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The safety pilot situation poses a different problem. Again the flying pilot is easy. He's the one flying the airplane.
But the safety pilot? You didn't say so, but I'll assume that the flying pilot is under the hood. If the flying pilot is not under the hood, the safety pilot isn't required and gets to log squat.
If the flying pilot is under the hood, I think the answer is "yes." if the safety pilot is also acting as PIC fore the flight, she may log actual. Here's why I think so: Back to the basic rule:
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61.51 (g) Logging instrument flight time.
(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.
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Notice the lack of "sole manipulator" language. Instead you have the more nebulous term "operate" (look at the definition in FAR Part 1). But in the context of pilots, the word usually means having some degree of what FAA Legal has called "operational control" over the flight. There are even FAA Legal opinions that tell us that a non-flying SIC in a two-pilot-required crew is "operating" the airplane. As PIC under IMC, the safety pilot is operating the aircraft even if she doesn't manipulate the controls. So she may log the actual time even though (strange as it may seem) she can't log it as 61.51 PIC time.
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Let's play with this scenario for a second, Mark (i.e. the flying pilot (FP) (sole manipulator) is under the hood in IMC on an IFR flight plan filed by the instrument rated safety pilot (acting PIC) in the right seat).
In this case, the FP (being under the hood) logs simulated instrument time, irrespective of what the conditions are outside the airplane. Now, using your arguments above, the instrument-rated/current safety pilot logs actual instrument time. That part is a little "funny" considering the FP logs simulated during the same time the safety pilot logs actual. (I don't want to get into the career develop vs. logging debate).
That being said, you mentioned in the last sentence that the safety pilot (acting PIC) logs actual but can not log 61.51 PIC time. That part perplexes me--here's why: if the FP is under the hood, then we know that the regs require the safety pilot. Because the regs require her and we know she is "acting PIC" (we're on an IFR flight plan), then I can't see why she can log the 61.51 PIC time. Mark, can you explain how the FP can log simulated instrument time while the safety pilot, who is acting PIC, can not log 61.51 PIC.
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Where did you come up with logging simulated in actual conditions? There's a big difference between wearing a hood in VMC, and wearing a hood inside a cloud. VMC you can pull off the hood and suddenly fly by looking outside again. In a cloud, you don't have that option. There's nothing simulated about it hood or not.
Similarly, wearing a hood in VMC, you can still see outside. You can see the ground, sky, get a sense of motion, small items, but make a big difference. Wearing a hood in a cloud removes those small cues. Again, not simulated, hooded or not.
When the airplane is in the clouds, the safety pilot is not a required crewmember, therefore can't log anything. Check out the relevant reg:
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§ 91.109(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.
(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and
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First off it's not simulated, cause you're SOL if you can't hack it. Secondly, if you do consider it simulated flight, then you're doing it illegally because the safety pilot doesn't have adequate vision according to (2).
