AMC 20-29

AMC 20-29 Effective: 26/07/2010

Annex II to ED Decision 2010/003/R of 19/07/2010

AMC 20-29
Composite Aircraft Structure

0. TABLE OF CONTENTS
1. PURPOSE............................................................................................................. 2
2. OBJECTIVE .......................................................................................................... 2
3. APPLICABILITY................................................................................................... 2
4. RELATED REGULATIONS AND GUIDANCE ............................................................ 2
5. GENERAL............................................................................................................. 2
6. MATERIAL AND FABRICATION DEVELOPMENT .................................................... 3
A. MATERIAL AND PROCESS CONTROL .......................................................................... 3
B. DESIGN CONSIDERATIONS FOR MANUFACTURING IMPLEMENTATION .................................... 4
C. STRUCTURAL BONDING ....................................................................................... 5
D. ENVIRONMENTAL CONSIDERATIONS ......................................................................... 6
E. PROTECTION OF STRUCTURE ................................................................................. 7
F. DESIGN VALUES ............................................................................................... 7
G. STRUCTURAL DETAILS......................................................................................... 7
7. PROOF OF STRUCTURE – STATIC......................................................................... 8
8. PROOF OF STRUCTURE – FATIGUE AND DAMAGE TOLERANCE........................... 11
A. DAMAGE TOLERANCE EVALUATION......................................................................... 11
B. FATIGUE EVALUATION ....................................................................................... 19
C. COMBINED DAMAGE TOLERANCE AND FATIGUE EVALUATION ........................................... 19
9. PROOF OF STRUCTURE – FLUTTER AND OTHER AEROELASTIC INSTABILITIES . 19
10. CONTINUED AIRWORTHINESS .......................................................................... 19
A. DESIGN FOR MAINTENANCE ................................................................................ 20
B. MAINTENANCE PRACTICES .................................................................................. 20
C. SUBSTANTIATION OF REPAIR ............................................................................... 21
D. DAMAGE DETECTION, INSPECTION AND REPAIR COMPETENCY ......................................... 21
11. ADDITIONAL CONSIDERATIONS ....................................................................... 22
A. CRASHWORTHINESS ......................................................................................... 22
B. FIRE PROTECTION, FLAMMABILITY AND THERMAL ISSUES .............................................. 23
C. LIGHTNING PROTECTION .................................................................................... 25
APPENDIX 1 - APPLICABLE CSS AND RELEVANT GUIDANCE ..................................... 27
APPENDIX 2 – DEFINITIONS .................................................................................... 30
APPENDIX 3 - CHANGE OF COMPOSITE MATERIAL AND/OR PROCESS...................... 33

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 AMC 20-29

1. PURPOSE
This AMC provides an acceptable means, but not the only means, for airworthiness certification
of composite aircraft structures. Guidance information is also presented on the closely related
design, manufacturing and maintenance aspects. This AMC primarily addresses carbon and
glass fibre reinforced plastic structures, although many aspects of this document are also
applicable to other forms of structure, e.g. metal bonded structure, wooden structure, etc.

Note: When applying this guidance to other forms of structure, additional design
considerations may be necessary and other appropriate references should also be consulted.

2. OBJECTIVE
AMC 20-29 standardises recognised good design practices common to composite aircraft
structures in one document.
For rotorcraft, AMC 20-29 complements existing AMC to CS-27 and CS-29 (referring to FAA AC
27-1B MG8 and AC 29-2C MG8).

3. APPLICABILITY
This AMC provides Acceptable Means of Compliance with the provisions of CS-23, CS-25, CS-
27 and CS-29. Many of the concepts included in this AMC may also be applicable in part or in
full to other CSs. However, when using this AMC as an Acceptable Means of Compliance for
these other CSs, appropriate engineering judgement should be exercised and early agreement
with the Agency sought.

This AMC applies to: applicants for a type-certificate, restricted type-certificate or

supplemental type-certificate; certificate/approval holders; parts manufacturers; material
suppliers; and maintenance and repair organisations.

Note: The technical content of this AMC is harmonised with FAA Advisory Circular AC 20-107B,
dated 8 September 2009.

4. RELATED REGULATIONS AND GUIDANCE

a. Applicable paragraphs are listed in Appendix 1.

b. Relevant guidance considered complementary to this AMC is provided in Appendix 1.

5. GENERAL
a. The procedures outlined in this AMC provide Acceptable Means of Compliance and
Guidance Material for composite structures, particularly those that are essential in
maintaining the overall flight safety of the aircraft (“critical structure” as defined in
Appendix 2). This AMC is published to aid in the evaluation of certification programmes
for composite applications and to reflect the current status of composite technology. It is
expected that this AMC will be modified periodically to reflect the continued evolution of
composite technology and the data collected from service experience and expanding
applications.

b. There are factors unique to the specific composite materials and processes used for a
given application. For example, the environmental sensitivity, anisotropic properties, and
heterogeneous nature of composites can make the determination of structural failure
loads, modes, and locations difficult. The reliability of such evaluation depends on
repeatable structural details created by scaled manufacturing or repair processes. The
extent of testing and/or analysis may differ for a structure depending upon the criticality

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to flight safety, expected service usage, the material and processes selected, the design
margins, the failure criteria, the database and experience with similar structures, and on
other factors affecting a particular structure. It is expected that these factors will be
considered when interpreting this AMC for use on a specific application.

c. Definitions of terms used in this AMC can be found in Appendix 2.

6. MATERIAL AND FABRICATION DEVELOPMENT

All composite materials and processes used in structures are qualified through enough
fabrication trials and tests to demonstrate a reproducible and reliable design. One of the
important features of composite construction is the degree of care needed in the procurement
and processing of composite materials. The final mechanical behaviour of a given composite
material may vary greatly depending on the processing methods employed to fabricate
production parts. Special care needs to be taken in controlling both the materials being
procured and how the material is processed once delivered to the fabrication facility. The CSs
(namely paragraphs 2x.603 and 2x.605) specify the need to procure and process materials
under approved material and process specifications that control the key parameters governing
performance. These paragraphs outline a need to protect structures against the degradation
possible in service. They also require that the design account for any changes in performance
(e.g., environmental and variability effects) permitted by material and process specifications.

a. Material and Process Control

(1) Specifications covering material, material processing, and fabrication procedures are
established to ensure a basis for fabricating reproducible and reliable structure. Material
specifications are required to ensure consistent material can be procured, and batch
acceptance testing or statistical process controls are used to ensure material properties
do not drift over time. Specifications covering processing procedures should be developed
to ensure that repeatable and reliable structure can be manufactured. The means of
processing qualification and acceptance tests defined in each material specification should
be representative of the expected applicable manufacturing process. The process
parameters for fabricating test specimens should match the process parameters to be
used in manufacturing actual production parts as closely as possible. Both test and
production parts must conform to material and process specifications.

(2) Once the fabrication processes have been established, changes should undergo
additional qualification, including testing of differences, before being implemented, (refer
to Appendix 3). It is important to establish processing tolerances, material handling and
storage limits, and key characteristics, which can be measured and tracked to judge part
quality.

(3) Material requirements identified in procurement specifications should be based on the

qualification test results for samples produced using the related process specifications.
Qualification data must cover all properties important to the control of materials
(composites and adhesives) and processes to be used for production of composite
structure. Carefully selected physical, chemical, and mechanical qualification tests are
used to demonstrate the formulation, stiffness, strength, durability, and reliability of
materials and processes for aircraft applications. It is recommended that airframe
designers and manufacturers work closely with material suppliers to properly define
material requirements.

(4) To provide an adequate design database, environmental effects on critical properties

of the material systems and associated processes should be established. In addition to
testing in an ambient environment, variables should include extreme service temperature
and moisture content conditions and effects of long-term durability. Qualification tests for
environmental effects and long-term durability are particularly important when evaluating

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the materials, processes, and interface issues associated with structural bonding (refer to
paragraph 6.c for related guidance).

(5) Key characteristics and processing parameters should be specified and monitored for
in-process quality control. The overall quality control plan required by the certifying
agency should involve all relevant disciplines, i.e., engineering, manufacturing, and
quality control. A reliable quality control system should be in place to address special
engineering requirements that arise in individual parts or areas as a result of potential
failure modes, damage tolerance and flaw growth requirements, loadings, inspectability,
and local sensitivities to manufacture and assembly.

(6) Tolerances permitted by the material and process specifications should be

substantiated by analysis supported by test evidence, or tests at the coupon, element or
sub-component level. For new production methods, repeatable processes should be
demonstrated at sufficient structural scale in a way shown to be consistent with the
material and process qualification tests and development of the associated specifications.
This will require integration of the technical issues associated with product design and
manufacturing details prior to a large investment in structural tests and analysis
correlation. It will also ensure the relevance of quality control procedures defined to
control materials and processes as related to the product structural details.

(7) Note that the Agency does not certify materials and processes. However, materials
and processes specifications are part of the type-design subject to type-certification.
Appropriate certification credit may be given to products and organisations using the
same materials and processes in similar applications subject to substantiation and
applicability. In some cases, material and processing information may become part of
accepted shared databases used throughout the industry. New users of shared
qualification databases must control the associated materials and processes through
proper use of the related specifications and demonstrate their understanding by
performing equivalency sampling tests for key properties. Note that materials and
processes used in European Technical Standard Order (ETSO) articles or authorisations
must also be qualified and controlled.

b. Design Considerations for Manufacturing Implementation

(1) Process specifications and manufacturing documentation are needed to control

composite fabrication and assembly. The environment and cleanliness of facilities are
controlled to a level validated by qualification and proof of structure testing. Raw and
ancillary materials are controlled to specification requirements that are consistent with
material and process qualifications. Parts fabricated should meet design drawing
tolerances obtained from the production tolerances validated in qualification, design data
development, and proof of structure tests. Some key fabrication process considerations
requiring such control include: (i) material handling and storage, (ii) laminate layup and
bagging (or other alternate process steps for non-laminated material forms and advanced
processes), (iii) mating part dimensional tolerance control, (iv) part cure (thermal
management), (v) machining and assembly, (vi) cured part inspection and handling
procedures, and (vii) technician training for specific material, processes, tooling and
equipment.

(2) Substantiating data is needed for design to justify all known defects, damage and
anomalies allowed to remain in service without rework or repair. Adequate manufacturing
records support the identification and substantiation of known defects, damage and
anomalies.

