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Maintaining IFR currency

Greenley

Well Known Member
Wondering about maintaining IFR currency. While my insurance has an open pilot clause, it requires 25 hours in type. There are no RV-10's in my area. I am assuming the safety pilot would need to have those 25 hours. How do you guys handle this who are in this position? Hoping to sell my Cessna, so that will no longer be an option, and would rather do my practice in my long distance machine.
 
IMHO, if the safety pilot is NOT the PIC your insurance doesn't care.

I learned something interesting last week. According to insurance agent, it is not PIC that they care about, it is who is flying the plane. If you have classified yourself as PIC and your friend is flying, he is considered the pilot by the carrier and needs to meet the policies requirements for pilots. The concept of "classifying" someone as PIC is really an FAA thing and doesn't transfer to the insurance world, as I understand it.

Obviously this doesn't apply to the safety pilot, who is just looking out the window for traffic, but thought I would pass on what I learned.

Larry
 
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The safety pilot is a passenger who is a pilot with with a valid medical (doesn't need a current BFR). If the safety pilot has a basic med then he must meet all currency and qualification requirements to act as PIC as a required crew member. I fly with a pilot who has a medical, and also have a Redbird TD with the G1000 overlay to mimic the glass panel in my RV8. Being able to fly an approach a day at home (at any airport in the US) really keeps the scan, control skills and approach plate interpretation super sharp. It's now possible, since July of last year, to log FAA approved simulator time for currency.
 
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OK, I was thinking that the safety pilot was a required crew member for simulated IFR so would have to come under the time requirements. Glad that is not the case.
 
Forgot to say... congrats on finishing your plane, getting your airworthiness cert, and getting into phase 1- you've joined an exclusive club! :)
 
Just heard from Gallagher, according to them a safety pilot either needs to meet the open pilot clause of a policy or be listed on the insurance. Of course to be listed you need to have had transition training to the model involved. This is a requirement on top of FAA requirements.
 
Just heard from Gallagher, according to them a safety pilot either needs to meet the open pilot clause of a policy or be listed on the insurance. Of course to be listed you need to have had transition training to the model involved. This is a requirement on top of FAA requirements.

I am hopefull and suspect this is a misunderstanding on the part of the agent you spoke with. If you follow the logic, even getting a BFR would require a CFI with the required hours. Hopefully one of the more senior gallagher ladies will chime in here to clarify. A saftey pilot's role is to "look" for traffic and is not a co-pilot or even a backup for the pilot. Their role is purely traffic observation. Can't see the logic on this one and the insurances companies would do themselves a real disservice by making VFR instrument practice fundamentally impossible. Statistics prove that instrument practice increases proficiency and proficiency reduces accident rates.

I am certain this post will get the phone ringing over at Gallagher and should see a response soon.

Larry
 
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I hope it is a misunderstanding. Upon further communication with Gallagher, even a BFR would require a CFI either be eligible to be listed and be listed on the insurance, or meet the open pilot requirements. This is because a BFR has the CFI taking the controls for brief periods of time. My current CFI is ineligible because he has not had transition training, so he could not even be listed.
 
I hope it is a misunderstanding. Upon further communication with Gallagher, even a BFR would require a CFI either be eligible to be listed and be listed on the insurance, or meet the open pilot requirements. This is because a BFR has the CFI taking the controls for brief periods of time. My current CFI is ineligible because he has not had transition training, so he could not even be listed.

I have my CFII listed on my policy. He had zero RV time when he was added. It didn't change my premium.

I think the person is confusing the safety pilot under vfr and ifr conditions. Under IFR, they are the PIC, but in VFR they're basically just and observer.
 
This is because a BFR has the CFI taking the controls for brief periods of time. My current CFI is ineligible because he has not had transition training, so he could not even be listed.

I just did a BFR last week and the CFI never touched the stick. However, I somewhat understand their perspective on that. But it greatly increases the difficulty of getting a BFR done. If this safety pilot issue turns out to be accurate, it's time we start speaking with the carriers directly. I am certain at least one carrier will allow this and we can entice them with moving over a lot of business from other carriers that won't allow it. It's really a no brainer for the insurance company. The safety pilot never touches the stick so there is no risk for them.

I remain convinced this is coming from an underwriter not fully thinking it through and understanding that a safety pilot is not an acitive pilot and does not pilot the plane. Happy to have a restriction in my policy that forbids safety pilots from controlling the aircraft. I fact, my policy already state that no one may pilot my plane unless they meet the open pilot requirements. I would guess that most underwriters are not pilots and it would be easy to misunderstand the role of a safety pilot. By name it sounds like a co-pilot or someone there to help pilot in some situations. In reality, it is not. They are there for traffic observation only.

Larry
 
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I think the person is confusing the safety pilot under vfr and ifr conditions. Under IFR, they are the PIC, but in VFR they're basically just and observer.

