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Do you have to be current to carry passengers to act as safety pilot? (Assuming that you are not logging the time as acting PIC)
FAR question - safety pilot
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Greg Bockelman
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No. The only requirement is that you have a current medical and be rated. No endorsements necessary either.
Currency is a PIC thing in that case.
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thanks, Greg. That's pretty much exactly how I thought it was written. 
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Hmm. That brings up something that I hadn't considered before. You also don't have to be night current to act as safety pilot at night.
Greg Bockelman
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Nope.
midlifeflyer
Touchdown! Greaser!
You don't need to meet any PIC qualification/curency requirement if you are not acting as PIC.
Of course you might need to meet an SIC qualification requirement, but the only one I'm aware of that applies to safety pilots is that if the flight is done under IFR, the safety pilot needs an instrument rating.
Greg Bockelman
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You mean an IFR flight plan or in IMC, Mark?
I can't say I have heard that one before.
I can't say I have heard that one before.
midlifeflyer
Touchdown! Greaser!
"Under IFR" (the rules) is enough. The reference is 61.55(a) which deals with SIC qualifications.
Until around 2005, there was a 61.55(d)(4) that exempted safety pilots from 61.55 altogether (if you have the old FAQ you'll see it referred to in one of the answers). You'll see that in the current version, the only safety pilot exemption (it's in 61.55(f)(4)) is from the special SIC familiarization requirements in 61.55(b).
Greg Bockelman
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Ok. Never got that far into it, I guess.
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If the flight is under IFR then the acting PIC has to be instrument-rated and current.
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Interesting -- I wonder if anyone in AFS-800 realizes what they did when they reorganized 61.55 in 2005 to cover the SIC type rating issue. I'll bet this was an inadvertant omission, and I've got an email out to AFS-800 to see whether that's true or not. It was certainly done without fanfare, and a lot of folks probably missed that change in the wording.
ghogue
Pre-takeoff checklist
Ron,
I missed this too. Looking back in my hard copy versions of FAR/AIM, years 2005 and earlier and 2007 and later pretty much reflect the same wording. The 2006 version is the strange one, only lasting about one year/publication cycle.
gary
midlifeflyer
Touchdown! Greaser!
If you are seeing the old language with the full exemption in your current FAR hardcopy, I'd go to the publisher. Here's the US General Printing Office official site's version of 61.55, current as of September 4, 2008
http://ecfr.gpoaccess.gov/cgi/t/tex...v8&view=text&node=14:2.0.1.1.2.1.1.33&idno=14
Whether the limitataion of the exemption was intentional or not I haven't a clue, but I agree with Ron that it was without any real fanfare. I don't recall having seen anything about the changes to 61.55 that even mentioned it.
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ghogue
Pre-takeoff checklist
Mark,
Perhaps I worded my response poorly. My current hard copy and online versions are in synch. I was just saying that the only year I can find with the "exemption" that I believe you were referring to was in the published 2006 FAR/AIM.
2008 Version
(f) The familiarization training requirements of paragraph (b) of this section do not apply to a person who is:
2006 Version
(f) This section does not apply to a person who is:
2005 and earlier reads similar to 2008 (and 2007 for that matter).
Also agree about no fanfare. I was only aware of it after reading it from tgrayson on JetCareers forum.
gary
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TMetzinger
Final Approach
Yeah, the FedRegister preamble is so old (2005) I don't have it anymore. The way the reg reads now, if you're under IFR, the SIC must have an instrument rating - the only exemption applicable to safety pilots is for the familiarization requirements in 61.55(b).
Just in case it helps - here's the whole section:
§ 61.55 Second-in-command qualifications.
{New-2005-18 (a) revised August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command pilot flight crewmember only if that person holds:
{Beginning of old text revised August 4, 2005, effective September 6, 2005}
(a) Except as provided in paragraph (d) of this section, no person may serve as a second in command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second in command unless that person holds:
(1) At least a current private pilot certificate with the appropriate category and class rating; and
{New-2005-18 (a)(2) revised August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(2) An instrument rating or privilege that applies to the aircraft being flown if the flight is under IFR; and
{Beginning of old text revised August 4, 2005, effective September 6, 2005}
{(a)} (2) An instrument rating that applies to the aircraft being flown if the flight is under IFR.
