Logging PIC vs SIC.

[tail low]

Hello.

After advice on the legalities of logging PIC time flying on FAA / N registered business jet.

Hold a command rating for the type being flown. Am I able to log PIC time from the right seat when I am pilot flying? (P1 / P2 crew)

Many Thanks.

[Globally Challenged]

Who is signing the tech log?

[PukinDog]

...deleted

[westhawk]

Under FAR 61.51, any time flown as the sole manipulator of the controls of an aircraft for which one is rated to act as PIC may be logged as PIC time. Many airlines and other employers have little interest in how much time one has spent manipulating the controls when they ask for an accounting of time spent "acting as the PIC". They want to know how many hours have been spent as the designated PIC. (part 1 definition) To "act as the PIC" is different than how the time is to be logged under 61.51.

Other operators, insurance companies, safety audit firms and the FAA itself make no distinction between the two definitions of "PIC time" for reporting purposes.

This presents somewhat of a quandary for certain FAA certificated pilots preparing themselves for submitting airline applications. To qualify for certain FAA issued certificates and ratings that specify minimum PIC times, any time spent in flight as "sole manipulator" may be logged as PIC as per 61.51. As stated previously, this same standard is commonly used by many other organizations with regard to reporting.

But then when the airline applicant goes to report their PIC time on an airline application, the airline specifies that for the purpose of the application, "PIC time means time during which the pilot was 'designated' or 'assigned' as 'THE PIC'." (there can only be one at a time!) So now the applicant has to go back and determine how much of their logged "PIC time" occurred when they were actually "THE PIC" The airline isn't interested in that 61.51 "sole manipulator" brand of "PIC time".

So here's what I suggest potential airline candidates do about logging PIC time. Do both! Log PIC according to 61.51 AND separately log time spent as "THE PIC". (part 1 definition) A separate column in the logbook or just asterisk the part 1 PIC time so it can be separated from the "sole manipulator" PIC time and added up at any time.

So to summarize, PIC time may be logged as long as it meets the stipulations of part 61.51. Some airlines and other operators may only be interested in how much of that time was spent "as "THE PIC". (part 1 definition)

I hope that helps.

[Welle]

.....same problem in EASA biz jet part of the world...
I have seen operations with two cpts on the flightdeck, where everyone logged PIC time....(let it be ignorance of the rulez or the urgent personal need to log PIC time)
many pilots just start to log PIC time, as soon as they have their ATP issued.
(only exception imo: actual LPC on the aircraft -here the TRE in the RHS can log PIC time as well as the CDR in the LHS)

I have also questioned resumes with missing SIC times on type - some with 0hrs SIC time for a specific rating - so how did the pilot perform his EASA base training, as a PIC, when the rating was not even entered in the licence yet..

my2cents
welle

[tail low]

Thank you for the feedback. Pasted extract from FAR 61.51 below..

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

(ii) When the pilot is the sole occupant in the aircraft;

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

(1) Preflight preparation;

(2) Preflight procedures;

(3) Takeoff and departure;

(4) In-flight maneuvers;

(5) Instrument procedures;

(6) Landings and approaches to landings;

(7) Normal and abnormal procedures;

(8) Emergency procedures; and

(9) Postflight procedures;

(C) The supervising pilot in command holds—

(1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

(2) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.

(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

(3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

(4) A student pilot may log pilot-in-command time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

(ii) Has a solo flight endorsement as required under §61.87 of this part; and

(iii) Is undergoing training for a pilot certificate or rating.

(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:

(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or

(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.

[PukinDog]

Under FAR 61.51, any time flown as the sole manipulator of the controls of an aircraft for which one is rated to act as PIC may be logged as PIC time. Many airlines and other employers have little interest in how much time one has spent manipulating the controls when they ask for an accounting of time spent "acting as the PIC". They want to know how many hours have been spent as the designated PIC. (part 1 definition) To "act as the PIC" is different than how the time is to be logged under 61.51.

Other operators, insurance companies, safety audit firms and the FAA itself make no distinction between the two definitions of "PIC time" for reporting purposes.

This presents somewhat of a quandary for certain FAA certificated pilots preparing themselves for submitting airline applications. To qualify for certain FAA issued certificates and ratings that specify minimum PIC times, any time spent in flight as "sole manipulator" may be logged as PIC as per 61.51. As stated previously, this same standard is commonly used by many other organizations with regard to reporting.

But then when the airline applicant goes to report their PIC time on an airline application, the airline specifies that for the purpose of the application, "PIC time means time during which the pilot was 'designated' or 'assigned' as 'THE PIC'." (there can only be one at a time!) So now the applicant has to go back and determine how much of their logged "PIC time" occurred when they were actually "THE PIC" The airline isn't interested in that 61.51 "sole manipulator" brand of "PIC time".

