Logging Hood Time with a Safety Pilot

Hello all,

Apologies if this should be in a different forum…

I am working on my instrument rating and have an opportunity to go flying with a friend in the same make/model Cirrus I am training in. I am going to fly the return leg which is roughly 100nm under the hood with him as safety pilot. Three questions.

  1. HOW do I properly log this in my Jeppesen paper logbook? There is no clear section to put the safety pilots name. Just write it someone on that line?
  2. Can I log the leg I fly as X-Country since it is over 50nm?
  3. Who and what portion does each person get to log PIC? Does the safety pilot get to log PIC time while I am under the hood?
    Thank you all!


  1. Just put the safety pilot name anywhere on the flight entry.

  2. Yes you can log it as cross country.

  3. Each person gets to log PIC. You as the sole manipulator of the controls and the safety pilot as a required crew member.

If you are not a member, this is the only Forum you can post in anyway so don’t worry about it.

On the line for remarks put the name of the safety pilot and his certificate number. Log the time as simulated instrument time.


You can log all the time you are manipulating the controls assuming you are rated in the type of airplane being flown (e.g. airplane, single engine land).

There is a distinction between logging PIC time (FAR 61.51) and ACTING as PIC

The safety pilot must be certificated and can log PIC time for the time you are wearing the hood because he is a required crew member and is responsible for the safety of the flight when you are under the hood. He can therefore designated as the ACTING pilot in command for that time. If you were in IMC or on an Instrument Flight Plan then the safety pilot would need to be instrument rated and current and be PIC for the entire flight, although you still could log whatever time you were the sole manipulator of the controls. Note that your insurance company might have specific requirements for PIC so be sure the safety pilot meets them. And pay attention to whether the safety pilot has an FAA medical or is flying under Basic Med. If it’s basic med then the safety pilot MUST act as PIC for the flight because he is not qualified to be a secondary crew member (I know it doesn’t make sense, but that’s the FAA)

only the person that LANDS the airplane can log the cross country.

Could you point to FAA regulations or interpretations that say that? I have never seen a requirement related only to landings.

The two FAA interpretations listed below discuss multiple scenarios where Pilot A acts as PIC in simulated instrument conditions and pilot B acts as safety pilot and goes on saying that pilot B may not log cross-country flight. But this is not directly related to landings. This is because (according to FAA) the 61.65(d) says that only the pilot conducting the entire flight, including takeoff , landing and enroute, as a required crewmember may log cross-country time.

Also note that your friend must have a high performance endorsement for him to log the flight as PIC (assuming > 200hp Cirrus). If he does not have this endorsement, it is still legal for him to be a safety pilot, but he may only log the flight as SIC.

That is the way an instructor described it to me… I could have misunderstood his exact reasoning, but he told me both pilots can log PIC but only one can log as cross country. Perhaps it’s the take-off, not the landing.

Your instructor was right about PIC, but the answer about cross-country is more nuanced as I described above. Takeoff and landings don’t matter.

Hey Zacharie,
I hope these answers have convinced you of the wealth of knowledge hidden in COPA. You are welcome to become one of us.

Doesn’t necessarily have to be 50 miles. You could fly a trip to an airport 10 miles away and it could legally be logged as cross-country time. FAR 61.1(b)(i) states that a flight that includes a landing at a point other than the point of departure is a cross-country flight.

However, the definition of cross-country flight with respect to qualifying for a certificate or rating can be more specific. For a Sport Pilot certificate, cross-country flight time must include a landing at least a straight line distance of more than 25 nautical miles from the original point of departure. For Private and Commercial Pilot certificates or an instrument rating, cross-county flights are deemed to be 50 miles. Both of these must include a landing at an airport qualifying for the corresponding distance.

Cross county flights that qualify towards an ATP certificate also must be 50 miles but do not have to include a landing at an airport at that distance. [FAR 61.1(b)(vi).] Note that this conflicts with the FAR 61.1(b)(i) definition!

So the answer to the question about what constitutes a cross country flight is: “It depends.”

There is a little trickiness here.

The sole manipulator of the controls always gets to log PIC if he or she is rated for the aircraft.

In IMC, the safety pilot is no longer required, so the right-seater is no longer a required flight crewmember. This means even if the person is acting as PIC from the right seat for whatever reason, he or she can not log PIC time while in IMC unless:

  • The right-seater is sole manipulator of the controls,
  • The right-seater is an instructor, or
  • The aircraft requires more than one crewmember.
    As soon as the flight enters VMC, the right-seater acting as PIC is now a required flight crewmember as safety pilot and can start logging PIC time again.