I think that you were thinkng of a non-instrument rated pilot. For a current and rated pilot, he can be PIC under ifr, of course.
My understanding of the faa?s vindictive interpretation of the basic med rules is that a basic med safety pilot must be the PIC - legally responsible for the safe and legal operation of the airplane. Pilots should think thru the ramifications of this, both with the faa and insurance companies.
Like others, I hope the insurance rep mis-spoke. The FAA allows pilots to act as a safety pilot even in circumstances where they are not qualified to act as PIC, e.g., no high performance endorsement is required even if the plane is over 200 HP.
 
Does this mean I can't allow anyone not on my insurance to touch a flight control??? I love taking non-pilot friends flying and letting them "fly" the airplane.
 
Does this mean I can't allow anyone not on my insurance to touch a flight control??? I love taking non-pilot friends flying and letting them "fly" the airplane.

No, you are the PIC in that scenario, even when they are operating the controls.
 
Does this mean I can't allow anyone not on my insurance to touch a flight control??? I love taking non-pilot friends flying and letting them "fly" the airplane.

This is exactly what I was told by gallagher. Anyone touching the controls needs to meet the open pilot requirements of the policy. The PIC thing is a regulatory matter and the insurance companies set their own guidelines and don't necessarily follow the regs for doing so. The fact that you must follow regs to be covered doesn't mean they don't also have additional requirements of their own. The requirement for time in type or CFI sign off is one of those.

None of this means you can't do it, only that if they found out they would deny coverage on an incident in which it took place.

Larry
 
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I feel like we all might be talking about a lot of separate issues here.

1.) If you are practicing IFR in VFR conditions and the safety pilot is rated in category and class: single engine land. The pilot practicing IFR is acting PIC. The safety pilot does not need to meet the OPW or be approved because he is not the acting PIC. (I realize in the FAA?s eyes the safety pilot can log time too, however the insurance company is more interested in who?s actually flying and who is logged as PIC for the flight.) (I?ve spoken with underwriters from AIG, Global and Old Republic about this and they all agree with this.)

2.) A CFI should be approved by the insurance company when operating the aircraft as Pilot in Command when he/she does not meet the open pilot warranty. Here is an example. I am the CFI and you are the aircraft owner of a Cessna 182RG. Your Flight review has not expired, but you want to get it done before the renewal date. During the flight, you are the PIC. Let?s say you come to me after the FR has expired. Now I, as the CFI, am PIC because you no longer meet the FAA requirements. If the OPW requires 25 hours in a 182RG and I don?t have it, you should contact the insurance company to have me approved for the Flight Review.

Does this clarify things? Feel free to call the office to discuss: 877-475-5860

(Please keep in mind that all claims are handled on a case-by-case basis)
 
Listen to Shanna, she is the expert. A basic Med pilot riding along as a safety pilot on an instrument currency ride in VFR conditions is NOT OK, because that makes her/he a required crewmember, and she/he can’t be listed as PIC. If conditions are IFR and the flying pilot is no longer current, then the safety pilot is PIC (no basic med), but she needs to be IFR current and qualified in type to act as safety pilot. Also, if she is PIC, she needs to have full controls on the airplane - not usually the case with Vans tandem airplanes.

According to AOPA: If you don't have a current medical, you can still provide flight instruction as long as you are not acting as PIC or as a required pilot flight crewmember. You can't act as a safety pilot because that would make you a required flight crewmember, but you can instruct someone who is at least a private pilot, is current, has a medical, and is qualified to fly the aircraft you are instructing in. And yes, you can get paid for your flight instruction services.


If a basic med CFI pilot is giving you a BFR, does she/he need to be PIC? Nope, not as long as you are current and qualified in type and flight conditions, and yes, she/he can legally charge you for her services.

Pretty confusing isn’t it??
 
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To confuse things a little more - lets say you are a basic med pilot (me) and you need instrument currency flights to stay current. Your airplane partner (mine) is an IFR current A350 pilot, also current and qualified in our RV8. Can he provide safety pilot duty on my instrument currency flights. You betcha! Can I provide safety pilot duties on our RV8 proficiency flights?? You betcha, again. I’m not providing IFR currency for an IPC, but simply providing eyeballs for traffic, etc, for him to gain proficiency in IFR flying in our RV8, and he is legally PIC. See the difference? He is current, qualified in the RV8, and merely gaining proficiency in IFR RV8 flying, since it’s a little different than his A350. He is not doing an IPC - that was covered in his latest sim training.

Still pretty confusing,.....

I hope I have it right..... Shanna??
 
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To clarify - an instructor doesn?t need to have a medical (on basic med), unless they are PIC, or a required crewmember. But - if they are doing a BFR, or IPC that is signed off, their CFI needs to be current...
 