So here's what I suggest potential airline candidates do about logging PIC time. Do both! Log PIC according to 61.51 AND separately log time spent as "THE PIC". (part 1 definition) A separate column in the logbook or just asterisk the part 1 PIC time so it can be separated from the "sole manipulator" PIC time and added up at any time.

So to summarize, PIC time may be logged as long as it meets the stipulations of part 61.51. Some airlines and other operators may only be interested in how much of that time was spent "as "THE PIC". (part 1 definition)

I hope that helps.


Nice summary westhawk on a subject that understandably causes great confusion, and your recommendation to carry a breakdown of "Manipulator" vs operational "Signed for the aircraft/listed on the flight plan" PIC times is right on.

Some other entities that will only recognize Operational PIC (for lack of a better term) include many non-FAA Aviation Authorities. For those who ever go on to do a license conversion abroad in addition to that country's written testing it's the norm to provide a flight time breakdown and in some cases submit logbooks/or copies for their approval. Because most non-FAA Authorities don't have a similar version of 61.51 "manipulator" PIC time, keeping it in a separate column and submitting only operational PIC time is recommended. For any employer abroad, same deal.

Another difference between FAA time-logging vs. Others abroad is what constitutes Instrument Time. Again, from 61.51:

(1) A person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=4&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) may log instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=6&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) time only for that flight time (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=f0aec8c5355fdf7ac5b33f45b2ace9af&term_occur=9&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) when the person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=5&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) operates the aircraft (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=8e9caab04f792d93d0738c9d3290164e&term_occur=24&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) solely by reference to instruments (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=8&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) under actual or simulated instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=7&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) flight conditions.

In other words, Instrument Time is that which is flown in IMC (actual or simulated, solely by reference to the instruments). FAA Instrument Time is like Night hours, a description of conditions of flight. As a general rule of thumb in an FAA logbook using the FAA's criteria, Instrument Time (actual IMC) usually (not to say always) represents about 10% to 20% of Total Flight Time unless at some point the pilot spent an inordinate amount of hours operating at low altitudes in regions where IMC conditions can prevail for weeks or a season.

However, outside of FAA-land most pilots are logging as Instrument Time 100% of all hours operating on an IFR flight plan, even if it was entirely conducted in VMC. Logbooks where 70% or 80% of Total Time is categorized as Instrument Time aren't uncommon, with professional crews logging 100% of flight time as Instrument Time even if between Dubai and Perth they only spotted 2 clouds 30,000' below them 50 miles away. Is it wrong?..not for their Authority's logging criteria, but for all that Instrument Time in the logbook what the FAA actually wants to know (experience operating in IMC) is invisible. For reference for Authorities/employers abroad, in an FAA logbook one could also keep an additional, "operational" Instrument Time column showing all hours flown while on an IFR fight plan.

[westhawk]

Good additions to the summary PD!

These are things that only come to be understood in increments, following much discussion, numerous re-readings of the regs, or sometimes having to go back and correct or modify previous log entries to align them with accepted practices. The differences in interpretation of definitions applicable to regulations, the differences between national regulators definitions and interpretations and the complex nature of keeping all of this straight conspire to create more than just a little confusion and contentiousness among the troops. Sometimes it can look allot like a cat chasing it's tail.

If I had it do all over again, I'd enter every flight in a very detailed computer spreadsheet in a format that could be expected to be importable to future logbook apps. All the work I put into creating computer records of my flight experience in the past has essentially been wasted because the data was entered into records whose format is incompatible with later (presently supported) logbook software. Never again. Fortunately, my old-school paper logbook records have been maintained and backed up by scanning them into computer files in case I ever need to re-construct them.

With that said, there are several very capable computer logbook programs/apps/software available these days that can accommodate user-specified custom fields in addition to an already comprehensive array of flight time categories. At any time, reports can be generated according to user-specified search parameters. You can easily find all the flight time logged in a particular type, flight condition or rules as long as these parameters were specified and filled when entered. And you can go back and edit the original record if it wasn't. The latest trend is for certain flight planning/filing service providers to incorporate pilot flight time logging into it's ever-growing list of services and features.

Use whatever services, apps or software seems most appropriate to fit your needs, but I recommend two things:
1) Always keep your paper logbook up to date, including all endorsements. Store backup images of all pages both offline and online.
2) Make sure the software version of your logbook uses a file format that will be retrievable by future software in case the company who sold you the logbook program dries up and blows away in the winds of change!

[rudestuff]

I think the 'sole manipulator' line is open to interpretation: Are these people throwing their own gear and flaps? It would suggest that they are operating a mult crew airplane single pilot and the other guy/girl is just sitting on their hands....

[arketip]

I have also questioned resumes with missing SIC times on type - some with 0hrs SIC time for a specific rating - so how did the pilot perform his EASA base training, as a PIC, when the rating was not even entered in the licence yet..

my2cents
welle

Maybe he didn't because he was not required to?