{New-2005-18 (a)(3) added August 4, 2005, effective September 6, 2005}
(3) The appropriate pilot type rating for the aircraft unless the flight will be conducted as domestic flight operations within United States airspace.
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(b) Except as provided in paragraph (e) of this section, no person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command unless that person has within the previous 12 calendar months:
(1) Become familiar with the following information for the specific type aircraft for which second-in-command privileges are requested -
(i) Operational procedures applicable to the powerplant, equipment, and systems.
(ii) Performance specifications and limitations.
(iii) Normal, abnormal, and emergency operating procedures.
(iv) Flight manual.
(v) Placards and markings.
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(2) Except as provided in paragraph (g) of this section, performed and logged pilot time in the type of aircraft or in a flight simulator that represents the type of aircraft for which second-in-command privileges are requested, which includes--
(i) Three takeoffs and three landings to a full stop as the sole manipulator of the flight controls;
(ii) Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command; and
(iii) Crew resource management training.
(c) If a person complies with the requirements in paragraph (b) of this section in the calendar month before or the calendar month after the month in which compliance with this section is required, then that person is considered to have accomplished the training and practice in the month it is due.
{New-2005-18 (d) added August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(d) A person may receive a second-in-command pilot type rating for an aircraft after satisfactorily completing the second-in-command familiarization training requirements under paragraph (b) of this section in that type of aircraft provided the training was completed within the 12 calendar months before the month of application for the SIC pilot type rating. The person must comply with the following application and pilot certification procedures:
(1) The person who provided the training must sign the applicant's logbook or training record after each lesson in accordance with § 61.51(h)(2) of this part. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's training records or logbook and make the required endorsement. The qualified management official must hold the position of Chief Pilot, Director of Training, Director of Operations, or another comparable management position within the organization that provided the training and must be in a position to verify the applicant's training records and that the training was given.
(2) The trainer or qualified management official must make an endorsement in the applicant's logbook that states "[Applicant's Name and Pilot Certificate Number] has demonstrated the skill and knowledge required for the safe operation of the [Type of Aircraft], relevant to the duties and responsibilities of a second in command."
(3) If the applicant's flight experience and/or training records are in an electronic form, the applicant must present a paper copy of those records containing the signature of the trainer or qualified management official to an FAA Flight Standards District Office or Examiner.
(4) The applicant must complete and sign an Airman Certificate and/or Rating Application, FAA Form 8710-1, and present the application to an FAA Flight Standards District Office or to an Examiner.
(5) The person who provided the ground and flight training to the applicant must sign the "Instructor's Recommendation" section of the Airman Certificate and/or Rating Application, FAA Form 8710-1. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's FAA Form 8710-1.
(6) The applicant must appear in person at a FAA Flight Standards District Office or to an Examiner with his or her logbook/training records and with the completed and signed FAA Form 8710-1.
(7) There is no practical test required for the issuance of the "SIC Privileges Only" pilot type rating.
{New-2005-18 (e) added August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(e) A person may receive a second-in-command pilot type rating for the type of aircraft after satisfactorily completing an approved second-in-command training program, proficiency check, or competency check under subpart K of part 91, part 121, part 125, or part 135, as appropriate, in that type of aircraft provided the training was completed within the 12 calendar months before the month of application for the SIC pilot type rating. The person must comply with the following application and pilot certification procedures:
(1) The person who provided the training must sign the applicant's logbook or training record after each lesson in accordance with § 61.51(h)(2) of this part. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's training records or logbook and make the required endorsement. The qualified management official must hold the position of Chief Pilot, Director of Training, Director of Operations, or another comparable management position within the organization that provided the training and must be in a position to verify the applicant's training records and that the training was given.
(2) The trainer or qualified management official must make an endorsement in the applicant's logbook that states "[Applicant's Name and Pilot Certificate Number] has demonstrated the skill and knowledge required for the safe operation of the [Type of Aircraft], relevant to the duties and responsibilities of a second in command."