(3) Additional substantiating design data is needed from new suppliers of parts
previously certificated. This may be supported by manufacturing trials and quality
assessments to ensure equivalent production and repeatability. Some destructive

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inspection of critical structural details is needed for manufacturing flaws that are not end
item inspectable and require process controls to ensure reliable fabrication.

c. Structural Bonding

Bonded structures include multiple interfaces (e.g., composite-to-composite, composite-

to-metal, or metal-to-metal), where at least one of the interfaces requires additional
surface preparation prior to bonding. The general nature of technical parameters that
govern different types of bonded structures are similar. A qualified bonding process is
documented after demonstrating repeatable and reliable processing steps such as surface
preparation. It entails understanding the sensitivity of structural performance based upon
expected variation permitted per the process. Characterisation outside the process limits
is recommended to ensure process robustness. In the case of bonding composite
interfaces, a qualified surface preparation of all previously cured substrates is needed to
activate their surface for chemical adhesion. For all bonding interfaces, regardless if on
metallic or previously cured composite substrates, a qualified surface preparation is
needed to activate their surface for chemical adhesion. Many technical issues for bonding
require cross-functional teams for successful applications. Applications require stringent
process control and a thorough substantiation of structural integrity.

(1) Many bond failures and problems in service have been traced to invalid qualifications
or insufficient quality control of production processes. Physical and chemical tests may be
used to control surface preparation, adhesive mixing, viscosity, and cure properties (e.g.,
density, degree of cure, glass transition temperature). Lap shear stiffness and strength
are common mechanical tests for adhesive and bond process qualification. Shear tests do
not provide a reliable measure of long-term durability and environmental degradation
associated with poor bonding processes (i.e., lack of adhesion). Some type of peel test
has proven more reliable for evaluating proper adhesion. Without chemical bonding, the
so-called condition of a “weak bond” exists when the bonded joint is either loaded by
peel forces or exposed to the environment over a long period of time, or both. Adhesion
failures, which indicate the lack of chemical bonding between substrate and adhesive
materials, are considered an unacceptable failure mode in all test types. Material or bond
process problems that lead to adhesion failures are solved before proceeding with
qualification tests.

(2) Process specifications are needed to control adhesive bonding in manufacturing and
repair. A “process control mentality”, which includes a combination of in-process
inspections and tests, has proven to be the most reliable means of ensuring the quality of
adhesive bonds. The environment and cleanliness of facilities used for bonding processes
are controlled to a level validated by qualification and proof of structure testing.
Adhesives and substrate materials are controlled to specification requirements that are
consistent with material and bond process qualifications. The bonding processes used for
production and repair meet tolerances validated in qualification, design data
development, and proof of structure tests. Some key bond fabrication process
considerations requiring such control include: (i) material handling and storage, (ii) bond
surface preparation, (iii) mating part dimensional tolerance control, (iv) adhesive
application and clamp-up pressure, (v) bond line thickness control, (vi) bonded part cure
(thermal management), (vii) cured part inspection and handling procedures, and (vii)
bond technician training for specific material, processes, tooling and equipment. Bond
surface preparation and subsequent handling controls leading up to the bond assembly
and cure must be closely controlled in time and exposure to environment and
contamination.

(3) CS 23.573(a) sets the certification specification for primary composite airframe
structures, including considerations for damage tolerance, fatigue, and bonded joints.
Although this is a small aeroplane rule, the same performance standards are normally
expected for large aeroplanes and rotorcraft (via special conditions and CRIs).

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(a) For bonded joints, CS 23.573(a)(5) states:

"For any bonded joint, the failure of which would result in catastrophic loss of the
aeroplane, the limit load capacity must be substantiated by one of the following
methods:
(i) The maximum disbonds of each bonded joint consistent with the capability to
withstand the loads in paragraph (a)(3) of this section must be determined by
analysis, tests, or both. Disbonds of each bonded joint greater than this must be
prevented by design features; or
(ii) Proof testing must be conducted on each production article that will apply the
critical limit design load to each critical bonded joint; or
(iii) Repeatable and reliable non-destructive inspection techniques must be established
that ensure the strength of each joint."

(b) These options do not supersede the need for a qualified bonding process and
rigorous quality controls for bonded structures. For example, fail safety implied by the
first option is not intended to provide adequate safety for the systematic problem of a
bad bonding process applied to a fleet of aircraft structures. Instead, it gives fail safety
against bonding problems that may occasionally occur over local areas (e.g., insufficient
local bond contact pressure or contamination). Performing static proof tests to limit load,
which is the second option, may not detect weak bonds requiring environmental
exposure and time to degrade bonded joint strength. This issue should be covered by
adequately demonstrating that qualified bonding materials and processes have long-term
environmental durability. Finally, the third option is open for future advancement and
validation of non-destructive inspection (NDI) technology to detect weak bonds, which
degrade over time and lead to adhesion failures. Such technology has not been reliably
demonstrated at a production scale to date.

(4) Adhesion failures are an unacceptable failure mode for bonded structure that require
immediate action by the responsible engineers to identify the specific cause and isolate
all affected parts and assemblies for directed inspection and repair. Depending on the
suspected severity of the bonding problem, an airworthiness directive may be required to
restore the affected aircraft to an airworthy condition. Any design, manufacturing or
repair details linked to the bonding problem should also be permanently corrected.

d. Environmental Considerations

Environmental design criteria should be developed that identify the critical environmental
exposures, including humidity and temperature, to which the material in the application
under evaluation may be exposed. Service data (e.g., moisture content as a function of
time in service) can be used to ensure such criteria are realistic. In addition, the peak
temperatures for composite structure installed in close proximity to aircraft systems that
generate thermal energy need to be identified for worst-case normal operation and
system failure cases. Environmental design criteria are not required where existing data
demonstrate that no significant environmental effects, including the effects of
temperature and moisture, exist for the material system and construction details, within
the bounds of environmental exposure being considered.

(1) Experimental evidence should be provided to demonstrate that the material design
values or allowables are attained with a high degree of confidence in the appropriate
critical environmental exposures to be expected in service. It should be realised that the
worst case environment may not be the same for all structural details (e.g., hot wet
conditions can be critical for some failure modes, while cold dry conditions may be worse
for others). The effect of the service environment on static strength, fatigue and stiffness
properties and design values should be determined for the material system through
tests, e.g., accelerated environmental tests, or from applicable service data. The

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maximum moisture content considered is related to that possible during the service life,
which may be a function of a given part thickness, moisture diffusion properties and
realistic environmental exposures. The effects of environmental cycling (i.e., moisture
and temperature) should be evaluated when the application involves fluctuations or
unique design details not covered in the past. Existing test data may be used where it
can be shown to be directly applicable to the material system, design details, and
environmental cycling conditions characteristic of the application. All accelerated test
methods should be representative of real-time environmental and load exposure. Any
factors used for acceleration that chemically alter the material (e.g., high temperatures
that cause post-cure) should be avoided to ensure behaviour representative of real
environmental exposures.

(2) Depending on the design configuration, local structural details, and selected
processes, the effects of residual stresses that depend on environment should be
addressed (e.g., differential thermal expansion of attached parts).

e. Protection of Structure

Weathering, abrasion, erosion, ultraviolet radiation, and chemical environment (glycol,

hydraulic fluid, fuel, cleaning agents, etc.) may cause deterioration in a composite
structure. Suitable protection against and/or consideration of degradation in material
properties should be provided for conditions expected in service and demonstrated by
test and/or appropriate validated experience. Where necessary, provide provisions for
ventilation and drainage. Isolation layers are needed at the interfaces between some
composite and metal materials to avoid corrosion (e.g., glass plies are used to isolate
carbon composite layers from aluminium). In addition, qualification of the special
fasteners and installation procedures used for parts made from composite materials need
to address the galvanic corrosion issues, as well as the potential for damaging the
composite (delamination and fibre breakage) in forming the fastener.

f. Design Values

Data used to derive design values must be obtained from stable and repeatable material
that conforms to mature material and representative production process specifications.
This will ensure that the permitted variability of the production materials is captured in
the statistical analysis used to derive the design values. Design values derived too early
in the material’s development stage, before raw material and composite part production
processes have matured, may not satisfy the intent of the associated rules. Laminated
material system design values should be established on the laminate level by either test
of the laminate or by test of the lamina in conjunction with a test validated analytical
method. Similarly, design values for non-laminated material forms and advanced
composite processes must be established at the scale that best represents the material
as it appears in the part or by tests of material substructure in conjunction with a test
validated analytical method.

g. Structural Details

For a specific structural configuration of an individual component (point design), design

values may be established which include the effects of appropriate design features (holes,
joints, etc.). Specific metrics that quantify the severity of composite structural damage
states caused by foreign impact damage threats are needed to perform analysis (i.e., the
equivalent of a metallic crack length). As a result, testing will often be needed to
characterise residual strength, including the structural effects of critical damage location
and combined loads. Different levels of impact damage are generally accommodated by
limiting the design strain levels for ultimate and limit combined load design criteria. In
this manner, rational analyses supported by tests can be established to characterise
residual strength for point design details.

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7. PROOF OF STRUCTURE – STATIC

The structural static strength substantiation of a composite design should consider all critical
load cases and associated failure modes. It should also include effects of environment
(including residual stresses induced during the fabrication process), material and process
variability, non-detectable defects or any defects that are allowed by the quality control,
manufacturing acceptance criteria, and service damage allowed in maintenance documents of
the end product. The static strength of the composite design should be demonstrated through
a programme of component ultimate load tests in the appropriate environment, unless
experience with similar designs, material systems, and loadings is available to demonstrate the
adequacy of the analysis supported by sub-component, element and coupon tests, or
component tests to accepted lower load levels. The necessary experience to validate an
analysis should include previous component ultimate load tests with similar designs, material
systems, and load cases.

a. The effects of repeated loading and environmental exposure which may result in material
property degradation should be addressed in the static strength evaluation. This can be
shown by analysis supported by test evidence, by tests at the coupon, element or sub-
component level, as appropriate, or alternatively by relevant existing data. Earlier
discussions in this AMC address the effects of environment on material properties
(paragraph 6.d) and protection of structure (paragraph 6.e). For critical loading
conditions, three approaches exist to account for prior repeated loading and/or
environmental exposure in the full-scale static test.

(1) In the first approach, the full-scale static test should be conducted on structure with
prior repeated loading and conditioned to simulate the critical environmental exposure
and then tested in that environment.

(2) The second approach relies upon coupon, element, and sub-component test data to
determine the effect of repeated loading and environmental exposure on static strength.
The degradation characterised by these tests should then be accounted for in the full-
scale static strength demonstration test (e.g., overload factors), or in analysis of these
results (e.g., showing a positive margin of safety with design values that include the
degrading effects of environment and repeated load).

