Safety Pilots


Well-Known Member
So a buddy (and fellow CFII) dropped this one on me today, and after discussing...nay...arguing it for about 20 minutes, I figured I'd better get a 2nd (or 48th) opinion.


Pilot is rated and 90-day current in the airplane on a VFR flight, and is looking to shoot a practice approach to prolong already present IFR currency. Does the safety pilot need 90-day (i.e. passenger-carrying) currency if there are people in the back seats?

I'm leaning towards yes, since shared PIC authority, etc. and it's never a bad idea to have the safety pilot be passenger carrying current. My buddy couldn't refute it, but I also couldn't find anything specific in the regs to back myself up.


Pilot Hopeful

Well-Known Member
The answer depends on who is acting as PIC.

Per 14 CFR 91.109(c)(1): "No person may operate a civil aircraft in simulated instrument flight unless 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." There is no requirement that the safety pilot be current in or familiar with the aircraft, provided that the other (flying) pilot is acting as PIC; see 14 CFR 61.55 (b) and (f).

Now, if both pilots are logging PIC legitimately (i.e., the safety pilot is acting PIC and the flying pilot is sole manipulator of the controls), then, yes, the safety pilot must be qualified and current for the operation. In that case, the safety pilot as acting PIC must comply with the recency requirements of 14 CFR 61.57.


Well-Known Member
Helpful is absolutely correct. There is no such thing as "shared PIC authority." Maybe that's why you couldn't find it. At any given time there is only one person who has ultimate authority over the flight.

Assuming both are qualified (and that may not solely be an FAA issue), the pilots may decide who is acting as PIC. If the flying pilot is acting as PIC the safety pilot is an SIC when the hood is on. But when the hood is off, the safety pilot is a passenger and the PIC needs landing currency.

If the safety pilot is PIC then, the flying pilot (even though he can log PIC time as sole manipulator) is a passenger who is flying the airplane and the safety pilot needs landing currency.

That said, there is no formal interpretation on whether two pilots may share a flight without the PIC being landing current. The answer might be s surprise. I was certainly surprised when the FAA ended up saying that neither pilot (even student pilot) nor CFI needs to be landing current for an instructional flight.