A basic Med pilot riding along as a safety pilot on an instrument currency ride in VFR conditions is NOT OK, because that makes her/he a required crewmember, and she/he can?t be listed as PIC.

Please cite a FAR on this.

I disagree because:
1) the safety pilot need not be PIC.
2) Basic med pilots may be PIC.
3) Basic med pilots may be IR rated and current.
 
To confuse things a little more - lets say you are a basic med pilot (me) and you need instrument currency flights to stay current. Your airplane partner (mine) is an IFR current A350 pilot, also current and qualified in our RV8. Can he provide safety pilot duty on my instrument currency flights. You betcha! Can I provide safety pilot duties on our RV8 proficiency flights?? You betcha, again. I’m not providing IFR currency for an IPC, but simply providing eyeballs for traffic, etc, for him to gain proficiency in IFR flying in our RV8, and he is legally PIC. See the difference? He is current, qualified in the RV8, and merely gaining proficiency in IFR RV8 flying, since it’s a little different than his A350. He is not doing an IPC - that was covered in his latest sim training.

Still pretty confusing,.....

I hope I have it right..... Shanna??

You state here that it is ok for you (basic med pilot) to provide safety pilot duties on your RV-8. Maybe you missed all of the dialog on this subject, but the FAA clearly says you cannot provide safety pilot duties for IFR practice approaches in VMC conditions without a valid medical, eventhough your role is just looking out the window. Don't care what shanna says as she doesn't work for the FAA. If your insurance provider finds that you violated a FAR, I am quite sure they will deny coverage for claims under those conditions. Pretty sure that is spelled out in most policies.

Two distinct issues here. What the FAA requires to be legal and what an insurer requires under the conditions of their policy. The two are not connected and not the same.

Larry
 
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Please cite a FAR on this.

I disagree because:
1) the safety pilot need not be PIC.
2) Basic med pilots may be PIC.
3) Basic med pilots may be IR rated and current.

Pls use the search. This has been discussed here several times and there are numerous references to the FAA's position on this.

Larry
 
Whoa, we?ve got a lot of different scenarios happening in this thread. :eek:

If you have a specific scenario you would like to discuss, please feel free to reach out to us or your current broker. It?s not possible for me to provide clarification on every scenario out there with a blanket statement in one post, because there are too many variables.

I am not an FAA/FAR expert (nor claim to be). You should ALWAYS be compliant with the FAA regulations. As Larry stated, coverage can be voided if you violate a FAR. Generally when I reply, I am only referring to how the insurance companies view a given situation.

I did not post anything regarding Basic Med because in general, the insurance companies feel if you are complying with the FAA regulations then you are fine. And if not, they spell it out in the policy.

Sometimes insurance companies are more strict than the FAA and require more than what the FAA does. That?s when you need to pay attention to your policy or ask your broker questions. A good example of this, is when insurance companies require a CFI to meet certain minimum requirements before approving them to provide instruction in the insured aircraft. The CFI may be perfectly qualified in the FAA?s eye but not meet the standards of your insurance policy and therefore void coverage.

Another example where you could be operating your aircraft in accordance with the FAA but not the insurance company, is by getting compensated for providing a service. Even if you have a LODA, and are able to get paid per the FAA, your personal use policy (most common policy) would be voided. These ?Pleasure and Business? policies are designed for personal use and prohibit compensation. If you are getting paid for a service for the use or instruction in your aircraft you likely need a different policy. Again, blanket statements here, and there are many different companies with different policy terms, so double check with your broker if you are considering getting compensated for the use of your aircraft.

There are too many examples of the insurance companies being more strict than the FAA to list them all. If in doubt, ask your broker.

Again, my best advice would be to ALWAYS comply with the FAA and then double check with your broker to make sure you are meeting the insurance requirements as well.
 
Please cite a FAR on this.

I disagree because:
1) the safety pilot need not be PIC.
2) Basic med pilots may be PIC.
3) Basic med pilots may be IR rated and current.

I think you both are technically right to a degree:

Part 61.3 states:
(c) Medical certificate.
(1) A person may serve as a required pilot flight crewmember of an aircraft only if that person holds the appropriate medical certificate issued under part 67 of this chapter, or other documentation acceptable to the FAA, that is in that person's physical possession or readily accessible in the aircraft. Paragraph (c)(2) of this section provides certain exceptions to the requirement to hold a medical certificate

A safety pilot is a required crew member per part 91.109 (b).

So an FAA Medical is required by the safety pilot UNLESS the safety pilot is also acting as PIC (see the attached FAA BasicMed FAQ link for why that is -- BLUF it's in the legislation that authorizes BasicMed).
https://www.faa.gov/licenses_certificates/airmen_certification/basic_med/media/basicmed_faq.pdf
 
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