(3) In practice, aspects of the first two approaches may be combined to obtain the
desired result (e.g., a full scale static test may be performed at critical operating
temperature with a load factor to account for moisture absorbed over the aircraft
structure’s life). Alternate means to account for environment using validated tests and
analyses (e.g., an equivalent temperature enhancement to account for the effect of
moisture without chemically altering the material), may be proposed by the applicant.

b. The strength of the composite structure should be reliably established, incrementally,

through a programme of analysis and a series of tests conducted using specimens of
varying levels of complexity. Often referred to in industry as the “building block”
approach, these tests and analyses at the coupon, element, details, and sub-component
levels can be used to address the issues of variability, environment, structural
discontinuity (e.g., joints, cut-outs or other stress risers), damage, manufacturing
defects, and design or process-specific details. Typically, testing progresses from simple
specimens to more complex elements and details over time. This approach allows the
data collected for sufficient analysis correlation and the necessary replicates to quantify
variations occurring at the larger structural scales to be economically obtained. The
lessons learned from initial tests also help avoid early failures in more complex full-scale
tests, which are more costly to conduct and often occur later in a certification programme
schedule.

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(1) Figures 1 and 2 provide a conceptual schematic of tests typically included in the
building block approach for a fixed wing and tail rotor blade structures, respectively. The
large quantity of tests needed to provide a statistical basis comes from the lowest levels
(coupons and elements) and the performance of structural details are validated in a
lesser number of sub-component and component tests. Detail and subcomponent tests
may be used to validate the ability of analysis methods to predict local strains and failure
modes. Additional statistical considerations (e.g., repetitive point design testing and/or
component overload factors to cover material and process variability) will be needed
when analysis validation is not achieved. The static strength substantiation programme
should also consider all critical loading conditions for all Critical Structure. This includes
an assessment of residual strength and stiffness requirements after a predetermined
length of service, which takes into account damage and other degradation due to the
service period.

Figure 1 - Schematic diagram of building block tests for a fixed wing.

Figure 2 - Schematic diagram of building block tests for a tail rotor blade.

(2) Successful static strength substantiation of composite structures has traditionally

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depended on proper consideration of stress concentrations (e.g., notch sensitivity of

details and impact damage), competing failure modes and out-of-plane loads. A complete
building block approach to composite structural substantiation addresses most critical
structural issues in test articles with increasing levels of complexity so that many areas of
reliable performance can be demonstrated prior to the component tests. The details and
sub-component testing should establish failure criteria and account for impact damage in
assembled composite structures. Component tests are needed to provide the final
validation accounting for combined loads and complex load paths, which include some
out-of-plane effects. When using the building block approach, the critical load cases and
associated failure modes would be identified for component tests using the analytical
methods, which are supported by test validation.

c. The component static test may be performed in an ambient atmosphere if the effects of
the environment are reliably predicted by building block tests and are accounted for in
the static test or in the analysis of the results of the static test.

d. The static test articles should be fabricated and assembled in accordance with production
specifications and processes so that the test articles are representative of production
structure including defects consistent with the limits established by manufacturing
acceptance criteria.

e. The material and processing variability of the composite structure should be considered in
the static strength substantiation. This is primarily achieved by establishing sufficient
process and quality controls to manufacture structure and reliably substantiate the
required strength by test and analysis. The scatter in strength properties due to
variability in materials and processes are characterised by proper allowables or design
values, which are derived in compliance with CS 2x.613. When the detail, sub-component
and component tests show that local strains are adequately predicted and positive
margins of safety exist using a validated analysis everywhere on the structure, then proof
of static strength is said to be substantiated using analysis supported by test evidence.
Alternatively, in the absence of sufficient building block test data and analysis validation,
overloads are needed in the component test to gain proof of static strength for the
structure using an approach referred to as substantiated by tests. The overload factors
applied in this case need to be substantiated either through tests or past experience and
must account for the expected material and process variation.

f. It should be shown that impact damage that can be expected from manufacturing and
service, but not more than the established threshold of detectability for the selected
inspection procedure, will not reduce the structural strength below ultimate load
capability. This can be shown by analysis supported by test evidence, or by a combination
of tests at the coupon, element, sub-component and component levels. The realistic test
assessment of impact damage requires proper consideration of the structural details and
boundary conditions. When using a visual inspection procedure, the likely impact damage
at the threshold of reliable detection has been called barely visible impact damage
(BVID). Selection of impact sites for static strength substantiation should consider the
criticality of the local structural detail, and the ability to inspect a location. The size and
shape of impactors used for static strength substantiation should be consistent with likely
impact damage scenarios that may go undetected for the life of an aircraft. Note that it is
possible for some designs to have detectable impact damage and still meet static
strength loads and other requirements without repair (refer to allowable damage
discussions in paragraph 10.c(1)).

g. Major material and process changes on existing certified structure require additional
static strength substantiation (e.g., refer to Appendix 3).

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8. PROOF OF STRUCTURE – FATIGUE AND DAMAGE TOLERANCE

The evaluation of composite structure should be based on the applicable certification
specifications identified in the type-certification basis. Such evaluation must show that
catastrophic failure due to fatigue, environmental effects, manufacturing defects, or accidental
damage will be avoided throughout the operational life of the aircraft. The nature and extent of
analysis or tests on complete structures and/or portions of the primary structure will depend
upon applicable previous fatigue/damage tolerant designs, construction, tests, and service
experience on similar structures. In the absence of experience with similar designs, Agency-
approved structural development tests of components, sub-components, and elements should
be performed (following the same principles discussed in paragraph 7.b and Appendix 3). The
following considerations are unique to the use of composite material systems and provide
guidance for the method of substantiation selected by the applicant. When establishing details
for the damage tolerance and fatigue evaluation, attention should be given to a thorough
damage threat assessment, geometry, inspectability, good design practice, and the types of
damage/degradation of the structure under consideration.

 Composite damage tolerance and fatigue performance is strongly dependent on

structural design details (e.g., skin laminate stacking sequence, stringer or frame
spacing, stiffening element attachment details, damage arrestment features, and
structural redundancy).
 Composite damage tolerance and fatigue evaluations require substantiation in
component tests unless experience with similar designs, material systems, and loadings
is available to demonstrate the adequacy of the analysis supported by coupons,
elements, and sub-component tests.
 Final static strength, fatigue, and damage tolerance substantiation may be gained in
testing a single component test article if sufficient building block test evidence exists to
ensure that the selected sequence of repeated and static loading yield results
representative of that possible in service or provide a conservative evaluation.
 Peak repeated loads are needed to practically demonstrate the fatigue and damage
tolerance of composite aircraft structure in a limited number of component tests. As a
result, metal structures present in the test article generally require additional
consideration and testing. The information contained in AMC 25.571 provides fatigue and
damage tolerance guidance for metallic structures.

a. Damage Tolerance Evaluation

(1) Damage tolerance evaluation starts with identification of structure whose failure
would reduce the structural integrity of the aircraft. A damage threat assessment must be
performed for the structure to determine possible locations, types, and sizes of damage
considering fatigue, environmental effects, intrinsic flaws, and foreign object impact or
other accidental damage (including discrete source) that may occur during manufacture,
operation or maintenance.

(a) Currently, there are very few industry standards that outline the critical
damage threats for particular composite structural applications with enough detail to
establish the necessary design criteria or test and analysis protocol for complete
damage tolerance evaluation. In the absence of standards, it is the responsibility of
individual applicants to perform the necessary development tasks to establish such
data in support of product substantiation. Some factors to consider in development
of a damage threat assessment for a particular composite structure include part
function, location on the aircraft, past service data, accidental damage threats,
environmental exposure, impact damage resistance, durability of assembled
structural details (e.g., long-term durability of bolted and bonded joints), adjacent
system interface (e.g., potential overheating or other threats associated with
system failure), and anomalous service or maintenance handling events that can

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overload or damage the part. As related to the damage threat assessment and
maintenance procedures for a given structure, the damage tolerance capability and
ability to inspect for known damage threats should be developed.

(b) Foreign object impact is a concern for most composite structures, requiring
attention in the damage threat assessment. This is needed to identify impact
damage severity and detectability for design and maintenance. It should include any
available damage data collected from service plus an impact survey. An impact
survey consists of impact tests performed with representative structure, which is
subjected to boundary conditions characteristic of the real structure. Many different
impact scenarios and locations should be considered in the survey, which has a goal
of identifying the most critical impacts possible (i.e., those causing the most serious
damage but are least detectable). When simulating accidental impact damage at
representative energy levels, blunt or sharp impactors of different sizes and shapes
should be selected to cause the most critical and least detectable damage,
according to the load conditions (e.g., tension, compression or shear). Until
sufficient service experience exists to make good engineering judgments on energy
and impactor variables, impact surveys should consider a wide range of conceivable
impacts, including runway or ground debris, hail, tool drops, and vehicle collisions.
This consideration is important to the assumptions needed for use of probabilistic
damage threat assessments in defining design criteria, inspection methods, and
repeat inspection intervals for maintenance. Service data collected over time can
better define impact surveys and design criteria for subsequent products, as well as
establish more rational inspection intervals and maintenance practice. In review of
such information, it should be realised that the most severe and critical impact
damages, which are still possible, may not be part of the service database.

(c) Once a damage threat assessment is completed, various damage types can be
classified into five categories of damage as described below (refer to figure 3).
These categories of damage are used for communication purposes in this AMC.
Other categories of damage, which help outline a specific path to fatigue and
damage tolerance substantiation, may be used by applicants in agreement with the
regulatory authorities.

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Figure 3 - Schematic diagram showing design load levels versus categories of

damage severity.

Category 1: Allowable damage that may go undetected by scheduled or directed

field inspection and allowable manufacturing defects. Structural substantiation for
Category 1 damage includes demonstration of a reliable service life, while retaining
ultimate load capability. By definition, such damage is subjected to the
requirements and guidance associated with paragraph 7 of this AMC. Some
examples of Category 1 damage include BVID and allowable defects caused in
manufacturing or service (e.g., small delamination, porosity, small scratches,
gouges, and minor environmental damage) that have substantiation data showing
ultimate load is retained for the life of an aircraft structure.

Category 2: Damage that can be reliably detected by scheduled or directed field

inspections performed at specified intervals. Structural substantiation for Category 2
damage includes demonstration of a reliable inspection method and interval while
retaining loads above limit load capability. The residual strength for a given
Category 2 damage may depend on the chosen inspection interval and method of
inspection. Some examples of Category 2 damage include visible impact damage
(VID), VID (ranging in size from small to large), deep gouges or scratches,
manufacturing mistakes not evident in the factory, detectable delamination or
debonding, and major local heat or environmental degradation that will sustain
sufficient residual strength until found. This type of damage should not grow or, if
slow or arrested growth occurs, the level of residual strength retained for the
inspection interval is sufficiently above limit load capability.

