Safety pilot operations under simulated instrument conditions represent one of the most frequently misunderstood logging scenarios in Part 61, and the scenario described in this post captures the core regulatory tension accurately while leaving several important distinctions unresolved. Under 14 CFR 61.51(e)(1)(i), Pilot A—as sole manipulator of the controls of an aircraft for which they hold a rating—may log pilot-in-command time for the entire flight, including the takeoff and landing segments flown without foggles. Total time, cross-country time (assuming the landing point exceeds 50 nautical miles from the departure airport as stated), simulated instrument time for the goggle-covered portion, and landings all log correctly under Pilot A's analysis. The more nuanced question involves Pilot B. Under 91.109(b), simulated instrument flight requires a safety pilot, making that safety pilot a required crew member under the regulation—but only during the period Pilot A is actually operating under the hood. Outside those moments, no regulatory requirement exists for a second pilot, which means Pilot B has no basis to log any flight time during takeoff or landing when Pilot A is flying VFR as sole manipulator.
The distinction between PIC and SIC for Pilot B hinges on a pre-flight designation that the post does not address. Under 61.51(e)(1)(iii), a pilot may log PIC time when acting as PIC of an operation requiring more than one pilot by the regulations under which the flight is conducted. When Pilot A goes under foggles, 91.109 creates a two-pilot requirement, and if the pilots have designated Pilot B as the acting PIC prior to departure, Pilot B may log PIC concurrently with Pilot A—both pilots logging PIC simultaneously is legal and well-supported by FAA legal interpretations including the Speranza interpretation. However, if no such designation is made, Pilot B's correct entry is SIC under 61.51(f)(2), not PIC. This distinction matters significantly: SIC time does not satisfy the aeronautical experience requirements for an instrument rating under 61.65, nor does it carry the same weight in airline hiring contexts as verified PIC time. Pilots building toward an ATP or seeking employment at regional or Part 135 operators must ensure their logbook methodology withstands scrutiny, and conflating SIC with PIC—even inadvertently—constitutes a logbook accuracy problem that can surface during FAA or employer audits.
The proposed return-trip role reversal is operationally sound and commonly practiced. Each pilot alternating roles as sole manipulator and safety pilot/designated PIC on reciprocal legs is an efficient and fully legal time-building strategy that maximizes the value of each flight for both participants. Both pilots should document the pre-flight PIC designation in their logbooks with a brief notation, and the safety pilot must hold at least a private pilot certificate with an appropriate category and class rating for the aircraft, be current on their flight review, and carry their certificate on the flight. The safety pilot does not need an instrument rating to serve in this role, though they must be able to see and avoid traffic while the flying pilot is under foggles—a practical responsibility that demands full situational awareness throughout the flight.
This scenario reflects a broader pattern in general aviation where the regulatory framework for logging and currency intersects in ways that generate persistent confusion even among certificated pilots. The FAA's logging rules under Part 61.51 were designed for a simpler era and have been extended through legal interpretation rather than rulemaking to accommodate complex multi-pilot VFR training operations. For professional pilots at Part 135 or 91K operations, these same principles govern how simulator instructors, check airmen, and second-in-command trainees log time during training events—misapplication of the sole-manipulator and required-crew-member standards in those environments can create compliance exposure during FSDO oversight. Maintaining a clear, contemporaneous logbook with specific notations about the basis for each PIC entry—particularly in dual-pilot VFR training flights and sim sessions—is a professional practice standard that protects pilots at every certificate level.