sole manipulator of the flight controls, and the right-seat pilot can log PIC if he agrees to "serve as PIC" and is current and qualified to act as PIC (including complex endorsements if necessary).

Note that this is one of very few ways that two pilots in a C172 can log PIC at the same time. Another example would be a private pilot flying the aircraft under the supervision of a CFI. Interestingly enough, it's possible to serve as PIC without being allowed to log PIC time. It's not logical, IMO, but that's the way it is.

JBirdAV8r,
You are incorrect as far as the FAA regulations are concerned. However I realize there is much confusion in this area, especially since the airlines like to count PIC time differently than the FAA. Many airlines don't like to see PIC in your logbook unless your're "da man", but the FAA allows you to log PIC under conditions where you aren't necessarily the pilot in command.

B747Skipper,
What your airline allows you to log for "pay purposes" is completely different from what the FAA requires as a legal record. The FAA requires pilots to keep at least the following in a logbook or reliable record:
1. Experience required to apply for a new certificate or rating
2. Takeoff, landing, and instrument currency
Of course, you're outside the jurisdiction of the FAA, so I don't know what your civil aviation authority requires. Is it standardized with FAA requirements?



Last year 1,944 New Yorkers saw something and said something.
User currently offlinePPGMD From United States of America, joined Sep 2001, 2453 posts, RR: 0
Reply 18, posted (11 years 3 months 2 weeks 6 days 7 hours ago) and read 3019 times:

M717,

But the moment you take over and become the sole manipulator of the controls (also known as PIC) your guy under the hood is a passenger and thus you are busting currency.

I am fully aware of 61.51(f)(2), but like I said logging SIC as a safety pilot is a real stretch of 61.51, that was mostly put in there to allow SIC, of aircraft that don't require it, under Part 121 and 135 to be able to log it. Try explaining that to the airline that you are applying too.

"So umm how do you have 100hrs flying SIC in a C172RG?"



At worst, you screw up and die.
User currently offlineB747skipper From , joined Dec 1969, posts, RR:
Reply 19, posted (11 years 3 months 2 weeks 6 days 7 hours ago) and read 3023 times:

Dear Jhooper -
xxx
Obviously, hours you fly, to qualify for the CPL, and later ATPL, or CFI should be kept accurately, also instruction records...
xxx
Agree about currency as well, 3 landings - 90 days FAA, or instrument time, but actually, if you fly for an airline, they keep that for you... My schedulers keep me "current" - and since I no longer maintain a "log book" up-to-date, should anyone ask, I say "it is company records"...
xxx
As you may know, I volunteer "as instructor" at the Aero Club and use my little L-21, for that activity... I also maintain an aircraft log book where everyone who flies the aircraft has to sign the time flown, for the 100 hours or 30 days inspection... If I sign and certify some trainee in HIS log book, that entry and my signature is an official record of my activity as a CFI. My activities as instructor in simulators or on the line with the airline, are all matter of company official records...
xxx
There is a lot of "abuse" in the USA as far as logging time, and certification. As an example, with the Argentina administration, a student pilot requiring cross country experience must obtain a stamp (seal) and signature from an official at every airport he lands for that cross country flight in his log book. Parker time is not known down here, no way to log if not certificated...
xxx
When Argentines go to the USA to get their training and licenses, they sometimes ask the FBO they land at, for a stamp, and a signature in their log book (some of these FBO individuals hate to "sign" anything, they believe maybe a "law suit" against them is in the mind of that pilot...) - Hell NO... that pilot tries to comply with Argentina requirements to prove or witness his flights.
xxx
Happy contrails  Smile
(s) Skipper


User currently offlineM717 From United States of America, joined Dec 2002, 608 posts, RR: 4
Reply 20, posted (11 years 3 months 2 weeks 6 days 5 hours ago) and read 3006 times:

" I am fully aware of 61.51(f)(2), but like I said logging SIC as a safety pilot is a real stretch of 61.51."