Category 3: Damage that can be reliably detected within a few flights of occurrence
by operations or ramp maintenance personnel without special skills in composite

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inspection. Such damage must be in a location such that it is obvious by clearly

visible evidence or cause other indications of potential damage that becomes
obvious in a short time interval because of loss of the part form, fit or function. Both
indications of significant damage warrant an expanded inspection to identify the full
extent of damage to the part and surrounding structural areas. In practice,
structural design features may be needed to provide sufficient large damage
capability to ensure limit or near limit load is maintained with easily detectable,
Category 3 damage. Structural substantiation for Category 3 damage includes
demonstration of a reliable and quick detection, while retaining limit or near limit
load capability. The primary difference between Category 2 and 3 damages are the
demonstration of large damage capability at limit or near limit load for the latter
after a regular interval of time, which is much shorter than the former. The residual
strength demonstration for Category 3 damage may be dependent on the reliable
short time detection interval. Some examples of Category 3 damage include large
VID or other obvious damage that will be caught during walk-around inspection or
during the normal course of operations (e.g., fuel leaks, system malfunctions or
cabin noise).

Category 4: Discrete source damage from a known incident such as flight

manoeuvres is limited. Structural substantiation for Category 4 damage includes a
demonstration of residual strength for loads specified in the regulations. It should
be noted that pressurised structure will generally have Category 4 residual strength
requirements at a level higher than shown in figure 3. Some examples of Category 4
damage include rotor burst, bird strikes (as specified in the regulations), tyre
bursts, and severe in-flight hail.

Category 5: Severe damage created by anomalous ground or flight events, which is

not covered by design criteria or structural substantiation procedures. This damage
is in the current guidance to ensure the engineers responsible for composite aircraft
structure design and the Agency work with maintenance organisations in making
operations personnel aware of possible damage from Category 5 events and the
essential need for immediate reporting to responsible maintenance personnel. It is
also the responsibility of structural engineers to design-in sufficient damage
resistance such that Category 5 events are self-evident to the operations personnel
involved. An interface is needed with engineering to properly define a suitable
conditional inspection based on available information from the anomalous event.
Such action will facilitate the damage characterisation needed prior to repair. Some
examples of Category 5 damage include severe service vehicle collisions with
aircraft, anomalous flight overload conditions, abnormally hard landings,
maintenance jacking errors, and loss of aircraft parts in flight, including possible
subsequent high-energy, wide-area (blunt) impact with adjacent structure. Some
Category 5 damage scenarios will not have clearly visual indications of damage,
particularly in composite structures. However, there should be knowledge of other
evidence from the related events that ensure safety is protected, starting with a
complete report of possible damage by operations.

(d) The five categories of damage will be used as examples in subsequent

discussion in this paragraph and in paragraphs 9 and 10. Note that Category 2, 3, 4
and 5 damages all have associated repair scenarios.

(2) Structure details, elements, and sub-components of Critical Structure should be

tested under repeated loads to define the sensitivity of the structure to damage growth.
This testing can form the basis for validating a no-growth approach to the damage
tolerance requirements. The testing should assess the effect of the environment on the
flaw and damage growth characteristics and the no-growth validation. The environment
used should be appropriate to the expected service usage. Residual stresses will develop
at the interfaces between composite and metal structural elements in a design due to

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differences in thermal expansion. This component of stress will depend on the service
temperature during repeated load cycling and is considered in the damage tolerance
evaluation. Inspection intervals should be established, considering both the likelihood of a
particular damage and the residual strength capability associated with this damage. The
intent of this is to assure that structure is not exposed to an excessive period of time with
residual strength less than ultimate, providing a lower safety level than in the typical slow
growth situation, as illustrated in Figure 4. Conservative assumptions for capability with
large damage sizes that would be detected within a few flights may be needed when
probabilistic data on the likelihood of given damage sizes does not exist. Once the
damage is detected, the component is either repaired to restore ultimate load capability
or replaced.

Figure 4 - Schematic diagram of residual strength illustrating that significant

accidental damage with “no-growth” should not be left in the structure without repair
for a long time.

(a) The traditional slow growth approach may be appropriate for certain damage
types found in composites if the growth rate can be shown to be slow, stable and
predictable. Slow growth characterisation should yield conservative and reliable
results. As part of the slow growth approach, an inspection programme should be
developed consisting of the frequency, extent, and methods of inspection for
inclusion in the maintenance plan. Inspection intervals should be established such
that the damage will have a very high probability of detection between the time it
becomes initially detectable and the time at which the extent of the damage reduces
the residual static strength to limit load (considered as ultimate), including the
effects of environment. For any detected damage size that reduces the load
capability below ultimate, the component is either repaired to restore ultimate load
capability or replaced. Should functional impairment (such as unacceptable loss of
stiffness) occur before the damage becomes otherwise critical, part repair or
replacement will also be necessary.

(b) Another approach involving growth may be appropriate for certain damage
types and design features adopted for composites if the growth can be reliably
shown to be predictable and arrested before it becomes critical. Figure 5 shows
schematic diagrams for all three damage growth approaches applied to composite
structure. The arrested growth method is applicable when the damage growth is
mechanically arrested or terminated before becoming critical (residual static
strength reduced to limit load), as illustrated in Figure 5. Arrested growth may occur
due to design features such as a geometry change, reinforcement, thickness
change, or a structural joint. This approach is appropriate for damage growth that is
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detectable and found to be reliably arrested, including all appropriate dynamic

effects. Structural details, elements, and sub-components of Critical Structure,
components or full-scale structures, should be tested under repeated loads for
validating an Arrested Growth Approach. As was the case for a “no-growth”
approach to damage tolerance, inspection intervals should be established,
considering the residual strength capability associated with the arrested growth
damage size (refer to the dashed lines added to Figure 5 to conceptually show
inspection intervals consistent with the slow growth basis). Again, this is intended to
ensure that the structure does not remain in a damaged condition with residual
strength capability close to limit load for long periods of time before repair. For any
damage size that reduces load capability below ultimate, the component is either
repaired to restore ultimate load capability or replaced.

(c) The repeated loading should be representative of anticipated service usage.

The repeated load testing should include damage levels (including impact damage)
typical of those that may occur during fabrication, assembly, and in-service,
consistent with the inspection techniques employed. The damage tolerance test
articles should be fabricated and assembled in accordance with production
specifications and processes so that the test articles are representative of
production structure.

(3) The extent of initially detectable damage should be established and be consistent
with the inspection techniques employed during manufacture and in service. This
information will naturally establish the transition between Category 1 and 2 damage
types (i.e., inspection methods used by trained inspectors in scheduled maintenance). For
damage that is clearly detectable to an extent that it will likely be found before scheduled
maintenance (i.e., allowing classification as Category 3 damage), detection over shorter
intervals and by untrained personnel may be permitted. Flaw/damage growth data should
be obtained by repeated load cycling of intrinsic flaws or mechanically introduced
damage. The number of cycles applied to validate both growth and no-growth concepts
should be statistically significant, and may be determined by load and/or life
considerations and a function of damage size. The growth or no growth evaluation should
be performed by analysis supported by test evidence or by tests at the coupon, element,
or sub-component level.

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Figure 5 - Illustrations of residual strength and damage size relationships for three
different approaches to composite structural damage tolerance substantiation

(4) The extent of damage for residual strength assessments should be established,
including considerations for the probability of detection using selected field inspection
procedures. The first four categories of damage should be considered based on the
damage threat assessment. In addition, Category 3 damage should be detected in a
walk-around inspection or through the normal course of operations. Residual strength
evaluation by component or sub-component testing or by analysis supported by test
evidence should be performed considering that damage. The evaluation should
demonstrate that the residual strength of the structure will reliably be equal to or greater
than the strength required for the specified design loads (considered as ultimate),
including environmental effects. The statistical significance of reliable sub-component and
detail residual strength assessments may include conservative methods and engineering
judgment. It should be shown that stiffness properties have not changed beyond
acceptable levels.

(a) For the no-growth, slow growth, arrested growth approaches, residual strength
testing should be performed after repeated load cycling. All probabilistic analyses
applied for residual strength assessments should properly account for the complex
nature of damage defined from a thorough damage threat assessment.
Conservative damage metrics are permitted in such analyses assuming sufficient
test data on repeated load and environmental exposure exists.

(b) Composite designs should afford the same level of fail-safe, multiple load path
structure assurance as conventional metals design. Such is also the expectation in
justifying the use of static strength allowables with a statistical basis of 90 percent
probability with 95 percent confidence.

(c) Some special residual strength considerations for bonded structure are given in
paragraph 6.c.(3).

(5) The repeated load spectrum developed for fatigue testing and analysis purposes
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should be representative of the anticipated service usage. Low amplitude load levels that
can be shown not to contribute to damage growth may be omitted. Reducing maximum
load levels is generally not accepted. Variability in repeated load behaviour should be
covered by appropriate load enhancement or life scatter factors and these factors should
take into account the number of specimens tested. The use of such factors to
demonstrate reliability in component tests should be consistent with the fatigue and
damage tolerance behaviour characterised for the materials, processes and other design
details of the structure in building block tests.

(6) An inspection programme should be developed consisting of frequency, extent, and

methods of inspection for inclusion in the maintenance plan. Inspection intervals should
be established such that the damage will be reliably detected between the time it initially
becomes detectable and the time at which the extent of damage reaches the limits for
required residual strength capability. The potential for missed inspections should be
considered.

(a) For the case of no-growth design concept, inspection intervals should be
established as part of the maintenance programme. In selecting such intervals, the
residual strength level associated with the assumed damages should be considered.
This point was illustrated in Figures 4 and 5. Note that an acceptable inspection
interval for the larger damages shown for the “no-growth” and “arrested growth”
options in Figures 4 and 5 was conceptually shown as related to an acceptable slow
growth basis in terms of the residual strength and time below ultimate load before
damage was detected and repaired. Data on the probability of occurrence for
different damage sizes also helps define an inspection interval.

(b) A thorough composite damage threat assessment and the separation of

different damage sizes into categories, each with associated detection methods,
supports programmes using a rigorous damage tolerance assessment to avoid
conservative design criteria with very large damage assumptions. In such cases,
Category 2 damage types will require the structural substantiation of well specified
and reliable inspection methods applied by trained inspectors at scheduled
maintenance intervals (by default, Category 1 damage is at the threshold of this
evaluation). Those damages classified as Category 3 may take advantage of shorter
service time intervals provided sufficient structural substantiation exists with
demonstrated proof that there will be early detection by untrained ramp
maintenance or operations personnel. By definition, Category 4 damage will require
residual strength substantiation to levels that complete a flight with limited
manoeuvres based on the associated regulatory loads. Due to the nature of service
events leading to Category 4 damage, suitable inspections will need to be defined to
evaluate the full extent of damage, prior to subsequent aircraft repair and return to
service. By definition, Category 5 damages do not have associated damage
tolerance design criteria or related structural substantiation tasks. Category 5
damage will require suitable inspections based on engineering assessment of the
anomalous service event, and appropriate structural repair and/or part replacement,
prior to the aircraft re-entering service.