(3) If the applicant's flight experience and/or training records are in an electronic form, the applicant must provide a paper copy of those records containing the signature of the trainer or qualified management official to an FAA Flight Standards District Office, an Examiner, or an Aircrew Program Designee.
(4) The applicant must complete and sign an Airman Certificate and/or Rating Application, FAA Form 8710-1, and present the application to an FAA Flight Standards District Office or to an Examiner or to an authorized Aircrew Program Designee.
(5) The person who provided the ground and flight training to the applicant must sign the "Instructor's Recommendation" section of the Airman Certificate and/or Rating Application, FAA Form 8710-1. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's FAA Form 8710-1.
(6) The applicant must appear in person at an FAA Flight Standards District Office or to an Examiner or to an authorized Aircrew Program Designee with his or her logbook/training records and with the completed and signed FAA Form 8710-1.
(7) There is no practical test required for the issuance of the "SIC Privileges Only" pilot type rating.
{New-2005-18 (f) redesignated August 4, 2005, effective September 6, 2005. Was (d).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(f) The familiarization training requirements of paragraph (b) of this section do not apply to a person who is:
(1) Designated and qualified as pilot in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(2) Designated as the second in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(3) Designated as the second in command in that specific type of aircraft for the purpose of receiving flight training required by this section, and no passengers or cargo are carried on the aircraft; or
(4) Designated as a safety pilot for purposes required by § 91.109(b) of this chapter.
{New-2005-18 (g) redesignated August 4, 2005, effective September 6, 2005. Was (e).}
(g) The holder of a commercial or airline transport pilot certificate with the appropriate category and class rating is not required to meet the requirements of paragraph (b)(2) of this section, provided the pilot:
(1) Is conducting a ferry flight, aircraft flight test, or evaluation flight of an aircraft's equipment; and
(2) Is not carrying any person or property on board the aircraft, other than necessary for conduct of the flight.
{New-2005-18 (h) redesignated August 4, 2005, effective September 6, 2005. Was (f).}
(h) For the purpose of meeting the requirements of paragraph (b) of this section, a person may serve as second in command in that specific type aircraft, provided:
(1) The flight is conducted under day VFR or day IFR; and
(2) No person or property is carried on board the aircraft, other than necessary for conduct of the flight.
{New-2005-18 (i) redesignated August 4, 2005, effective September 6, 2005. Was (g).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(i) The training under paragraphs (b) and (d) of this section and the training, proficiency check, and competency check under paragraph (e) of this section may be accomplished in a flight simulator that is used in accordance with an approved training course conducted by a training center certificated under part 142 of this chapter or under subpart K of part 91, part 121 or part 135 of this chapter.
{New-2005-18 (j) redesignated August 4, 2005, effective September 6, 2005. Was (h).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(j) When an applicant for an initial second-in-command qualification for a particular type of aircraft receives all the training in a flight simulator, that applicant must satisfactorily complete one takeoff and one landing in an aircraft of the same type for which the qualification is sought. This requirement does not apply to an applicant who completes a proficiency check under part 121 or competency check under subpart K, part 91, part 125, or part 135 for the particular type of aircraft.
[Amdt. 61-103, 62 FR 40898, July 30, 1997; Amdt. 61-109, 68 FR 54519, September 17, 2003, effective November 17, 2003; Amdt. 61-113, 70 FR 45263, August 4, 2005, effective September 6, 2005, as corrected at 70 FR 61888, October 27, 2005]
To make it MORE interesting, the Q&A from John Lynch before 2005 made it clear that an SIC safety pilot did NOT have to have an instrument rating, because
"Now some may ask why would the FAA except a safety pilot from the SIC requirements of § 61.55. You have to keep in mind the only reason for a safety pilot is to prevent the aircraft from being flown into the ground or conflict with other aircraft while the other pilot is flying the aircraft with a view limiting device (hood). And the pilot qualification requirements for the safety pilot are already addressed in § 91.109(b)(1). Furthermore, the FAA reasoned that if it had not excepted pilots who serve as safety pilots from the SIC requirements of § 61.55 then the rule would have required safety pilots to complete SIC training and endorsements for every aircraft (e.g., Cessna 152, Piper PA28-140, Cessna 310, etc.; otherwise, single-piloted aircraft) where the person serves as a safety pilot."
