Originally Posted by
421C
I take back my earlier point. ca_flyer, thanks for your patience, at least I have learned something. More careful reading of 61.55 (especially subpart (d) which refers to Safety Pilots) makes it clear that the Safety Pilot is a required crewmember in the Second-In-Command sense, and that means he must be current etc, and meet other SIC requirements except those that 61.55f4 says are not needed.
Maybe I'm just being exceedingly thick this morning, but my reading of 61.55(d)(4) says that the SIC regulations don't apply to safety pilots as discussed in this thread.
So I reckon you were right the first time. There is no regulation that says a safety pilot as described in 91.109 has to be current
unless he is acting as PIC. An argument has been put forward that he needs to be able to take over as PIC at any time, so must be qualified to be PIC. Well, that's stretching it. If you needed to be current as a part 91.109 safety pilot then why not say that in the regs? Does a 737 co-pilot in a part 121 operation need an ATP just in case the captain dies and the co-pilot SIC needs to take over? Nope, just a CPL, which doesn't allow you to be PIC in that sort of operation.