IFR logging question - is this legal?

Jose wrote:
If you are a VFR only pilot, and want to log some instrument PIC time,
and conditions are IMC, you would need the hood to comply with
91.109(b). You could not BE PIC, but you do not need a CFII either.
You can have an instrument rated safety pilot BE PIC while you, as sole
manipulator, log PIC time. You need IR pilot (who also happens to be
the safety pilot) as PIC for the flight to be legal IFR, and you need
the safety pilot (who also happens to be the PIC) to be a crew member
because when you have the hood on, you need somebody to look outside.

There is no regulation in the above proposal that requires multiple
pilots (the requirement for the non-flying pilot to log PIC under
61.51(e). The FAR that requires multiple pilots says "simulated
instrument conditions".

91.109(b) No person may operate a civil aircraft in simulated
instrument flight unless-
(1) 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.