Can't wait to hear what the new logic is, if it's not "Ooops."
Just in case it helps - here's the whole section:
§ 61.55 Second-in-command qualifications.
{New-2005-18 (a) revised August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command pilot flight crewmember only if that person holds:
{Beginning of old text revised August 4, 2005, effective September 6, 2005}
(a) Except as provided in paragraph (d) of this section, no person may serve as a second in command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second in command unless that person holds:
(1) At least a current private pilot certificate with the appropriate category and class rating; and
{New-2005-18 (a)(2) revised August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(2) An instrument rating or privilege that applies to the aircraft being flown if the flight is under IFR; and
{Beginning of old text revised August 4, 2005, effective September 6, 2005}
{(a)} (2) An instrument rating that applies to the aircraft being flown if the flight is under IFR.
{New-2005-18 (a)(3) added August 4, 2005, effective September 6, 2005}
(3) The appropriate pilot type rating for the aircraft unless the flight will be conducted as domestic flight operations within United States airspace.
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(b) Except as provided in paragraph (e) of this section, no person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command unless that person has within the previous 12 calendar months:
(1) Become familiar with the following information for the specific type aircraft for which second-in-command privileges are requested -
(i) Operational procedures applicable to the powerplant, equipment, and systems.
(ii) Performance specifications and limitations.
(iii) Normal, abnormal, and emergency operating procedures.
(iv) Flight manual.
(v) Placards and markings.
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(2) Except as provided in paragraph (g) of this section, performed and logged pilot time in the type of aircraft or in a flight simulator that represents the type of aircraft for which second-in-command privileges are requested, which includes--
(i) Three takeoffs and three landings to a full stop as the sole manipulator of the flight controls;
(ii) Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command; and
(iii) Crew resource management training.
(c) If a person complies with the requirements in paragraph (b) of this section in the calendar month before or the calendar month after the month in which compliance with this section is required, then that person is considered to have accomplished the training and practice in the month it is due.
{New-2005-18 (d) added August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(d) A person may receive a second-in-command pilot type rating for an aircraft after satisfactorily completing the second-in-command familiarization training requirements under paragraph (b) of this section in that type of aircraft provided the training was completed within the 12 calendar months before the month of application for the SIC pilot type rating. The person must comply with the following application and pilot certification procedures:
(1) The person who provided the training must sign the applicant's logbook or training record after each lesson in accordance with § 61.51(h)(2) of this part. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's training records or logbook and make the required endorsement. The qualified management official must hold the position of Chief Pilot, Director of Training, Director of Operations, or another comparable management position within the organization that provided the training and must be in a position to verify the applicant's training records and that the training was given.
(2) The trainer or qualified management official must make an endorsement in the applicant's logbook that states "[Applicant's Name and Pilot Certificate Number] has demonstrated the skill and knowledge required for the safe operation of the [Type of Aircraft], relevant to the duties and responsibilities of a second in command."
(3) If the applicant's flight experience and/or training records are in an electronic form, the applicant must present a paper copy of those records containing the signature of the trainer or qualified management official to an FAA Flight Standards District Office or Examiner.
(4) The applicant must complete and sign an Airman Certificate and/or Rating Application, FAA Form 8710-1, and present the application to an FAA Flight Standards District Office or to an Examiner.
(5) The person who provided the ground and flight training to the applicant must sign the "Instructor's Recommendation" section of the Airman Certificate and/or Rating Application, FAA Form 8710-1. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's FAA Form 8710-1.
(6) The applicant must appear in person at a FAA Flight Standards District Office or to an Examiner with his or her logbook/training records and with the completed and signed FAA Form 8710-1.
(7) There is no practical test required for the issuance of the "SIC Privileges Only" pilot type rating.