(7) The structure should be able to withstand static loads (considered as ultimate loads)
which are reasonably expected during a completion of the flight on which damage
resulting from obvious discrete sources occur (i.e., uncontained engine failures, etc.). The
extent of damage should be based on a rational assessment of service mission and
potential damage relating to each discrete source. Structural substantiation will be
needed for the most critical Category 4 damage as related to the associated load cases.
Some Category 4 damage may have high margins but will likely still require suitable
inspections since their detectability may not be consistent with the substantiations
validated for Category 2 damage types.

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(8) The effects of temperature, humidity, and other environmental or time-related aging
factors, which may result in material property degradation, should be addressed in the
damage tolerance evaluation. Unless tested in the environment, appropriate
environmental factors should be derived and applied in the evaluation.

b. Fatigue Evaluation
Fatigue substantiation should be accomplished by component fatigue tests or by analysis
supported by test evidence, accounting for the effects of the appropriate environment.
The test articles should be fabricated and assembled in accordance with production
specifications and processes so that the test articles are representative of production
structures. Sufficient component, sub-component, element or coupon tests should be
performed to establish the fatigue scatter and the environmental effects. Component,
sub-component, and/or element tests may be used to evaluate the fatigue response of
structure with impact damage levels typical of those that may occur during fabrication,
assembly, and in service, consistent with the inspection procedures employed. Other
allowed manufacturing and service defects, which would exist for the life of the structure,
should also be included in fatigue testing. It should be demonstrated during the fatigue
tests that the stiffness properties have not changed beyond acceptable levels.
Replacement lives should be established based on the test results. By definition,
Category 1 damage is subjected to fatigue evaluation and expected to retain ultimate
load capability for the life of the aircraft structure.

c. Combined Damage Tolerance and Fatigue Evaluation

Generally, it is appropriate for a given structure to establish both an inspection
programme and demonstrate a service life to cover all detectable and non-detectable
damage, respectively, which is anticipated for the intended aircraft usage. Extensions in
service life should include evidence from component repeated load testing, fleet leader
programmes (including NDI and destructive tear-down inspections), and appropriate
statistical assessments of accidental damage and environmental service data
considerations.

9. PROOF OF STRUCTURE – FLUTTER AND OTHER AEROELASTIC INSTABILITIES

The aeroelastic evaluations including flutter, control reversal, divergence, and any undue loss
of stability and control as a result of structural loading and resulting deformation, are required.
Flutter and other aeroelastic instabilities must be avoided through design, quality control,
maintenance, and systems interaction.

a. The evaluation of composite structure needs to account for the effects of repeated
loading, environmental exposure, and service damage scenarios (e.g., large Category 2,
3 or 4 damage) on critical properties such as stiffness, mass and damping. Some control
surfaces exposed to large damage retain adequate residual strength margins, but the
potential loss of stiffness or mass increase (e.g., sandwich panel disbond and/or water
ingression) may adversely affect flutter and other aeroelastic characteristics. This is
particularly important for control surfaces that are prone to accidental damage and
environmental degradation. Other factors such as the weight or stiffness changes due to
repair, manufacturing flaws, and multiple layers of paint need to be evaluated. There may
also be issues associated with the proximity of high temperature heat sources near
structural components (e.g., empennage structure in the path of jet engine exhaust
streams or engine bleed air pneumatics system ducting). These effects may be
determined by analysis supported by test evidence, or by tests at the coupon, element or
sub-component level.

10. CONTINUED AIRWORTHINESS

The maintenance and repair of composite aircraft structure should meet all general, design and
fabrication, static strength, fatigue/damage tolerance, flutter, and other considerations

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covered by this AMC as appropriate for the particular type of structure and its application.

a. Design for Maintenance

Composite aircraft structure should be designed for inspection and repair access in a field
maintenance environment. The inspection and repair methods applied for structural
details should recognise the special documentation and training needed for critical
damage types that are difficult to detect, characterise and repair. The inspection intervals
and life limits for any structural details and levels of damage that preclude repair must be
clearly documented in the appropriate continued airworthiness documents.

b. Maintenance Practices
Maintenance manuals, developed by the appropriate organisations, should include
appropriate inspection, maintenance, and repair procedures for composite structures,
including jacking, disassembly, handling, part drying methods, and repainting instructions
(including restrictions for paint colours that increase structural temperatures). Special
equipment, repair materials, ancillary materials, tooling, processing procedures, and
other information needed for inspection or repair of a given part should be identified since
standard field practices, which have been substantiated for different aircraft types and
models, are not common.

(1) Damage Detection

(a) Procedures used for damage detection must be shown to be reliable and
capable of detecting degradation in structural integrity below ultimate load
capability. These procedures must be documented in the appropriate sections of the
instructions for continued airworthiness. This should be substantiated in static
strength, environmental resistance, fatigue, and damage tolerance efforts as
outlined in paragraphs 6, 7 and 8. Substantiated detection procedures will be
needed for all damage types identified by the threat assessment, including a wide
range of foreign object impact threats, manufacturing defects, and degradation
caused by overheating. Degradation in surface layers (e.g., paints and coatings)
that provide structural protection against ultraviolet exposure must be detected.
Any degradation to the lightning strike protection system that affects structural
integrity, fuel tank safety, and electrical systems must also be detected.

(b) Visual inspection is the predominant damage detection method used in the field
and should be performed under prescribed lighting conditions. Visual inspection
procedures should account for access, time relaxation in impact damage dent depth,
and the colour, finish and cleanliness of part surfaces.

(2) Inspection. Visual indications of damage, which are often used for composite
damage detection, provide limited details on the hidden parts of damage that require
further investigation. As a result, additional inspection procedures used for complete
composite damage characterisation will generally be different from those used for initial
damage detection and need to be well documented. Non-destructive inspection
performed prior to repair and destructive processing steps performed during repair must
be shown to locate and determine the full extent of the damage. In-process controls of
repair quality and post-repair inspection methods must be shown to be reliable and
capable of providing engineers with the data to determine degradation in structural
integrity below ultimate load capability caused by the process itself. Certain processing
defects cannot be reliably detected at completion of the repair (e.g., weak bonds). In
such cases, the damage threat assessment, repair design features and limits should
ensure sufficient damage tolerance.

(3) Repair. All bolted and bonded repair design and processing procedures applied for a
given structure shall be substantiated to meet the appropriate requirements. Of particular

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safety concern are the issues associated with bond material compatibilities, bond surface
preparation (including drying, cleaning, and chemical activation), cure thermal
management, composite machining, special composite fasteners, and installation
techniques, and the associated in-process control procedures. The surface layers (e.g.,
paints and coatings) that provide structural protection against ultraviolet exposure,
structural temperatures, and the lightning strike protection system must also be properly
repaired.

(4) Documentation and Reporting. Documentation on all repairs must be added to the
maintenance records for the specific part number. This information supports future
maintenance damage disposition and repair activities performed on the same part. It is
recommended that service difficulties, damage, and degradation occurring to composite
parts in service should be reported back to the design approval holder to aid in
continuous updates of damage threat assessments to support future design detail and
process improvements. Such information will also support future design criteria, analysis,
and test database development.

c. Substantiation of Repair

(1) When repair procedures are provided in Agency approved documents or the
maintenance manual, it should be demonstrated by analysis and/or test that the method
and techniques of repair will restore the structure to an airworthy condition. Repairable
damage limits (RDL), which outline the details for damage to structural components that
may be repaired based on existing data, must be clearly defined and documented.
Allowable damage limits (ADL), which do not require repair, must also be clearly defined
and documented. Both RDL and ADL must be based on sufficient analysis and test data to
meet the appropriate structural substantiation requirements and other considerations
outlined in this AMC. Additional substantiation data will generally be needed for damage
types and sizes not previously considered in design development. Some damage types
may require special instructions for field repair and the associated quality control. Bonded
repair is subjected to the same structural bonding considerations as the base design
(refer to paragraph 6.c).

(2) Operators and maintenance repair organisations (MRO) wishing to complete major
repairs or alterations outside the scope of approved repair documentation should be
aware of the extensive analysis, design, process, and test substantiation required to
ensure the airworthiness of a certificated structure. Documented records and the
certification approval of this substantiation should be retained in accordance with
regulations to support any subsequent maintenance activities.

d. Damage Detection, Inspection and Repair Competency

(1) All technicians, inspectors and engineers involved in damage disposition and repair
should have the necessary skills to perform their supporting maintenance tasks on a
specific composite structural part. The continuous demonstration of acquired skills goes
beyond initial training (e.g., similar to a welder qualification). The repair design,
inspection methods, and repair procedures used will require approved structural
substantiation data for the particular composite part. Society of Automotive Engineers
International (SAE) Aerospace Information Report (AIR) 5719 outlines training for an
awareness of the safety issues for composite maintenance and repair. Additional training
for specific skill building will be needed to execute particular engineering, inspection and
repair tasks.

(2) Pilots, ramp maintenance, and other operations personnel that service aircraft should
be trained to immediately report anomalous ramp incidents and flight events that may
potentially cause serious damage to composite aircraft structures. In particular,
immediate reporting is needed for those service events that are outside the scope of the

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damage tolerance substantiation and standard maintenance practices for a given

structure. The immediate detection of Category 4 and 5 damages are dependent on the
proper reaction of personnel that operate and service the aircraft.

11. ADDITIONAL CONSIDERATIONS

a. Crashworthiness

(1) The crashworthiness of the aircraft is dominated by the impact response

characteristics of the fuselage. Regulations, in general, evolve based on either experience
gained through incidents and accidents of existing aircraft or in anticipation of safety
issues raised by new designs. In the case of crashworthiness, regulations have evolved as
experience has been gained during actual aircraft operations. For example, emergency
load factors and passenger seat loads have been established to reflect dynamic conditions
observed from fleet experience and from controlled FAA and industry research. Fleet
experience has not demonstrated a need to have an aircraft level crashworthiness
standard. As a result, the regulations reflect the capabilities of traditional aluminium
aircraft structure under survivable crash conditions. This approach was satisfactory as
aircraft have continued to be designed using traditional construction methods. With the
advent of composite fuselage structure and/or the use of novel design, this historical
approach may no longer be sufficient to substantiate the same level of protection for the
passengers as provided by similar metallic designs.

