FAR Ninety-One Point One Oh Nine, the Safety Pilot Rule, and the Hidden Currency Trap Sitting in the Right Seat

The regulation everyone learns in training is that simulated instrument flight requires a safety pilot. What rarely gets covered with the same depth is who that safety pilot can legally be - and a missed detail here puts every flight on the wrong side of the FARs. FAR 91.109 establishes three specific requirements for the safety pilot role, and understanding them also determines the correct way for both pilots to log the flight.

What Does FAR 91.109 Actually Require?

FAR 91.109 states that no pilot may operate an aircraft in simulated instrument conditions unless a safety pilot occupies the other control seat and maintains outside visual reference. The regulation applies to any view-limiting device - foggles, a canvas hood, or any custom device from the flight school. If it limits your outside visual reference to simulate instrument conditions, the regulation applies.

One important boundary: the regulation covers simulated instrument conditions on a VFR day. It does not authorize flying a view-limiting device in actual instrument meteorological conditions. If you are doing hood work and wander into clouds, you are no longer in a simulated scenario - you are in actual IMC, which requires an instrument-rated, instrument-current PIC. Exit the clouds immediately and declare if necessary. The training scenario ends the moment actual clouds are involved.

Who Qualifies as a Safety Pilot?

Three requirements must all be met. Most pilots can name the first. Fewer can name all three on demand.

Requirement 1: At least a private pilot certificate. A sport pilot certificate does not qualify. A student pilot certificate does not qualify. The FAR sets that floor explicitly, and it is not negotiable.

Requirement 2: Appropriate category and class rating. The safety pilot’s certificate must match the aircraft being flown. A Cessna 172 requires a single-engine land rating. A Piper Seneca requires a multiengine land rating. A floatplane requires a single-engine sea rating. The category and class of the airplane must match what is endorsed on the safety pilot’s certificate - this one catches people.

Requirement 3: Adequate vision outside the aircraft. The safety pilot’s entire purpose on that flight is to see and avoid traffic while you are under the hood. If they normally require corrective lenses and left their glasses at home, they cannot legally fill the role. Adequate vision means corrected to whatever their medical certificate requires.

Does a Safety Pilot Need a Medical Certificate?

Yes - and this is the detail that surprises pilots who have been doing hood work for years.

FAR 91.109 designates the safety pilot as a required crewmember, not a helpful observer or a friendly passenger. That word “required” carries specific regulatory weight. In aviation, required crewmember status is a defined legal designation: required crewmembers must be qualified, certified, and medically current to operate in that role.

The medical certificate requirement in aviation is often discussed as something that governs who can be pilot in command. It does govern that. But it also applies to anyone regulation requires to be in that cockpit during flight. Your safety pilot is required to be there by FAR 91.109. Required crewmembers need to be medically certified. That is not a matter of interpretation - it is what the regulation produces when you read the full chain.

For typical Part 91 operations, a third-class medical is sufficient. It is valid for 60 calendar months for pilots under 40, and 24 calendar months for pilots 40 or older. Confirming currency takes about thirty seconds before you turn the key.

Who Is Pilot in Command During Simulated Instrument Flight?

FAR 91.3 is clear: there can only be one pilot in command, and that designation must be made before the flight. Who gets designated changes what each pilot is required to hold.

Scenario 1: The pilot under the hood is PIC.

The rated pilot wearing the foggles holds PIC designation and is the sole manipulator of the controls. The safety pilot is a required crewmember - not PIC. In this arrangement, the safety pilot needs the correct certificate and class rating, adequate vision, and a valid medical. They do not need a current flight review. Under FAR 61.56, the flight review requirement applies to pilots acting as PIC. The safety pilot in this scenario is not PIC, so that requirement does not apply to them on this flight. They also do not need an instrument rating - they are watching outside the airplane, not flying instruments.

Scenario 2: The safety pilot is the designated PIC.

This is a valid arrangement, and some flight schools prefer it because it places command authority with the pilot who can see outside. In this scenario, the safety pilot needs everything required to serve as PIC: a valid medical, a current flight review within the preceding 24 calendar months, and all other applicable PIC qualifications. If the flight is in Class Bravo airspace, additional considerations may apply depending on the safety pilot’s experience and ratings.

How Does Each Pilot Log the Flight?

Both pilots can log the flight time - in different categories, both legal, both accurate.

The pilot under the hood logs PIC time. FAR 61.51 allows a pilot to log PIC flight time when they are the sole manipulator of the controls of an aircraft for which they hold the appropriate category and class rating. That provision is independent of who holds PIC designation. So even in Scenario 2, where the safety pilot is designated PIC, the pilot under the hood still logs their time as PIC via the sole-manipulator rule.

The safety pilot logs SIC time when they are not designated PIC. FAR 61.51 allows second-in-command logging when you are required to be in that seat by regulation. Because FAR 91.109 requires the safety pilot to be present, they log it as SIC. If the safety pilot is designated PIC (Scenario 2), they log the time as PIC instead.

Two pilots, one flight, both logging flight time. This is one of those regulatory outcomes that looks strange until you follow the chain - then it makes complete sense.

For instrument students, the practical implication matters: hours flown under the hood with a properly qualified safety pilot can count as PIC instrument time toward the 40 hours of actual or simulated instrument time required for the instrument rating. Understanding how the regulation works tells you exactly what is going into your logbook and why.

The Pre-Flight Safety Pilot Checklist

Five items. Two minutes on the ground. They protect both pilots.

1. Private pilot certificate with appropriate category and class? Check the certificate before you go.
2. Valid medical certificate? Ask. Verify the expiration date. Do not assume.
3. Who is PIC? Designate it explicitly, out loud, before the engine starts.
4. If the safety pilot is PIC, do they have a current flight review within the last 24 calendar months?
5. Are both pilots clear on what they are each logging?

What to Expect on the Oral Exam

The Airman Certification Standards for the private pilot certificate include simulated instrument flight as a required task. During the oral, an examiner may ask what certificate the safety pilot needs and what class rating applies to the aircraft you flew. Know those answers cold.

For the instrument rating oral, expect deeper questions: the PIC designation question, what the safety pilot needs in each arrangement, and the logging rules for both pilots. These questions have specific regulatory answers and appear on oral exams precisely because they reveal whether a candidate read the regulation or merely absorbed the headline.

Key Takeaways

• A safety pilot must hold at least a private pilot certificate with the appropriate category and class rating, have adequate vision, and hold a valid medical certificate - all three requirements must be met.
• The safety pilot is a required crewmember under FAR 91.109, not a passenger, which is why the medical certificate requirement applies.
• PIC must be explicitly designated before the flight. That designation determines whether the safety pilot also needs a current flight review.
• The pilot under the hood logs PIC time as sole manipulator of the controls, regardless of who holds PIC designation for the flight.
• The safety pilot logs SIC time when not designated PIC, or PIC time when they are - and both are legal, accurate entries.