{New-2005-18 (e) added August 4, 2005, effective September 6, 2005}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(e) A person may receive a second-in-command pilot type rating for the type of aircraft after satisfactorily completing an approved second-in-command training program, proficiency check, or competency check under subpart K of part 91, part 121, part 125, or part 135, as appropriate, in that type of aircraft provided the training was completed within the 12 calendar months before the month of application for the SIC pilot type rating. The person must comply with the following application and pilot certification procedures:
(1) The person who provided the training must sign the applicant's logbook or training record after each lesson in accordance with § 61.51(h)(2) of this part. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's training records or logbook and make the required endorsement. The qualified management official must hold the position of Chief Pilot, Director of Training, Director of Operations, or another comparable management position within the organization that provided the training and must be in a position to verify the applicant's training records and that the training was given.
(2) The trainer or qualified management official must make an endorsement in the applicant's logbook that states "[Applicant's Name and Pilot Certificate Number] has demonstrated the skill and knowledge required for the safe operation of the [Type of Aircraft], relevant to the duties and responsibilities of a second in command."
(3) If the applicant's flight experience and/or training records are in an electronic form, the applicant must provide a paper copy of those records containing the signature of the trainer or qualified management official to an FAA Flight Standards District Office, an Examiner, or an Aircrew Program Designee.
(4) The applicant must complete and sign an Airman Certificate and/or Rating Application, FAA Form 8710-1, and present the application to an FAA Flight Standards District Office or to an Examiner or to an authorized Aircrew Program Designee.
(5) The person who provided the ground and flight training to the applicant must sign the "Instructor's Recommendation" section of the Airman Certificate and/or Rating Application, FAA Form 8710-1. In lieu of the trainer, it is permissible for a qualified management official within the organization to sign the applicant's FAA Form 8710-1.
(6) The applicant must appear in person at an FAA Flight Standards District Office or to an Examiner or to an authorized Aircrew Program Designee with his or her logbook/training records and with the completed and signed FAA Form 8710-1.
(7) There is no practical test required for the issuance of the "SIC Privileges Only" pilot type rating.
{New-2005-18 (f) redesignated August 4, 2005, effective September 6, 2005. Was (d).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(f) The familiarization training requirements of paragraph (b) of this section do not apply to a person who is:
(1) Designated and qualified as pilot in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(2) Designated as the second in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(3) Designated as the second in command in that specific type of aircraft for the purpose of receiving flight training required by this section, and no passengers or cargo are carried on the aircraft; or
(4) Designated as a safety pilot for purposes required by § 91.109(b) of this chapter.
{New-2005-18 (g) redesignated August 4, 2005, effective September 6, 2005. Was (e).}
(g) The holder of a commercial or airline transport pilot certificate with the appropriate category and class rating is not required to meet the requirements of paragraph (b)(2) of this section, provided the pilot:
(1) Is conducting a ferry flight, aircraft flight test, or evaluation flight of an aircraft's equipment; and
(2) Is not carrying any person or property on board the aircraft, other than necessary for conduct of the flight.
{New-2005-18 (h) redesignated August 4, 2005, effective September 6, 2005. Was (f).}
(h) For the purpose of meeting the requirements of paragraph (b) of this section, a person may serve as second in command in that specific type aircraft, provided:
(1) The flight is conducted under day VFR or day IFR; and
(2) No person or property is carried on board the aircraft, other than necessary for conduct of the flight.
{New-2005-18 (i) redesignated August 4, 2005, effective September 6, 2005. Was (g).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(i) The training under paragraphs (b) and (d) of this section and the training, proficiency check, and competency check under paragraph (e) of this section may be accomplished in a flight simulator that is used in accordance with an approved training course conducted by a training center certificated under part 142 of this chapter or under subpart K of part 91, part 121 or part 135 of this chapter.
{New-2005-18 (j) redesignated August 4, 2005, effective September 6, 2005. Was (h).}
{New-2005-24 As corrected at 70 FR 61888, October 27, 2005}
(j) When an applicant for an initial second-in-command qualification for a particular type of aircraft receives all the training in a flight simulator, that applicant must satisfactorily complete one takeoff and one landing in an aircraft of the same type for which the qualification is sought. This requirement does not apply to an applicant who completes a proficiency check under part 121 or competency check under subpart K, part 91, part 125, or part 135 for the particular type of aircraft.
