Editor's note: Effective December 22, 2022, the FAA amended various provisions within Part 61 and Part 68 to make BasicMed pilots eligible to act as safety pilots (required crewmembers other than the PIC)

“Can I fly under BasicMed and act as a safety pilot?” is a common question, and for good reason because the answer is, well, it depends.  But with a quick review of what it means to act as a safety pilot and the relevant limitations of BasicMed, pilots flying under these rules may find it easier to determine when they can act as a safety pilot. 

Initially, recall that a pilot is only a “safety pilot” during simulated instrument flight under FAR 91.109(c).  This rule states in part that no person can operate an aircraft in simulated instrument flight unless “the other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.” With limited exceptions, the safety pilot must have adequate vision forward and to each side of the aircraft, which is to be equipped with fully functioning dual controls.

With the definition of a safety pilot in mind, consider a flight in simulated instrument conditions where Pilot A is under the hood and is acting as Pilot in Command (PIC), and Pilot B is acting as safety pilot in the other seat.  Pilot B’s presence is required under FAR 91.109(c) for the portion of the flight that Pilot A is in simulated instrument flight, so Pilot B is then referred to under the regulations as a “required pilot flight crewmember.”

Now for the critical limitation: under federal law, BasicMed only applies to a pilot acting as PIC and does not apply to required pilot flight crewmembers like the safety pilot in the example above.  When acting as a required pilot flight crewmember, FAR 61.3(c) requires the safety pilot to have a valid and appropriate medical certificate.

The simple solution for a BasicMed pilot who wants to act as a safety pilot under FAR 91.109(c) without a medical certificate is to meet all currency and qualification requirements to act as PIC, and to act as PIC during the portions of the flight in simulated instrument conditions.  Even though the pilot under the hood cannot simultaneously act as PIC, the simulated instrument flight still satisfies that pilot’s recent flight experience requirements for a PIC under FAR 61.57, since that regulation does not require the pilot to be acting as PIC while he or she performed the required tasks during the simulated instrument flight.

Importantly, note that whenever a BasicMed pilot acts as PIC, then the entirety of the flight from takeoff to full-stop landing must be conducted within the flight condition limitations of BasicMed.  The FAA has stated that this limitation applies even if another qualified pilot holding a medical certificate is also present and able to act as PIC.  Finally, be sure to confirm that the aircraft limitations do not restrict the PIC to the left seat, and that anyone acting as PIC meets all applicable insurance requirements.