IFR curency and safety pilot
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Answered By AOPA
Part 61.57 (d)  states that a pilot that has not done the 6 approaches etc within the pas 6 months as per paragraph (c) the pilot can only reestablish instrument currency by completing the instrument proficiency check.  Local CFII check with FAA office and was quoted the Flight Standards Info that only if 12 months had passed without compiling with paragraph (c) would require a proficiency check.  I found a Flight Standards Information  890.1 CHG 462 Chapter 2  paragraph 5-264 subparagraph A that in part said "failure to met instrument requirement for 12 months would require a proficiency check.  Question: If pilot has not complied with paragraph (c) for 6 months, could pilot then comply with paragraph (c) before the end of a 12 month period, and be legal to fly IFR without a proficiency check ride?
Does a Safety Pilot acting in accordance with 91.109 (c) who is clearly not the PIC, does holds a private pilots certificate but does not have a current biannual legal? Is a current medical required safety pilot ,again if not PIC?
6 Replies
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AOPA Staff Answer
Because of the type of operation, simulated instrument, the safety pilot is considered to be a required crewmember.  A required crewmember has to have either a FAA medical or BasicMed.  If the safety pilot is using BasicMed then they would be required to be acting PIC which would mean they would need to have a current flight review.
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Gary Henderson:
Question: If pilot has not complied with paragraph (c) for 6 months, could pilot then comply with paragraph (c) before the end of a 12 month period, and be legal to fly IFR without a proficiency check ride?

Does a Safety Pilot acting in accordance with 91.109 (c) who is clearly not the PIC, does holds a private pilots certificate but does not have a current biannual legal? Is a current medical required safety pilot ,again if not PIC?

To the first question, yes.  As long as it's been less than six months since the last time you were current, you can just fill the 6HITs squares and then act as PIC under IFR.  61.57(c).

To the second, yes -- a Flight Review is required only to act as PIC. 61.56(c).

Finally, yes, a safety pilot not acting as PIC needs at least a Third Class Medical.  91.109(c) says the safety pilot needs at least Private Pilot.  That means the safety pilot is exercising Private Pilot privileges.  61.23(a)(3)(i) says you need at least a Third Class Medical to exercise Private Pilot privileges in an Airplane.

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Just to be clear, the OP said the safety pilot was NOT acting as PIC.  In that case, a Third Class or better medical is required.  

Beyond the OP's question, as IB points out, someone with Basic Med can be a safety pilot, but ONLY if ALSO acting as PIC.  In that case, the Basic Med/PIC/safety pilot would require not only a 61.56 flight review, but all other requirements to act s PIC, including 61.57 passenger landing currency (since the hooded pilot not acting as PIC is a passenger, not a required pilot crewmember), any applicable 61.31 additional training endorsements, and the appropriate type rating if the aircraft involved requires one.  

In addition to those FAA requirements, to keep the aircraft owner's insurance in force, the Basic Med/PIC/safety pilot would have to meet all open pilot waiver requirements in that policy.  That might not be a big deal for something like a 172 or Warrior, but for a plane like a Bonanza or Cirrus, those could be significant.
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With these PIC/crewmember rules in mind, what exactly needs to be done differently in the airplane for IFR currency or is it just FAA lawyering without an operational difference?
Consider these cases of to pilots trying to maintain IFR currency:
1. Basic Med pilot acts as safety pilot to pilot with medical
2. Pilot with medical acts as safety pilot for a basic med pilot
3. Two basic med pilots trying to keep each other current
 Also, anything different in how to log the approaches/flight?
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Good questions. In the interest of avoiding a lengthy written explanation and therefore the possibility of not answering  all questions to satisfaction I am going to suggest you give the AOPA PIC a call at 1-800-872-2672 option 2. Others can try to answer by the written word, but my experience is this will lead to the potential for additional confusion. 
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Joel Williams:
With these PIC/crewmember rules in mind, what exactly needs to be done differently in the airplane for IFR currency or is it just FAA lawyering without an operational difference?
Nothing is different between the airplane and the sim any more. The FAA eliminated the differences a couple of years ago.
Joel Williams:
1. Basic Med pilot acts as safety pilot to pilot with medical
Basic Med is only valid when acting as PIC. In this case, the Basic Med pilot would have to be the PIC as well as being the safety pilot. The pilot flying would log all the flying as PIC time including logging the instrument currency events under the "sole manipulator" provision. The Basic Med safety pilot/PIC would log PIC time for all the time the pilot flying was hooded, but nothing else.
Joel Williams:
2. Pilot with medical acts as safety pilot for a basic med pilot
Either pilot can be the PIC, but only the pilot flying can log the events for instrument currency. If the pilot flying is acting as PIC, the safety pilot logs SIC time for the time the pilot flying is hooded. If the safety pilot is acting as PIC, then the safety pilot can log PIC time while the pilot flying is hooded. Either way, the pilot flying logs PIC time for the whole flight.
Joel Williams:
3. Two basic med pilots trying to keep each other current
Since a Basic Med pilot can't be acting as safety pilot without also acting as PIC, it's the same answer as 1.
Joel Williams:
 Also, anything different in how to log the approaches/flight?
See above.  Just remember that when a Basic Med pilot is acting as safety pilot, s/he must also be the PIC, and that means meeting all applicable PIC requirements such as 90-day passenger landing currency, flight review, any applicable 61.31 additional training endorsements (TW, complex, etc) and instrument currency if they're operating under IFR regardless of the qualifications of the pilot flying.

And no matter who's the PIC, or what medical status anyone holds, unless the safety pilot is an instrument instructor, only the pilot flying can log the instrument events for IFR currency and instrument time.