Are FAA Legal Interpretations retroactive?

Assume someone had a flight in 2003 where they were acting as safety pilot on a cross country. Based on their understanding and their CFII's understanding at the time, both the safety pilot and flying pilot logged the cross country time.

The Gebhart Interpretation comes out in 2009. Should that safety pilot go back and negate the cross country time from that flight?

Is it generally the case that Legal Interpretations are retroactive?

1 Replies
1521 Posts

They don't have to “negate” it in their logbook, but they'd better not include that time on a new 8710-1 to meet pilot certification requirements now.