[Welle]

Maybe he didn't because he was not required to?

Hy - yes there is a possibility for an EASA CAA to credit the Base Training in case you can proove 500 flight hours on the new type on a foreign licence. (maybe this nr. changed in the meantime)

However it is very unlikely to see a CV with only PIC hours for a certain type.
How did the pilot perform his landing training?
How did the pilot perform his supervision on the new type?

[arketip]

Hy - yes there is a possibility for an EASA CAA to credit the Base Training in case you can proove 500 flight hours on the new type on a foreign licence. (maybe this nr. changed in the meantime)

However it is very unlikely to see a CV with only PIC hours for a certain type.
How did the pilot perform his landing training?
How did the pilot perform his supervision on the new type?

There was aviation before EASA.

When I received my rating it was immediately written in the licence, no flying under supervision required.
It can be unlikely to have no SIC time, but not impossible.

[Welle]

There was aviation before EASA.

When I received my rating it was immediately written in the licence, no flying under supervision required.
It can be unlikely to have no SIC time, but not impossible.

off -- course there was aviation before (and might be thereafter) - but let´s not get too deep into EASA bashing...

@ no SIC hrs: when I was questioning missing SIC hours, most pilots found out they needed to amend their cv. Many folks are just not aware, that there can be only one PIC on the flight deck (EASA) at one time...

@ no SIC hours: yes..., off course it´s possible: I had a customer/pilot with his own glex, off course he logs PIC hrs only..

rgds
welle

[selfin]

In other words, Instrument Time is that which is flown in IMC (actual or simulated, solely by reference to the instruments).

Actual instrument time is logged when actual instrument conditions exist which could be in VMC.

[EatMyShorts!]

You log "instrument time" as long as you are operating an IFR-flight, from takeoff until landing. Why? Because you fly according to your instruments as primary means of reference and navigation. Easy.

[BizJetJock]

Yes, the problem in the real world is stopping people flying soleley on the instruments and getting them to look out the window when it is appropriate!

[megan]

Don't know if this offers you any enlightenment.

https://www.faa.gov/about/office_org/field_offices/fsdo/sdl/local_more/avsafety_program/media/LOGGING%20PILOT-IN-COMMAND%20TIME.pdf

[arketip]

@ no SIC hours: yes..., off course it´s possible: I had a customer/pilot with his own glex, off course he logs PIC hrs only..

rgds
welle

No need to own the aircraft to log PIC only

[PukinDog]

You log "instrument time" as long as you are operating an IFR-flight, from takeoff until landing. Why? Because you fly according to your instruments as primary means of reference and navigation. Easy.

Your personal interpretation of FAA regs notwithstanding, not correct if you're logging by FAA criteria for the purposes for FAA record-keeping. Just in case you had trouble reading it before, again, from 61.51..

(1) A person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=4&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) may log instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=6&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) time only for that flight time (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=f0aec8c5355fdf7ac5b33f45b2ace9af&term_occur=9&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) when the person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=5&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) operates the aircraft (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=8e9caab04f792d93d0738c9d3290164e&term_occur=24&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) solely by reference to instruments (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=8&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) under actual or simulated instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=7&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) flight conditions.

Easy.

Just because Instrument time is logged differently elsewhere doesn't change the FAA's criteria. No use arguing about it.

[PukinDog]

I think the 'sole manipulator' line is open to interpretation: Are these people throwing their own gear and flaps? It would suggest that they are operating a mult crew airplane single pilot and the other guy/girl is just sitting on their hands....

Of course you do. In my experience those who learn and operate elsewhere, upon their first exposure to FAA regs, believe just about every one of them is open their their own interpretation if it doesn't mirror their homeland regs/interpretations exactly. Some, however, are a lot more insistent about it.

[EatMyShorts!]

Ok, but this is exactly what I wrote:
(1) A person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=4&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) may log instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=6&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) time only for that flight time (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=f0aec8c5355fdf7ac5b33f45b2ace9af&term_occur=9&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) when the person (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=24a80ca42ed148d527b7ddad982da95a&term_occur=5&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) operates the aircraft (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=8e9caab04f792d93d0738c9d3290164e&term_occur=24&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) solely by reference to instruments (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=8&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) under actual or simulated instrument (https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=7fe5a7765bc41dd93adc4e9d5f03ea31&term_occur=7&term_src=Title:14:Chapter:I:Subchapter:D:Part:61:Subpart:A:6 1.51) flight conditions. when you are operating your aircraft under instruments, and that is, by definition true for 100% of the flight time, when you are flying under IFR-rules. Or do you fly IFR and say "oh, look, that mountain is near the "Mountain View VOR", let's fly there, must be right :D

[westhawk]

The idea is simple. For FAA logging purposes, instrument time may be logged when the airplane is flown solely by reference to instruments. In the FAA universe, this means there is no outside visual reference available to the pilot. This is either because a view-limiting device is being used in the case of "simulated instrument time" or because meteorological conditions of limited visibility prevail during "actual instrument time". Black of night doesn't count.