(2) Airframe design should assure that occupants have every reasonable chance of
escaping serious injury under realistic and survivable crash impact conditions. A
composite design should account for unique behaviour and structural characteristics,
including major repairs or alterations, as compared with conventional metal airframe
designs. Structural evaluation may be done by test or analysis supported by test
evidence. Service experience may also support substantiation.

(3) The crash dynamics of an aircraft and the associated energy absorption are difficult
to model and fully define representative tests with respect to structural requirements.
Each aircraft product type (i.e., large aeroplane, small aeroplane, and rotorcraft) has
unique regulations governing the crashworthiness of particular aircraft structures. The
regulations and guidance associated with each product type should be used accordingly.
The regulations for large aeroplane and rotorcraft address some issues that go beyond
those required of small aeroplanes.

(4) Special conditions are anticipated for large aeroplanes with composite fuselage
structure to address crashworthiness survivability. The impact response of a composite
fuselage structure must be evaluated to ensure the survivability is not significantly
different from that of a similar-sized aircraft fabricated from metallic materials. Impact
loads and resultant structural deformation of the supporting airframe and floor structures
must be evaluated. Four main criteria areas should be considered in making such an
evaluation.

(a) Occupants must be protected during the impact event from release of items of mass
(e.g., overhead bins).

(b) At least the minimum number of emergency egress paths must remain following a
survivable crash.

(c) The acceleration and loads experienced by occupants during a survivable crash must
not exceed critical thresholds.

(d) A survivable volume of occupant space must be retained following the impact event.

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(5) The criticality of each of these four criteria will depend on the particular crash
conditions. For example, the loads and accelerations experienced by passengers may be
higher at lower impact velocities where structural failures have not started to occur. As a
result, validated analyses may be needed to practically cover all the crashworthiness
criteria for a fuselage.

(6) Existing large aeroplane requirements also require that fuel tank structural integrity
be addressed during a survivable crash impact event as related to fire safety (also refer
to paragraph 11.b). As related to crashworthiness, composite fuel tank structure must
not fail or deform to the extent that fire becomes a greater hazard than with metal
structure.

(7) Physics and mechanics of the crashworthiness for composite structures involve
several issues. The local strength, energy absorbing characteristics, and multiple
competing failure modes need to be addressed for composite structure subjected to a
survivable crash. This is not simply achieved for airframe structures made from
anisotropic, quasi-brittle, composite materials. As a result, the accelerations and load
histories experienced by passengers and equipment on a composite aircraft may differ
significantly from that seen on a similar metallic aircraft unless specific considerations are
designed into the composite structure. In addition, care should be taken when altering
composite structure to achieve specific mechanical behaviours. (For example, where the
change in behaviour of a metallic structure with a change in material thickness may be
easily predicted, an addition or deletion of plies to a composite laminate may also require
data for the effects of laminate stacking sequence on the failure mode and energy
absorption characteristics of a composite element).

(8) Representative structure must be included to gain valid test and analysis results.
Depending on aircraft loading (requiring investigation of various aircraft passenger and
cargo configurations), structural dynamic considerations, and progressive failures, local
strain rates and loading conditions may differ throughout the structure. Sensitivity of the
structural behaviour to reasonable impact orientation should also be considered for large
aeroplane and rotorcraft applications. This can be addressed by analysis supported by test
evidence.

(9) Considering a need for comparative assessments with metal structure and a range of
crash conditions, analysis with sufficient structural test evidence is often needed for large
aeroplane and rotorcraft applications. Analysis requires extensive investigation of model
sensitivity to modelling parameters (e.g., mesh optimisation, representation of joints,
element material input stress-strain data). Test also requires investigation of test
equipment sensitivity appropriate to composites (e.g., filter frequencies with respect to
expected pulse characteristics in the structure). Model validation may be achieved using a
building block approach, culminating in an adequately complex test (e.g., a drop test with
sufficient structural details to properly evaluate the crashworthiness criteria).

b. Fire Protection, Flammability and Thermal Issues

(1) Fire and exposure to temperatures that exceed maximum operating conditions
require special considerations for composite airframe structure. (Refer to note below).
Requirements for flammability and fire protection of aircraft structure attempt to
minimise the hazard to occupants in the event that flammable materials, fluids, or
vapours ignite. The regulations associated with each aircraft product type (i.e.,
transport, small airplane, rotorcraft) should be used accordingly. Compliance may
be shown by tests or analysis supported by test evidence. A composite design, including
repair and alterations, should not decrease the existing level of safety relative to metallic
structure. In addition, maintenance procedures should be available to evaluate the
structural integrity of any composite aircraft structures exposed to fire and temperatures
above the maximum operating conditions substantiated during design.

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 AMC 20-29

Note: Aircraft cabin interiors and baggage compartments have been areas of flammability
concerns in protecting passenger safety. This revision of the AMC does not address
composite materials used in aircraft interiors and baggage compartments. Please consult
other Guidance Material for Acceptable Means of Compliance with flammability rules for
interiors.

(2) Fire protection and flammability has traditionally been considered for engine mount
structure, firewalls, and other powerplant structures that include composite elements.
Additional issues critical to passenger safety have come with the expanded use of
composites in wing and fuselage structures for large aeroplanes. Existing regulations do
not address the potential for the airframe structure itself to be flammable. Wing and
fuselage applications should consider the effects of composite design and construction on
the resulting passenger safety in the event of in-flight fires or emergency landing
conditions, which combine with subsequent egress when a fuel-fed fire is possible.

(3) The results of fire protection and flammability testing with structural composite parts
indicate dependence upon overall design and process details, as well as the origin of the
fire and its extent. For example, the overall effects of composite fuselage structures
exposed to fire may be significantly different when the fire originates within the cabin,
where it can be controlled by limiting the structure’s contribution to spreading the fire,
than when the fire occurs exterior to the fuselage after a crash landing, where fuel is
likely to be the primary source for maintaining and spreading the fire. The threat in each
case is different, and the approach to mitigation may also be different. In-flight fire safety
addresses a fire originating within the aircraft due to some fault, whereas post-crash fire
safety addresses a fuel fed pool fire external to the aircraft. Special conditions are
anticipated for large aeroplanes with fuselage structure subjected to both in-flight and
post-crash fire conditions. Large aeroplane wing structure will need to have special
conditions for post-crash fire conditions.

(4) For an in-flight fire in large aeroplanes, it is critical that the fire not propagate or
generate hazardous quantities of toxic by-products. In-flight fires have been catastrophic
when they can grow in inaccessible areas. Composite fuselage structure could play a role
different from traditional metal structure if the issue is not addressed.

(5) Metallic large aeroplane fuselage and wing structures have established a benchmark
in fire protection that can be used to evaluate specific composite wing and fuselage
structural details. Exterior fire protection issues associated with composite structure must
include the effects of an exterior pool fire following a survivable crash landing. Fuselage
structure should provide sufficient time for passenger egress, without fire penetration or
the release of gasses and/or materials that are either toxic to escaping passengers or
reduce visibility (smoke density) or could increase the fire severity. Furthermore, these
considerations must be extended to wing and fuel tank structure, which must also be
prevented from collapse and release of fuel (including consideration of the influence of
fuel load upon the structural behaviour. For large aeroplanes, the standards of
CS 25.856(b) provide the benchmark to establish the required level of safety.

(6) The exposure of composite structures to high temperatures needs to extend beyond
the direct flammability and fire protection issues to other thermal issues. Many composite
materials have glass transition temperatures, which mark the onset of reductions in
strength and stiffness that are somewhat lower than the temperatures that can have a
similar effect on equivalent metallic structure. The glass transition temperature of most
composite materials is further reduced by moisture absorption. The reduced strength or
stiffness of composites from high temperature exposures must be understood per the
requirements of particular applications (e.g., engine or other system failures). After a
system failure and/or known fire, it may be difficult to detect the full extent of irreversible
heat damage to an exposed composite structure. As a result, composite structures

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 AMC 20-29

exposed to high temperatures may require special inspections, tests, and analysis for
proper disposition of heat damage. All appropriate damage threats and degradation
mechanisms need to be identified and integrated into the damage tolerance and
maintenance evaluation accordingly. Reliable inspections and test measurements of the
extent of damage that exists in a part exposed to unknown levels of high temperatures
should be documented. Particular attention should be given to defining the maximum
damages that likely could remain undetected by the selected inspection procedures.

c. Lightning Protection
Lightning protection design features are needed for composite aircraft structures. Current
Carbon fibre composites are approximately 1,000 times less electrically conductive than
standard aluminium materials, and composite resins and adhesives are traditionally non-
conductive. Glass and aramid fibre composites are non-conductive. A lightning strike to
composite structures can result in structural failure or large area damage, and it can
induce high lightning current and voltage on metal hydraulic tubes, fuel system tubes,
and electrical wiring if proper conductive lightning protection is not provided. Aircraft
lightning protection design guidance can be found in the FAA Technical Report “Aircraft
Lightning Protection Handbook” (See Appendix 1 2.a). The lightning protection
effectiveness for composite structures should be demonstrated by tests or analysis
supported by tests. Such tests are typically performed on panels, coupons,
subassemblies, or coupons representative of the aircraft structure, or tests on full
aircraft. The lightning test waveforms and lightning attachment zones are defined in
EUROCAE ED-84 and ED-91. Any structural damage observed in standard lightning tests
should be limited to Category 1, 2 or 3, depending on the level of detection. This damage
is characterised and integrated into damage tolerance analyses and tests as appropriate.
Small simple aeroplanes certified under CS-23 for VFR use only may be certified based on
engineering assessment, according to AC 23-15A. The effects of composite structural
repairs and maintenance on the lightning protection system should be evaluated. Repairs
should be designed to maintain lightning protection.

(1) Lightning Protection for Structural Integrity

(a) The composite structural design should incorporate the lightning protection
when appropriate for the anticipated lightning attachment. The extent of lightning
protection features depends on the lightning attachment zone designated for that
area of the aircraft. Lightning protection features may include, but are not limited
to, metal wires or mesh added to the outside surface of the composite structure
where direct lightning attachment is expected.

(b) When lightning strikes an aircraft, very high currents flow through the airframe.
Proper electrical bonding must be incorporated between structural parts. This is
difficult to achieve for moveable parts (e.g., ailerons, rudders and elevators). The
electrical bonding features must be sized to conduct the lightning currents or they
can vaporise, sending the high currents through unintended paths such as control
cables, control rods, or hydraulic tubes. Guidance for certification of lightning
protection of aircraft structures can be found in EUROCAE ED-113.

(2) Lightning Protection for Fuel Systems

(a) Special consideration must be given to the fuel system lightning protection for
an aircraft with integral fuel tanks in a composite structure. Composite structure
with integral fuel systems must incorporate specific lightning protection features on
the external composite surfaces, on joints, on fasteners, and for structural supports
for fuel system plumbing and components to eliminate structural penetration,
arcing, sparks or other ignition sources. AC 20-53B provides certification guidance
for aircraft fuel system lightning protection.