[Amdt. 61-103, 62 FR 40898, July 30, 1997; Amdt. 61-109, 68 FR 54519, September 17, 2003, effective November 17, 2003; Amdt. 61-113, 70 FR 45263, August 4, 2005, effective September 6, 2005, as corrected at 70 FR 61888, October 27, 2005]
To make it MORE interesting, the Q&A from John Lynch before 2005 made it clear that an SIC safety pilot did NOT have to have an instrument rating, because
"Now some may ask why would the FAA except a safety pilot from the SIC requirements of § 61.55. You have to keep in mind the only reason for a safety pilot is to prevent the aircraft from being flown into the ground or conflict with other aircraft while the other pilot is flying the aircraft with a view limiting device (hood). And the pilot qualification requirements for the safety pilot are already addressed in § 91.109(b)(1). Furthermore, the FAA reasoned that if it had not excepted pilots who serve as safety pilots from the SIC requirements of § 61.55 then the rule would have required safety pilots to complete SIC training and endorsements for every aircraft (e.g., Cessna 152, Piper PA28-140, Cessna 310, etc.; otherwise, single-piloted aircraft) where the person serves as a safety pilot."
Can't wait to hear what the new logic is, if it's not "Ooops."
midlifeflyer
Touchdown! Greaser!
FWIW I'm pretty sure the exemption goes back at least to the 1997 FAR Part 61 revision.
TMetzinger
Final Approach
I think you are correct - that's what the FAQ I quoted was in reference to.
midlifeflyer
Touchdown! Greaser!
I'm not sure it makes it any more interesting - the FAQ was based on the wording of the 61.55 that existed before the change where the exemption for safety pilots was very clear.
Actually in another thread where the issue came up, someone suggested that the exemption was an error to begin with. I tend to doubt that because of the lack of "fan fare"; more likely it was an error.
But you never know.
ghogue
Pre-takeoff checklist
Mark,
You're correct. Last night I had 5 copies of FAR/AIM laying in front of me, trying to cross reference each of them. I missed that some paragraphs had been re-lettered. I was comparing apples to oranges.
gary
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poadeleted20
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The change which lost that exemption was introduced in the Federal Register in late 2004, and may be found at http://edocket.access.gpo.gov/2004/pdf/04-25415.pdf. There is nothing in that notice about eliminating the safety pilot exemption from 61.55(a)(2), and states that the old paragraph (d) is merely renumbered paragraph (f). Thus, it appears to have been an inadvertant omission, but I'll wait until I hear from John Lynch (the person listed as the point of contact on the matter) about it.
gismo
Touchdown! Greaser!
At least some parts of 61.55 refer to "operations requiring a second-in-command pilot flight crewmember". I realize that a safety pilot is a "required crewmember" when the pilot flying is wearing a view limiting device but does that really require a "second-in-command pilot flight crewmember"?
If so the wording of the rule also requires that a safety pilot be rather well acquainted with the ship and have performed 3 takeoffs and landings as the sole manipulator. No way can I see this is supposed to apply to safety pilots.
midlifeflyer
Touchdown! Greaser!
It doesn't. 61.55(f) still exempts safety pilots from 61.55(b) which is where the requirements you are talking about appear.
poadeleted20
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Well, you're either a PIC crewmember or an SIC crewmember, and if you're not acting as PIC, then you're acting as SIC. And I believe I've seen an interpretation from the Chief Counsel's office saying a 91.109(b) safety pilot is an SIC if not acting as PIC.
61.55(f)(4) specifically exempts SIC's required only as 91.109(b) safety pilots from those requirements, which are in 61.55(b), so that's clearly not an issue. The problem is that the paragraph 61.55(f)(4) replaced in the pre-SIC-type-rating version of 61.55 (paragraph (d)(4) in the old reg) also specifically exempted SIC's required only by 91.109(b) as safety pilots from the IR requirement in 61.55(a)(2) for IFR operations; that second phrase was lost when 61.55(d) became 61.55(f) in 2005, and that's what all this discussion is about.
midlifeflyer
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Not quite. The former 61.55(d)(4) did not "specifically" exempt safety pilots from the instrument rating requirement. It exempted safety pilots from all 61.55 requirements in general terms.
