How to log PIC time under FAA rules (PIC vs SIC)

For the first eight years of my career there was no second seat to log. I instructed from 2000 and flew single-pilot in the bush from 2001. From 2003 I flew an FAA-registered King Air in the Canadian Arctic, on a contract for a Canadian geophysics company. Almost everything in my log was PIC or dual. In 2008 I moved to the right seat of a Dash 8-400 at a Canadian commuter airline, and in 2009 I upgraded to the left seat.

As a first officer, I never logged PIC. Under the Canadian rules I flew by, it would have been false. Under the FAA’s rules it could have been legal, and I still wouldn’t have done it. This article sets out what the FAA allows, and where I draw my own line.

What’s the difference between acting as PIC and logging PIC?

Acting as PIC is a job. The pilot in command is the person who has final authority and responsibility for the operation and safety of the flight, has been designated PIC before or during the flight, and holds the category, class and type rating for it (14 CFR 1.1). One pilot holds that job at a time.

Logging PIC follows its own list, in 61.51(e) (14 CFR 61.51). The FAA’s Chief Counsel put the difference plainly in 1993: “while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously” (Hicks interpretation (1993)).

When can you log PIC time?

Section 61.51(e) gives these routes (14 CFR 61.51):

• Sole manipulator of the controls of an aircraft you’re rated for.
• Sole occupant of the aircraft.
• Acting PIC where more than one pilot is required, by the aircraft’s type certificate or by the regulations the flight is conducted under. This route isn’t open to sport or recreational pilots.
• PIC under supervision, inside an approved PIC training program (see What is PIC under supervision in the US?).
• An ATP acting as PIC of an operation that requires an ATP certificate, for all the flight time.
• A flight instructor, for all the time spent as the authorized instructor, if rated to act as PIC of the aircraft.

“Rated” means the aircraft ratings on your certificate: category, class, and type where the aircraft needs one (Herman interpretation (2009)). It doesn’t mean everything you’d need to act as PIC. A private pilot without a complex or high-performance endorsement can log PIC as sole manipulator of that aircraft while another pilot acts as PIC (Herman interpretation (2009)). A pilot without an instrument rating can log PIC as sole manipulator on an IFR flight while an instrument-rated pilot acts as PIC (Speranza interpretation (2009)).

Student pilots have one route only. A student may log PIC only as sole occupant, with a solo endorsement, while training for a certificate or rating (14 CFR 61.51). A dual lesson isn’t PIC time for a student, however much of it they fly.

A certificated pilot who flies a lesson in an aircraft they’re rated for logs it both ways: PIC as sole manipulator, and training received from an authorized instructor (14 CFR 61.51). The instructor logs PIC too.

When I instructed in Canada, I logged my instructing time as PIC and nothing else. My paper logbook had no spare column for instruction given, so that number was never kept. Today I’d log it as PIC and keep instruction given in a column of its own.

Can two pilots log PIC on the same flight?

Yes, when each has a route of their own:

• In a single-pilot aircraft, a rated pilot who is sole manipulator logs PIC for that time. The pilot acting as PIC beside them can’t log PIC for the same time: only one pilot is required, so 61.51(e) gives the acting PIC no route (Speranza interpretation (2009)).
• In an aircraft or operation that requires two pilots, the acting PIC logs PIC for all of it. The other pilot, if rated for the aircraft, logs PIC for the time they’re sole manipulator (14 CFR 61.51) (Counsil interpretation (2012)). That’s the first officer’s case.
• With a safety pilot, it depends on who agreed to act as PIC, which the next section covers.

How does a safety pilot log time?

Simulated instrument flight needs a safety pilot in the other control seat, holding at least a private pilot certificate with the right category and class ratings (14 CFR 91.109). That makes the safety pilot a required crewmember while the view-limiting device is on, and only then. What each pilot logs depends on what they agreed before the flight:

• If the safety pilot acts as PIC, they log PIC for the time the other pilot is under the hood. The pilot flying logs PIC for the whole flight as sole manipulator. In the FAA’s example, that’s 2.0 hours for the safety pilot and 2.2 for the pilot flying (Gebhart interpretation (2009)).
• If the pilot under the hood acts as PIC, only they log PIC. The safety pilot logs SIC for the hood time (Trussell interpretation (2012)).
• Either way, the safety pilot can’t log cross-country time, because they aren’t a required crewmember for the whole flight (Gebhart interpretation (2009)).

Whoever logs what, the entry for the flight names the safety pilot (what each FAA entry must contain) (14 CFR 61.51).

All my own hood time, first as a student and later as an instructor, had an instructor aboard. That’s a different case: the instructor was PIC, and the student logged dual.

Can a first officer log PIC time?

Under FAA rules, yes, as sole manipulator, if the first officer’s type rating for the aircraft has no “SIC privileges only” limitation. The FAA said so in 2012 to a 757/767 first officer who had flown about 2,500 hours as sole manipulator (Counsil interpretation (2012)). Both types need two pilots, so “sole manipulator” means the pilot handling the controls at the time. It doesn’t mean an aircraft certificated for one pilot. A type rating limited to SIC privileges exists so that a pilot who meets the SIC requirements can fly in international airspace. It doesn’t make that pilot “rated” for logging PIC (Counsil interpretation (2012)).