I thought that was the answer to pretty much every question in aviation.


While disagreeing with you is always a risky proposition, I disagree with you here.

Your analysis is correct provided the left seat pilot is instrument rated and current. But if he is not, then the “safety pilot” must be legally able to act as PIC under IFR and can therefore log the time as PIC even if he is not manipulating the controls.

The real question in the Cirrus is whether the autopilot can log PIC time.[;)]

Ah, Master Yoda, Obi Wan disagrees.

The only non-commercial, non-instruction language in the regs that say you can log PIC time when acting as PIC is the following [bold emphasis mine]:

14 CFR 61.41 (e)(1)(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted;

More than one pilot is not required in a Cirrus, however, more than one pilot is required under the regulations when flying in simulated instrument conditions (i.e., with a safety pilot), but you can only be operating in simulated instrument conditions in VMC, otherwise you are operating in actual instrument conditions.

I refer you to the Walker (2011) Legal Interpretation from the FAA Office of Legal Council.

It seems like most our autopilots are de-rated rather than rated, so at best we should treat them like Student Pilots.


Well Peter, as I said, it’s always a gutsy move to disagree with you. Once again you’ve proven to be the master. I’m always humble in your presence (I really mean that too).

What’s interesting in the FAA letter is that they fully agree that the instrument rated pilot is, in fact, the Pilot in Command for the flight even though he never touches the controls, but deny him the right to log the time as such.

So the actual PIC can’t log PIC time. That’s the FAA for you.

And it’s a moving target. Years ago, it would have been possible for 3 people to legally log PIC time in a Cirrus. That would be the pilot manipulating the controls, a CFI giving instruction, and an ATP who was designated as PIC for the flight who curled up and took a nap in the back seat. However, that third option went away when they changed it in 1997 so that the ATP can only log PIC time when acting as pilot in command if the operation requires an ATP.

Regarding the safety pilot logging PIC, this document written by a guy in the Scottsdale FSDO says that a safety pilot who takes on the role of PIC may log PIC time (not just SIC).

“Normally, a safety pilot, required by regulations, who scans for traffic for a pilot flying under simulated instrument conditions is not pilot-in-command and thus logs second-in-command. However, if the two pilots agree that the safety pilot is designated pilot-in-command, the safety pilot/pilot-in-command may log PIC since he is the pilot responsible for the operation and safety of the aircraft.”

I’m not sure I agree with this FSDO guy!

I agree with the interpretation of the FSDO guy, but there is some trickiness there too, which I believe someone else mentioned.

To act as PIC, the right-seater must not only be rated, but must also have the proper endorsements (e.g., high-performance), and be current (§ 61.57). If all that’s the case, then the pilots can agree that the safety pilot is acting PIC, and “is directly responsible for, and is the final authority as to, the operation of that aircraft” (§ 91.3). The pilot operating in simulated instrument conditions is merely sole manipulator of the controls. Both get to log PIC time. However, if they enter actual instrument conditions, the right-seater must stop logging his PIC time because the operation no longer requires two crewmembers, even if he or she is still acting PIC.

Beware: if the sole manipulator of the controls busts the rules, it’s the acting PIC that’s on the hook.

However, if the right-seater is qualified to be safety pilot by his or her ratings, but not qualified to act as PIC, then he or she can not act as PIC. When acting as safety pilot in VMC that person can log SIC time, but in IMC that pilot does not get to log anything.

Weird, but that’s the FAA for you.

But acting as PIC doesn’t necessarily mean that you can log PIC time. Case in point: The ATP sleeping in the back seat.


The napping ATP cum acting PIC is not a required crew member like the safety pilot cum acting PIC.

But when in the clouds, the safety pilot is no longer a required crew member and can’t log anything. That’s what I’m saying. They can’t just declare themselves PIC and log PIC for the whole flight.

And even if their buddy is under the hood from takeoff to touchdown and they never kiss a cloud, the safety pilot still couldn’t log the whole flight because the time spent taxiing certainly isn’t flight requiring a second crew member, and “flight time” is from when the aircraft first starts motion for the purpose of flight (leaving the ramp) until you’re stopped at the conclusion of taxiing post-flight.

Excellent IFR Magazine article here on the whole mess.