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(b) Large aeroplane regulations for fuel system ignition prevention in CS 25.981
require lightning protection that is failure tolerant. As a result, redundant and robust
lightning protection for composite structure joints and fasteners in fuel tank
structure is needed to ensure proper protection in preventing ignition sources.

(3) Lightning Protection for Electrical and Electronic Systems

(a) Lightning strike protection of composite structures is needed to avoid inducing

high lightning voltages and currents on the wiring for electrical and electronic
systems whose upset or damage could affect safe aircraft operation. The
consequences from a lightning strike of unprotected composite structures can be
catastrophic for electrical and electronic systems that perform highly critical
functions, such as fly-by-wire flight controls or engine controls.

(b) Electrical shields over system wiring and robust circuit design of electrical and
electronic equipment both provide some protection against system upset or damage
due to lightning. Since most composite materials provide poor shielding, at best,
metal foil or mesh is typically added to the composite structure to provide additional
shielding for wiring and equipment. Electrical bonding between composite structure
parts and panels should be provided for the shielding to be effective. EUROCAE
ED-81 and ED-107 provide certification guidance for aircraft electrical and electronic
system lightning protection.

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 AMC 20-29

Appendix 1 - Applicable CSs and Relevant Guidance

1. Applicable CSs. A list of applicable CS paragraphs is provided for subjects covered in

this AMC (see notes). In most cases, these CS paragraphs apply regardless of the type of
materials used in aircraft structures.

AMC Paragraphs CS-23 CS-25 CS-27 CS-29

1. Purpose of this AMC --------Not Applicable-----------------

2. To Whom this AMC Applies --------Not Applicable-----------------

3. Cancellation --------Not Applicable-----------------

4. Related Regulations and Guidance --------Not Applicable-----------------

5. General --------Not Applicable-----------------

6. Material and Fabrication

Development
603 603 603 603
605 605 605 605
609 609 609 609
613 613 613 613
619 619 619 619

7. Proof of Structure – Static 305 305 305 305

307 307 307 307

8. Proof of Structure – Fatigue

and Damage Tolerance
573 571 571 571

9. Proof of Structure – Flutter

629 629 629 629

10. Continued Airworthiness 1529 1529 1529 1529

App. G App. H App. A App. A

11. Additional Considerations

a. Crashworthiness
(including impact dynamics)
561 561 561 561
562 562 562 562
601 601 601 601
631 631
721 721
783 783 783 783
785 785 785 785
787 787 787 787
789
801 801 801
803
807 807

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 AMC 20-29

809 809
963 963 963
965 965 965
967 967 967 967
981

b. Fire Protection, Flammability

and Thermal Issues

609 609 609 609

853 853 853 853

855 855 855 855
859 859 859 859
861 861
863 863 863 863
865 865
867
903 903 903

1121 1121 1121 1121

1181 1181 1181
1182 1182
1183 1183 1183 1183
1185 1185 1185
1187 1187
1189 1189 1189 1189
1191 1191 1191 1191
1193 1193 1193 1193
1194 1194
1359
1365

c. Lightning Protection
* see AMC 25.899 para.6
581*
609 609 609 609
610 610
867
899*
954 954* 954 954
981
1309 1309 1309
1316

---------------------------------------

Notes:
(1) This list may not be all inclusive and there may be differences between certification
agencies (e.g. FAA and the Agency).
(2) Special conditions may be issued in accordance with Part-21 21A.16B for novel and
unusual design features (e.g., new composite materials systems).

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 AMC 20-29

2. Guidance
FAA issues guidance providing supportive information of showing compliance with regulatory
requirements. Guidance may include the advisory circulars (AC) and policy statements (PS). In
general, an AC presents information concerning acceptable means, but not the only means, of
complying with regulations. The guidance listed below is deemed supportive to the purposes of
this AMC. These FAA documents can be located via website:
http://www.faa.gov/regulations_policies/. In addition, EUROCAE have developed industry
standards that are recognised by the Agency.

Note: Many of the FAA documents are harmonised with EASA. Applicants should confirm with
the Agency if in doubt regarding the status and acceptance of any such documents by the
Agency.

a. FAA/EUROCAE guidance documents

 AC 20-53B “Protection of Airplane Fuel Systems Against Fuel Vapor Ignition Due to
Lightning” [6/06]
 AC 20-135 "Powerplant Installation and Propulsion System Component Fire
Protection Test Methods, Standards, and Criteria" [2/90]
 AC 21-26 "Quality Control for the Manufacture of Composite Structures" [6/89]
 AC 21-31 "Quality Control for the Manufacture of Non-Metallic Compartment
Interior Components" [11/91]
 AC 23-15A “Small Airplane Certification Compliance Program” [12/03]
 AC 23-20 "Acceptance Guidance on Material Procurement and Process Specifications
for Polymer Matrix Composite Systems" [9/03]
 AC 25.571-1C “Damage Tolerance and Fatigue Evaluation of Structure” [4/98]
 AC 29 MG 8 “Substantiation of Composite Rotorcraft Structure” [4/06]
 AC 35.37-1A "Guidance Material for Fatigue Limit Tests and Composite Blade
Fatigue Substantiation" [9/01]
 AC 145-6 "Repair Stations for Composite and Bonded Aircraft Structure" [11/96]
 RTCA DO-160 / EUROCAE ED-14
 EUROCAE ED-81 “Certification of Aircraft Electrical/Electronic Systems for the
Indirect Effects of Lightning”
 EUROCAE ED-84 “Aircraft Lightning Environment and Related Test Waveforms”
 EUROCAE ED-91 “Aircraft Lightning Zoning”
 EUROCAE ED-107 “Guide to Certification of Aircraft in a High Intensity Radiated
Field (HIRF)”
 EUROCAE ED-113 Aircraft Lightning Direct Effects Certification
 EUROCAE ED-14E Environmental Conditions and Test Procedures for Airborne
Equipment
 FAA Technical Report “Aircraft Lightning Protection Handbook” (DOT/FAA/CT-
89/22).
b. FAA Policy Statements
 "Static Strength Substantiation of Composite Airplane Structure"
[PS-ACE100-2001-006, December 2001]
 "Final Policy for Flammability Testing per 14 CFR Part 23, Sections 23.853, 23.855
and 23.1359" [PS-ACE100-2001-002, January 2002]
 “Material Qualification and Equivalency for Polymer Matrix Composite Material
Systems" [PS-ACE100-2002-006, September 2003]
 “Bonded Joints and Structures - Technical Issues and Certification
Considerations” [PS-ACE100-2005-10038, September 2005]

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Appendix 2 – Definitions

The following definitions are applicable to AMC 20-29 and relevant CS paragraphs only.

Allowables: Material values that are determined from test data at the laminate or lamina
level on a probability basis (e.g., A or B basis values, with 99% probability and 95%
confidence, or 90% probability and 95% confidence, respectively). The amount of data
required to derive these values is governed by the statistical significance (or basis) needed.

Anisotropic: Not isotropic; having mechanical and/or physical properties which vary with
direction relative to natural reference axes inherent in the material.

Arrested Growth Approach: A method that requires demonstration that the structure, with
defined flaws present, is able to withstand appropriate repeated loads with flaw growth which
is either mechanically arrested or terminated before becoming critical (residual static strength
reduced to limit load). This is to be associated with appropriate inspection intervals and
damage detectability.

Category of Damage: One of five categories of damage based on residual strength capability,
required load level, detectability, inspection interval, damage threat and whether (or not) the
event creating damage is self-evident (see Section 8(a)(1)(c)).

Component: A major section of the airframe structure (e.g., wing, body, fin, horizontal
stabiliser) which can be tested as a complete unit to qualify the structure.

Coupon: A small test specimen (e.g., usually a flat laminate) for evaluation of basic lamina or
laminate properties or properties of generic structural features (e.g., bonded or mechanically
fastened joints).

Critical Structure: A load bearing structure/element whose integrity is essential in

maintaining the overall flight safety of the aircraft. This definition was adopted for this AMC
because there are differences in the definitions of primary structure, secondary structure, and
principle structural elements (PSE) when considering the different categories of aircraft. For
example, PSE are critical structures for Large Aeroplanes.

Damage: A structural anomaly caused by manufacturing (processing, fabrication, assembly

or handling) or service usage.

Debond: Same as Disbond.

Degradation: The alteration of material properties (e.g., strength, modulus, coefficient of

expansion) which may result from deviations in manufacturing or from repeated loading and/or
environmental exposure.

Delamination: The separation of the layers of material in a laminate. This may be local or
may cover a large area of the laminate. It may occur at any time in the cure or subsequent life
of the laminate and may arise from a wide variety of causes.

Design Values: Material, structural elements, and structural detail properties that have been
determined from test data and chosen to assure a high degree of confidence in the integrity of
the completed structure. These values are most often based on allowables adjusted to account
for actual structural conditions, and used in analysis to compute margins-of-safety.

Detail: A non-generic structural element of a more complex structural member (e.g., specific
design configured joints, splices, stringers, stringer runouts, or major access holes).

Disbond: An area within a bonded interface between two adherends in which an adhesion

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 AMC 20-29

failure or separation has occurred. It may occur at any time during the life of the substructure
and may arise from a wide variety of causes. Also, colloquially, an area of separation between
two laminae in the finished laminate (in this case the term “delamination” is normally
preferred).

Discrepancy: A manufacturing anomaly allowed and detected by the planned inspection

procedure. They can be created by processing, fabrication or assembly procedures.

Element: A generic part of a more complex structural member (e.g., skin, stringers, shear
panels, sandwich panels, joints, or splices).

Environment: External, non-accidental conditions (excluding mechanical loading), separately

or in combination, that can be expected in service and which may affect the structure (e.g.,
temperature, moisture, UV radiation, and fuel).

Factor(s):

- Life (or Load) Enhancement Factor: An additional load factor and/or test duration
applied to structural repeated load tests, relative to the intended design load and life
values, used to account for material variability. It is used to develop the required level of
confidence in data.
- Life Scatter Factor: Same as Life/Load Enhancement Factor.
- Overload Factor: A load factor applied to a specific structure test which is used to
address parameters (e.g., environment, a short test pyramid, etc.) not directly addressed
in that test. This factor is usually developed from lower pyramid testing addressing such
parameters.

Heterogeneous: Descriptive term for a material consisting of dissimilar constituents

separately identifiable; a medium consisting of regions of unlike properties separated by
internal boundaries.

Intrinsic Flaw: Defect inherent in the composite material or resulting from the production
process.