It wasn’t always so. In 1952, airline copilots couldn’t log PIC even for the time they flew the aircraft, so the Civil Aeronautics Board let copilot time spent performing a PIC’s duties count towards the ATP’s PIC requirement (Duncan memorandum (2012)). The rule still does (see What counts towards the ATP’s 250 hours of PIC?).

I never logged PIC from the right seat. Canadian rules give PIC time to the pilot in charge of the flight (when you log PIC in Canada), so for me it would have been false. Had I flown the same legs under the FAA with an unrestricted type rating, I still wouldn’t have logged it. It’s legal, and it doesn’t sit right with me.

In my experience, employers don’t define PIC any differently from the regulator, and they don’t object to time that was logged honestly. What they notice is a log that doesn’t match the pilot in front of them.

When can you log SIC time?

Normally, only when a second pilot is required. Section 61.51(f) allows SIC time (14 CFR 61.51):

• when you’re qualified as an SIC under 61.55 (14 CFR 61.55) and occupy a crewmember station in an aircraft whose type certificate requires more than one pilot;
• when you hold the category, class and instrument ratings the flight needs, and more than one pilot is required by the type certificate or by the regulations the flight is conducted under;
• in an approved Part 135 SIC professional development program under 135.99(c);
• when a government entity designates you SIC on a public aircraft operation, within limits (public aircraft SIC).

The regulations can require a second pilot in an aircraft certificated for one. Under Part 135, for example, a passenger flight under IFR needs a second in command unless the operator is approved to use an autopilot instead (14 CFR 135.101).

A company’s preference doesn’t count. A corporate Part 91 operator required two pilots in a Citation certificated for one. The FAA said the second pilot wasn’t a required crewmember, and couldn’t log SIC (Cato interpretation (2014)).

I’ve felt that pull. I’ve flown a single-pilot turbine twin with a second crew member aboard to help with loading and unloading, and I wanted to call that time SIC. It wasn’t. In Canada I’ve also flown for an operator approved to run a single-engine turbine, certificated for one pilot, as a two-crew operation, which extended the pilots’ duty day. There the approval required the second pilot, so the co-pilot’s time counted (co-pilot time in Canada).

What is PIC under supervision in the US?

A route to PIC time for a pilot performing the duties of PIC under a qualified PIC’s supervision. Section 61.51(e)(1)(iv) sets four conditions (14 CFR 61.51):

• you hold a commercial or ATP certificate with the aircraft’s category and class rating;
• you’re in an approved PIC training program, with ground and flight training in nine listed areas, from preflight preparation to postflight procedures;
• the supervising PIC holds a commercial certificate and a flight instructor certificate, or an ATP, with the aircraft’s ratings;
• the supervising PIC logs the training in your logbook, certifies it, and signs it with their flight instructor certificate number.

Without the approved program, it isn’t PIC time. In the FAA’s view, a first officer who performs PIC duties outside one logs that time as SIC (Duncan memorandum (2012)). It still counts towards the ATP, as the next section explains.

The signature is where Canadian habits differ. As a training and check pilot at a Canadian commuter airline, I was never asked to sign a candidate’s logbook. In my experience, Canadian practice doesn’t rely on validating the log itself. I upgraded to captain without using a PIC under supervision program. Canada’s version works differently, and counts at half value (PIC under supervision under the CARs).

What counts towards the ATP’s 250 hours of PIC?

An applicant for an ATP with an airplane rating needs 250 hours in an airplane “as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof”, including 100 hours of cross-country and 25 of night (14 CFR 61.159). A first officer’s time performing the captain’s duties under the captain’s supervision, logged as SIC, can count (Duncan memorandum (2012)). If you’re building towards an ATP from the right seat, I’d mark those legs in your log as you fly them, so you can show which SIC hours they were.

SIC time from a Part 135 SIC professional development program is different. It counts towards the ATP’s other experience requirements, but it can’t be logged as PIC, even as sole manipulator, and it can’t count towards the 250 hours (14 CFR 61.159).

When I converted to an FAA ATP, I had about 3,000 hours, almost all of it PIC or dual. The little SIC time I had never came into it.

How do you log relief pilot time?

Part 61 has no category for it. Section 61.51 has rules for solo, PIC, SIC and training time, and none for a relief pilot on an augmented crew (14 CFR 61.51). Whether relief time is pilot time for an FAA certificate turns on the definition in 61.1: time you serve as a required pilot flight crewmember, receive or give instruction, or serve as SIC in a 135.99(c) program (14 CFR 61.1). I haven’t found an FAA interpretation that applies it to time in the bunk.

On the 787, I logged relief time in its own column, including my time in the bunk: the pilot in the bunk is still part of the crew, and available if called. My operator gave no guidance at all. Keeping relief time in its own column means it can be counted, or left out, depending on who is asking. EASA’s rules cover it: see how to log cruise relief time under Part-FCL.

What are the most common PIC and SIC logging mistakes?

• A student logging PIC on a dual flight. Student PIC is sole occupant only.
• A first officer with an “SIC privileges only” type rating logging PIC as pilot flying.
• SIC logged in a single-pilot aircraft because the company put two pilots in it.
• A safety pilot logging cross-country time.
• PIC under supervision logged without an approved program, or without the supervising pilot’s signature and certificate number.

For what each entry in an FAA logbook must contain, and who can ask to see it, see FAA pilot logbook requirements.