Maybe. But that is specifically why there is 61.55(d)(4). It deals exclusively with the safety pilot required under 91.109 as SIC. I would doubt that any airline cares about SIC time logged as safety pilot. Most look for a certain amount of PIC time, turbine time, prior 121/135 etc. None of the airlines that I have worked for during the past 25 years really cared at all about my SIC time.

As far as the currency issue goes, I believe it was established that in the scenario posed in the beginning of this thread, the pilot in question could not act as safety pilot nor log it as PIC since he was not current.


User currently offlineJhooper From United States of America, joined Dec 2001, 6204 posts, RR: 12
Reply 21, posted (11 years 3 months 2 weeks 6 days 3 hours ago) and read 2994 times:

A noncurrent pilot may act as safety pilot, but may not serve as PIC. In the case of the safety pilot being noncurrent for PIC, he would log the time as SIC.

But the moment you take over and become the sole manipulator of the controls (also known as PIC) your guy under the hood is a passenger and thus you are busting currency.


PPGMD ,

If I'm reading your comment correctly, you're not making the distinction between ACTING as PIC and LOGGING PIC time; they are two totally different things. If the safety pilot is handling the controls (and therefore logging PIC because he's the sole manipulator) while there is a pilot under the hood, the safety pilot is NOT REQUIRED to be current IF he is not ACTING as PIC (in this case, the person under the hood is ACTING as PIC). Even though the pilot under the hood is the official PIC (under Part 1), he can not LOG PIC because he is not the sole manipulator of the controls (although I have to admit this is about the dumbest regulation there is). HOWEVER, you will run into trouble acting as safety pilot if you're not current AND the pilot under the hood is not otherwise qualified to ACT as PIC. SOMEBODY has to be PIC current and must be qualified to be PIC. I know this is a very confusing area of the regulations, and many people don't understand this distinction between ACTING as PIC and LOGGING PIC time.



Last year 1,944 New Yorkers saw something and said something.
User currently offlineKAUSpilot From United States of America, joined Jan 2002, 1959 posts, RR: 32
Reply 22, posted (11 years 3 months 2 weeks 6 days 2 hours ago) and read 2983 times:

On my student pilot cross countries I also got people at each airport to sign my logbook. I don't know if this is FAR required or not but my CFI at the time told me to do it, and it was no problem at all the airports I stopped at here in the US of A.

User currently offlineJhooper From United States of America, joined Dec 2001, 6204 posts, RR: 12
Reply 23, posted (11 years 3 months 2 weeks 6 days 1 hour ago) and read 2981 times:

That's a neat idea. I should have my students do that as well. When I did my solo cross countries, I just took pictures to prove I was there.


Last year 1,944 New Yorkers saw something and said something.
User currently offlinePPGMD From United States of America, joined Sep 2001, 2453 posts, RR: 0
Reply 24, posted (11 years 3 months 2 weeks 5 days 22 hours ago) and read 2971 times:

Actually there are some in the FAA that say that the safety pilot is the acting PIC during the entire flight. But he can't log it unless he is the sole manipulator of the controls. Thats what I hate about the FARs it's all about interpretation.

Personally I like the military way of logging time (when converted to civilian time). The aircraft commander is always PIC. He could be in the back in using the head, he is still PIC. 1st pilot and 2nd pilot are both SIC unless one of them is the aircraft commander. It's simple to the point, and you always know who's should be logging what, and when.



At worst, you screw up and die.
User currently offlineJhooper From United States of America, joined Dec 2001, 6204 posts, RR: 12
Reply 25, posted (11 years 3 months 2 weeks 4 days 2 hours ago) and read 2943 times:

PPGMD ,

I agree with you that the military way makes far more sense. But you are incorrect when you say that the safety pilot can't log the time as PIC. The safety pilot can log this as PIC if he is serving as the PIC and he is totally qualified to act as PIC (landing currency, etc.). See FAR 61.51(e)(1)(iii), which appears below:

--------------------------------------------------------------
(e) Logging pilot-in-command flight time. (1) A 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;

(ii) Is the sole occupant of the aircraft; or

(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

------------------------------------------------------------



Last year 1,944 New Yorkers saw something and said something.
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