==============================
(d) This section does not apply to a person who is:
(4) Designated as a safety pilot for purposes required by
Sec. 91.109(b) of this chapter.
==============================
No language was lost. Language was added.
Result is the same, but we might as well get the situation straight when explaining it
poadeleted20
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Thanks for that info. I didn't have a copy of the old wording and was going with the last sentence of John Lynch's explanation of the intent of the old wording:
dmccormack
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And that's true as long as flight is not "under IFR."
That said, I doubt many DPEs will go into the legal whys and wherefores of this issue.
poadeleted20
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To follow up on Dan's comment, in an undocumented and unexplained change to 14 CFR 61.55 in 2005, the FAA removed the exception to the requirement for an IR for safety pilots when the flight is conducted under IFR. Thus, if the flight is done on an IFR clearance (regardless of actual conditions), the safety pilot must have an instrument rating (although instrument currency is not required unless the safety pilot is also acting as PIC -- 61.57(c) only applies to the PIC, not the SIC).
As a side note, I've queried the author of that regulation to find out why that change was made or if it was even done intentionally or not. I have not yet received a reply.
As a side note, I've queried the author of that regulation to find out why that change was made or if it was even done intentionally or not. I have not yet received a reply.
dmccormack
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Ron,
Wouldn't the Safety Pilot only need to be PIC when flying IFR only when the left seat pilot was working on the IR and not yet IR? Or in any condition when acting as SP?
midlifeflyer
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It's not a PIC issue, Dan, it's an SIC issue.
61.55 deals with the requirements for an SIC, which includes needing an instrument rating for IFR flights. 61.55 used to have an general exception for safety pilots (who are acting as SIC when not acting as PIC). It was removed as part of the revision that dealt with SIC type ratings and familiarity requirements. 61.55 still has a safety pilot exception, but it's more limited and doesn't, as worded, exempt a safety pilot from instrument rating requirements if the flight is under IFR.
I think I posted the two versions of the reg in another thread. Ron things it was probably unintentional. I tend to agree since the Federal Register that discusses the changes doesn't even mention it, although I've heard some folks argue that the FAA never really intended to exempt safety pilots from needing an IR when acting as required crew under IFR and that all the change did was to "fix" it.
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poadeleted20
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...or if the left seat pilot wasn't instrument current per 61.57(c), or didn't have a current medical, etc.
No -- the pilots may choose to make the safety pilot the PIC for any number of reasons, but the safety pilot is not required to be PIC unless the hooded pilot isn't PIC-qualified/current for the operation they conduct.
poadeleted20
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If so, it's been wrong for 39 years or more, since it was that way when I started serious flight training in 1969. This isn't like the AGI/IGI issue, where they admitted almost immediately that they'd screwed up (but still took 10 years to propose the fix and heading towards another year and a half to implement it).
TMetzinger
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Hmm, so I can use the AGI for another year or more before I need to get the IGI (or CFII).
Is there any ground instruction an IGI can give that a CFII cannot? Or is it just that ground instructor certificates don't expire?
Is there any ground instruction an IGI can give that a CFII cannot? Or is it just that ground instructor certificates don't expire?
jesse
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Uhm..Did you read what I wrote compared to everything else in this thread? The ASA book says that the safety pilot must be current.
TMetzinger
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Current in this case meant takeoffs and landings, not instrument current. Landing currency is cat/class, while instrument currency is category only.
Greg Bockelman
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Jesse, I personally do not take ASA as a credible source for official FAR interpretation. Did they back it up with an FAR reference? This isn't the first case that publishers like that are flat wrong.
midlifeflyer
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The ASA book is wrong. Wouldn't be the first time.
poadeleted20
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Substitute "rated in the category and class" for "current in the category and class" and their answer would have been correct until the FAA changed the bit about instrument ratings in 2005. However, it is twice incorrect per the current rules.
dmccormack
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I sure did: "current in the category and class of aircrat being flown" does not necessarily imply Instrument currency.
poadeleted20
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Reply received from AFS-840 -- the change was intentional. He admitted that they didn't explain it very well in the Federal Register, but it was their intent to require the safety pilot to have an IR if the flight was operating under IFR. So, we'll just have to start teaching it differently to match the new rule.