The question of how to log flight time during safety pilot operations represents one of the more nuanced corners of 14 CFR Part 61, and it is one that confuses pilots at every certificate level. Under 91.109(c), any pilot flying under simulated instrument conditions — wearing a view-limiting device such as foggles — is required to have a safety pilot aboard who holds at least a private certificate in the same category and class of aircraft and possesses a current medical certificate. That safety pilot is legally a required crewmember for the duration of the simulated instrument flight, and that distinction is the cornerstone of how time is logged by both occupants.
The pilot wearing the foggles and manipulating the controls logs PIC time under 61.51(e)(1)(i) as the sole manipulator of the controls of an aircraft for which they are rated, and simultaneously logs instrument time for any approaches, holds, or en route time conducted under the hood. This is also the time that counts toward the six-approach, hold, and intercepting/tracking currency requirement under 61.57(c). The safety pilot, however, has two distinct options depending on how the flight is structured before wheels-up. If the two pilots agree that the safety pilot is acting as pilot in command — meaning that person bears legal responsibility for the safety of the flight — the safety pilot may log PIC time under 61.51(e)(1)(ii), because 91.109 makes them a required crewmember, satisfying the "more than one pilot is required" standard under that provision. If no such agreement is made and the pilot under the hood retains acting PIC status, the safety pilot may only log SIC time under 61.51(f). Critically, both pilots may log PIC simultaneously under the first scenario because they are invoking separate and distinct regulatory provisions — a fact that surprises many pilots but is explicitly supported by FAA legal interpretations.
For the instrument student, a few practical considerations shape how these flights are most effectively structured. First, the pre-flight agreement designating acting PIC must be explicit and mutual; it cannot be assumed or assigned retroactively in a logbook. Second, the safety pilot must maintain an actual visual scan for traffic and conflicting aircraft at all times — this is not a passenger seat, and a safety pilot who is distracted, reading, or otherwise not performing the see-and-avoid function is creating a serious legal and safety liability for both occupants. Third, the safety pilot's medical certificate requirement is often overlooked; a BasicMed holder qualifies for safety pilot duties under 61.23 provided the flight falls within BasicMed operational parameters, but a pilot flying purely on a sport or recreational certificate does not meet the rating requirements for most training aircraft.
Beyond the logging mechanics, the broader significance of safety pilot training lies in its cost efficiency and the quality of instrument scan it can build. Flying with a qualified safety pilot allows an instrument student to conduct realistic approach sequences — including missed approaches, holds, and full procedure turns — in actual aircraft without the overhead of a flight instructor on board for every hour. That said, the arrangement works best when the safety pilot is also instrument-rated or instrument-current themselves, because they can provide meaningful debrief feedback and recognize deviations in scan technique or procedure execution. Many instrument-rated pilots use reciprocal safety pilot arrangements to maintain their own currency under 61.57(c) while simultaneously helping a peer build toward the practical test, making the relationship mutually beneficial across the general aviation training ecosystem.