Manufacturing Defect: An anomaly or flaw occurring during manufacturing that can cause
varying levels of degradation in structural strength, stiffness and dimensional stability. Those
manufacturing defects (or permissible manufacturing variability) allowed by the quality control,
manufacturing acceptance criteria are expected to meet appropriate structural requirements
for the life of the aircraft part. Other manufacturing defects that escape detection in
manufacturing quality control should be included in a damage threat assessment and must
meet damage tolerance requirements until detected and repaired.

No-Growth Approach: A method that requires demonstration that the structure, with defined
flaws present, is able to withstand appropriate repeated loads without detrimental flaw growth
for the life of the structure.

Primary Structure: The structure which carries flight, ground, or pressurisation loads, and
whose failure would reduce the structural integrity of the aircraft.

Point Design: An element or detail of a specific design which is not considered generically
applicable to other structure for the purpose of substantiation, e.g., lugs and major joints.
Such a design element or detail can be qualified by test or by a combination of test and
analysis.

Slow Growth Approach: A method that requires demonstration that the structure, with
defined flaws present, is able to withstand appropriate repeated loads with slow, stable, and
predictable flaw growth for the life of the structure, or beyond appropriate inspection intervals

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 AMC 20-29

associated with appropriate damage detectability.

Structural Bonding: A structural joint created by the process of adhesive bonding,

comprising of one or more previously-cured composite or metal parts (referred to as
adherends).

Sub-component: A major three-dimensional structure which can provide completed structural

representation of a section of the full structure (e.g., stub-box, section of a spar, wing panel,
body panel with frames).

Weak Bond: A bond line with mechanical properties lower than expected, but without any
possibility to detect that by normal NDI procedures. Such situation is mainly due to a poor
chemical bonding.

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 AMC 20-29

Appendix 3 - Change of Composite Material and/or Process

1. It is necessary to re-certify composite structures, which during production, incorporate

substitutions of, or changes to, the materials and/or processes from those originally
substantiated at the time of initial certification. For example, the original material supplier
may either change its product, or cease production. Manufacturers may also find it
necessary to modify their production processes to improve efficiency or correct product
deficiencies. In either case, care must be taken to ensure that modifications and/or
changes are adequately investigated to ensure the continued adequacy of already
certificated composite structure. This appendix covers such material and/or process
changes, but does not address other changes to design (e.g., geometry, loading). The
definition of the materials and processes used is required in the specifications by
Part 21A.31. Changes to the material and process specifications are often major changes
in type design and must be addressed as such under Part-21, subpart D or E as
applicable.

2. The qualification and structural substantiation of new or modified materials and/or

processes used to produce parts of a previously certified aircraft product requires:

a. The identification of the key material and/or process parameters governing

performances;
b. The definition of the appropriate tests able to measure these parameters; and
c. The definition of pass/fail criteria for these tests.

3. ‘Qualification’ procedures developed by every manufacturer include specifications

covering:
a. Physical and chemical properties,
b. Mechanical properties (coupon level), and
c. Reproducibility (by testing several batches).

4. Specifications and manufacturing quality procedures are designed to control specific

materials and processes to achieve stable and repeatable structure for that combination
of materials and processes. However, the interchangeability of alternate materials and
processes for a structural application cannot be assumed if one only considers the
properties outlined in those specifications (as it could be for materials that are much less
process dependent, e.g., some metallic material forms). A structure fabricated using new
or modified materials and/or processes, which meet the ‘qualification’ tests required for
the original material and process specifications, does not necessarily produce components
that meet all the original engineering requirements for the previously certified structure.

5. Until improvements in identifying the complex relations between key material parameters
that govern composite processing occurs, there will be a need for extensive and diverse
testing that directly interrogates material performance using a range of representative
specimens of increasing complexity in building block tests. Furthermore, failure modes
may vary from one material and/or process to another, and analytical models are
sometimes insufficiently precise to reliably predict failure without sufficient empirical
data. Therefore, a step-by-step test verification with more complex specimens may be
required.

6. Classification of Material or Process Change

Material and/or process changes require appropriate classification in order to aid the
determination of the extent of investigation necessary. Some minor changes may only
require material equivalency sampling tests to be completed at the base of the test
pyramid, whilst more significant changes will require more extensive investigations,
including possibly a new structural substantiation.
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 AMC 20-29

a. Any of the following situations requires further investigation of possible changes to a

given composite structure:

(1) Case A: A change in one or both of the basic constituents, resin, or fibre (including
sizing or surface treatment alone) would yield an alternate material. Other changes that
result in an alternate material include changes in fabric weave style, fibre aerial weight
and resin content.

(2) Case B: Same basic constituents, but any change of the resin impregnation method.
Such changes include: (i) prepregging process (e.g., solvent bath to hot melt coating),
(ii) tow size (3k, 6k, 12k) for tape material forms with the same fibre areal weight, (iii)
prepregging machine at the same suppliers, (iv) supplier change for a same material
(licensed supplier).

(3) Case C: Same material, but modification of the processing route (if the modification
to the processing route governs eventual composite mechanical properties). Example
process changes of significance include: (i) curing cycle, (ii) bond surface preparation,
(iii) changes in the resin transfer moulding process used in fabricating parts from dry
fibre forms, (iv) tooling, (v) lay-up method, (vi) environmental parameters of the
material lay-up room, and (vii) major assembly procedures.

b. For each of the above cases, a distinction should be made between those changes
intended to be a replica of the former material/process combination (Case B and some of
Case C) and those which are “truly new material” (Case A and some of Case C). So, two
classes are proposed:

(1) “Identical materials/processes” in cases intended to create a replica structure.

(2) “Alternative materials/processes” in cases intended to create truly new structure.

c. Within the “identical materials/processes” class, a sub-classification can be made

between a change of the prepregging machine alone at the supplier and licensed
production elsewhere. For the time being, a change to a new fibre produced under a
licensed process and reputed to be a replica of the former one, will be dealt with as an
“alternative material/process”.

d. Some minor changes within the class representing identical materials/processes may not
interact with structural performances (e.g., prepreg release papers, some bagging
materials, etc.) and should not be submitted to the Agency as part of the change.
However, the manufacturers (or the supplier) should develop a proper system for
screening those changes, with adequate proficiency at all relevant decision levels. Other
minor material changes that fall under Case B may warrant sampling tests to show
equivalency only at lower levels of building block substantiation.

e. Case C changes that may yield major changes in material and structural performance
need to be evaluated at all appropriate levels of the building block tests to determine
whether the manufacturing process change yields identical or alternate materials.
Engineering judgment will be needed in determining the extent of testing based on the
proposed manufacturing change.

f. Case A (alternative material) should always be considered as an important change, which

requires structural substantiation. It is not recommended to try a sub-classification
according to the basic constituents being changed, as material behaviour (e.g., sensitivity
to stress concentrations) may be governed by interfacial properties, which may be
affected by either a fibre or a resin change.

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 AMC 20-29

7. Substantiation Method. Only the technical aspects of substantiation are addressed

below.

a. Compliance Philosophy. Substantiation should be based on a comparability study

between the structural performances of the material accepted for type certification, and
the second material. Whatever the modification proposed for a certificated item, the
revised margins of safety should remain adequate. Any reduction in the previously
demonstrated margin should be investigated in detail.

(1) Alternative Material/Process: New design values for all relevant properties should
be determined for any alternate material/process combination. Analytical models initially
used to certify structure, including failure prediction models, should be reviewed and, if
necessary, substantiated by tests. The procurement specification should be modified (or a
new specification suited to the selected material should be defined) to ensure key quality
variations are adequately controlled and new acceptance criteria defined. For example,
changing from first to second generation of carbon fibres may improve tensile strength
properties by more than 20% and a new acceptability threshold will be needed in the
specification of the alternate material to ensure the detection of quality variations.

(2) Identical Material: Data should be provided that demonstrates that the original
design values (whatever the level of investigation, material or design) remain valid.
Statistical methods need to be employed for data to ensure that key design properties
come from the same populations as the original material/process combination.
Calculation models including failure prediction should remain the same. The technical
content of the procurement specification (Case B) should not need to be changed to
properly control quality.

b. Testing.

(1) The extent of testing needed to substantiate a material change should address the
inherent structural behaviour of the composite and will be a function of the airworthiness
significance of the part and the material change definition. For example, the investigation
level might be restricted to the generic specimens at the test pyramid base (refer to
figures in paragraph 7) for an identical material, but non-generic test articles from higher
up the pyramid should be included for an alternative material. Care needs to be taken to
ensure that the test methods used yield data compatible with data used to determine
properties of the original structure.

(2) The testing that may be required for a range of possible material and/or process
changes should consider all levels of structural substantiation that may be affected. In
some instances (e.g., a minor cure cycle change), possible consequences can be
assessed by tests on generic specimens only. For other changes, like those involving
tooling (e.g., from a full bag process to thermo-expansive cores), the assessment should
include an evaluation of the component itself (sometimes called the “tool proof test”). In
this case, an expanded NDI procedure should be required for the first items to be
produced. This should be supplemented – if deemed necessary – by “cut up” specimens
from a representative component, for physical or mechanical investigations.

c. Number of Batches.

(1) The purpose for testing a number of batches is the demonstration of an acceptable
reproducibility of material characteristics. The number of batches required should take
into account: material classification (identical or alternative), the investigation level (non-
generic or generic specimen) the source of supply, and the property under investigation.
Care should be taken to investigate the variation of both basic material and the
manufacturing process.

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 AMC 20-29

(2) Existing references (e.g., The Composite Materials Handbook (CMH-17) Volumes 1
and 3, FAA Technical Report DOT/ FAA/AR-03/19), addressing composite qualification and
equivalence and the building block approach, provide more detailed guidance regarding
batch and test numbers and the appropriate statistical analysis up to laminate level.
Changes at higher pyramid levels, or those associated with other material forms, e.g.,
braided VARTM (Vacuum-Assisted Resin Transfer Moulding) structure, may require use of
other statistical procedures or engineering methods.

d. Pass/Fail Criteria. Target pass/fail criteria should be established as part of the test
programme. For strength considerations for instance, a statistical analysis of test data
should demonstrate that new design values derived for the second material provide an
adequate margin of safety. Therefore, provision should be made for a sufficient number
of test specimens to allow for such analysis. At the non-generic level, when only one test
article is used to assess a structural feature, the pass criteria should be a result
acceptable with respect to design ultimate loads. In the cases where test results show
lower margins of safety, certification documentation will need to be revised.

e. Other Considerations. For characteristics other than static strength (all those listed in
AMC 20-29, paragraphs 8, 9, 10 and 11), the substantiation should also ensure an
equivalent level of safety.

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