According to this interpretation, you can log it as PIC. Refer to the bold part. Would I do it? No.
Dear Mr. :
Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)
You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.
You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.
Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.
There is a distinction between actingas pilot in command and loggingof pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:
