Answered By AOPA
You’re hanging out at the local FBO and one of the local pilots walks in and asks a question aloud, “Anyone want to go up and be my safety pilot for a couple of approaches?” Of course the answer is “Yes;” you get to go flying and don’t have to pay for it. Walking out to the plane you realize that you may have accepted this flight a little prematurely. This pilot flies a Cessna 182 Turbo RG. The problem is you don’t have a complex or a high performance endorsement. Can you be the safety pilot for this flight? Can you log any of the flight time?
AOPA Staff Answer
You can be the safety pilot for this flight, but you can’t act as PIC, even when the other pilot is under the hood. The other pilot would need to be acting PIC for the entire flight, you would be SIC when he is under the hood and you would log SIC time. While it is always a good idea to be familiar with and have some experience in an aircraft in which you’re acting as safety pilot, there is no requirement for a safety pilot to hold the correct endorsements for the aircraft used, just a private pilot certificate with correct category and class (FAR 91.109(c)). For further clarification we can reference FAA Letters of Interpretation, in particular the Rizner Interpretation from 1991 (https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1991/Rizner - (1991) Legal Interpretation.pdf).