As a practical matter, all jet flying is instrument flying if you're doing it right! Even when there's something useful to see out the windshield, the airplane is still controlled by reference to instruments AND whatever useful information can be sensed by looking out the window. How you do it and how you log it are not the same thing.

But if the question is what may be logged as "instrument time" under FAA rules, please see paragraph 1.

[westhawk]

For FAA logging purposes, the "sole manipulator of the flight controls" means the person who is controlling the attitude, speed and direction of the aircraft. This is the "Pilot Flying". And yes, it counts while the autopilot is engaged too. The other pilot operating secondary controls and appliances, radios etc is most often referred to as the "Pilot Monitoring" in most two-pilot operations these days. They are not the "sole manipulator" and may not log "PIC time" or "instrument time" while performing PM duties. Of course if they are the designated PIC, then they log ALL the time as PIC. If they are acting as the SIC, but they are also the PF, then under 61.51 they may log "sole manipulator" time as "PIC time" if they are rated in the aircraft. Any "instrument time" or "approach procedures" goes to the PF for logging purposes.

So now this should be just about as clear to everyone as Mississippi river mud!

[selfin]

Black of night doesn't count.

The Office of the Chief Counsel has a different opinion.

See para 5 in the opinion given to Joseph P Carr on 7 Nov 1984 by John H Cassady, Assistant Chief Counsel, Regulations & Enforcement Division.

To answer your first question, actual instrument conditions may
occur in the case you described, a moonless night over the ocean
with no discernible horizon, if use of the instruments is
necessary to maintain adequate control over the aircraft. The
determination as to whether flight by reference to instruments is
necessary is somewhat subjective, and based in part on the sound
judgement of the pilot. Note that, under Section 61.51(b)(3),
the pilot must log the conditions of the flight. The log should
include the reasons for determining that the flight was under
actual instrument conditions in case the pilot later would be
called on to prove that the actual instrument flight time logged
was legitimate.

Archived as Legal Interpretation # 84-29 in a set of Chief Counsel opinions on logging time available here: http://www.offhand.org/amb/pic-time.txt

[westhawk]

Thanks for that FAA legal council interpretation reference selfin. I had not seen that one before. I guess black of night could indeed be counted legitimately, so long as it was subjectively determined by the PIC that reference to instruments was required in order to control the aircraft absent adequate visual reference. If I ever log instrument time for that reason, I'll be sure to explain my reasoning in the comments block. :) I know I myself have certainly had to fly strictly by instrument reference in what passes for VMC on many occasions. Live and learn!

[megan]

I think Australia is probably unique in that we have a night VMC classification. Following a number of tragic accidents where folks died because they didn't have the instrument skills on absolutely black, black nights they introduced a ruling that for night VMC there must be a discernible horizon. From experience I know that being over water on a pitch black overcast night with no celestial lighting you can't get more IMC.

https://www.casa.gov.au/standard-page/project-os-1401-night-visual-flight-rules-amendment-require-discernible-external

[B-757]

Ok, but this is exactly what I wrote:
when you are operating your aircraft under instruments, and that is, by definition true for 100% of the flight time, when you are flying under IFR-rules. Or do you fly IFR and say "oh, look, that mountain is near the "Mountain View VOR", let's fly there, must be right :D

..As others have already stated, under FAA rules you can log instruments ONLY if you are flying in IMC conditions, or, under simulated instrument conditions (such as a view limiting device. hood f.ex during training)..If you are on an IFR flight plan, in VMC conditions, you cannot log that as instrument time in the US..Period..EU land is different..I have an ATPL from 3 continents (including US and EU) so have gone through these issues many times before..

..I believe the question about logging PIC time was already discussed..

Fly Safe !!
B-757

[selfin]

...under FAA rules you can log instruments ONLY if you are flying in IMC conditions

That interpretation does not follow from the regulation provided in post 19 by PukinDog.

IMC (absent from the regulation) simply means the VFR minimums in 14 CFR 91.155 aren't met whereas the logging rule refers to actual instrument conditions which exist when "use of the instruments is necessary to maintain adequate control over the aircraft" (interpretation to Carr, see post 24).

[B-757]

That interpretation does not follow from the regulation provided in post 19 by PukinDog.

IMC (absent from the regulation) simply means the VFR minimums in 14 CFR 91.155 aren't met whereas the logging rule refers to actual instrument conditions which exist when "use of the instruments is necessary to maintain adequate control over the aircraft" (interpretation to Carr, see post 24).
..Yes this is true also, thanks..The interest of my post was directed towards the EU guys, some rules are different there..

Fly safe
B-757