Bonded Structure Task Extension-Final Report

Transport Airplane Metallic and Composite Structures Working Group Recommendation Report – Structural Bonding
Page 1 of 123
Transport Airplane Metallic and Composite

Structures Working Group –
Recommendation Report to FAA
Structural Bonding
RELEASE/REVISION RELEASE DATE

Final 7/29/2021
CONTENT OWNER:
Transport Airplane Metallic and Composite Structures Working Group
All revisions to this document must be approved by the content owner before release.
1
Transport Airplane Metallic and Composite Structures Working Group Recommendation Report – Structural
Bonding Page 2 of 123
Document Information
Authorization for Release
AUTHOR/CONCURRENCE: Chantal Fualdes Airbus 7/27/2021

Chantal Fualdes - Digital Signature Organization Date
AUTHOR/CONCURRENCE: Boeing
Kevin Davis Commercial 7/27/2021
Kevin Davis - Digital Signature Organization Date
CONCURRENCE: Salamon Haravan Bombardier 7/26/2021

Salamon Haravan - Digital Signature Organization Date
CONCURRENCE: Ryan Higgins British Airways 7/27/2021

Ryan Higgins - Digital Signature Organization Date
CONCURRENCE: Dassault
Benoit Morlet Aviation 7/27/2021
Benoit Morlet - Digital Signature Organization Date
CONCURRENCE: Douglas Jury Delta Air Lines 7/26/2021

Doug Jury - Digital Signature Organization Date
CONCURRENCE: Antonio Fernando Barbosa Embraer 7/27/2021

Antonio Fernando Barbosa - Digital Signature Organization Date
CONCURRENCE: Mark Boudreau FedEx 7/27/2021

Mark Boudreau - Digital Signature Organization Date
CONCURRENCE: Kevin Jones Gulfstream 7/27/2021

Kevin Jones - Digital Signature Organization Date
CONCURRENCE: Toshiyasu Fukuoka 福岡俊康 Mitsubishi 7/27/2021

Toshiyasu Fukuoka - Digital Signature Organization Date
CONCURRENCE: Textron
David K. Nelson Aviation 7/29/2021
David Nelson - Digital Signature Organization Date
AUTHOR/CONCURRENCE: Eric Chesmar United Airlines 7/27/2021

Eric Chesmar - Digital Signature Organization Date
CONCURRENCE: Linda Jahner FAA 7/26/2021

Linda Jahner- Digital Signature Organization Date
NEW *Please note: The electronic signatures above confirm both concurrence with the information 2 of 123
contained within the document and the authorization of it's release. Thank you.
Page 3 of 123
ACKNOWLEDGMENTS
The Transport Airplane Metallic and Composites Structures Working Group expresses our appreciation to
the following individuals who made meaningful contributions to our team. Our work would not be
complete without their generous involvement.
The TAMCSWG expresses our deepest appreciation and gratitude to Dr. Larry Ilcewicz, FAA Chief
Scientific Technical Advisor, Composites, whose experience and passion for this material is and support
of the industry and commitment to the safety of the flying public is remarkable. His tireless support to
this group is recognized and without parallel.
Mr. Walter Sippel, FAA Aerospace Engineer, has also been a great asset to this working group. He has
provided valuable guidance and oversight as a deeply knowledgeable regulator. He has demonstrated he
is a wonderful public servant.
Mr. Allen Fawcett, Boeing Engineer (retired), played a significant role in providing suggestions and
review of the material and his extensive experience with composites and bonding served as a great
resource to our team.
Mr. Simon Waite and Mr. Richard Minter, EASA, and Mr. Phil Ashwell, UK CAA, have all also
provided additional valuable perspectives from the international regulatory communities to ensure we are
all meeting aligned objectives as part of a global team focused first and foremost on safety.
Mr. Guilherme Garcia Momm, ANAC Airframe Engineer and PhD candidate, also provided thoughtful
input to our group related to his academic endeavors to address structural bonding and collection of
industry case studies.
Mr. Andries Buitenhuis, Fokker Chief Engineer, shared with the WG at late notice presentation material
on their experiences with metal bonds, both with service difficulties and quality control programs. This
material, incorporated into this report, is helpful in developing our recommendations.
3
Page 4 of 123
Table of Contents
1.0 Executive Summary 5

2.0 Bonded Structure Task Extension 9
2.1 Extended Tasking Description and Work Plan Summary 9
2.2 Introduction 11
2.3 Summary of the Bonding Task from 2018 Final Report 12
2.4 Detailed Work Plan 12
3.0 Rules recommendations 14
3.1 Rule changes 14
4.0 Guidance recommendations 16
4.1 Historic Perspectives on Existing Guidance 16
4.2 Experiences of OEM and Best Practices Guidance Improvements 16
4.2.1 AC 25.571-1D 16
4.2.2 AC 20-107B 19
4.2.3 AC 21-26A Quality System for the Manufacture of Composite Structure 21
4.2.4 Bonded Structural Considerations 23
4.2.4.1 Structural Redundancy – SLP and SDC 23
4.2.4.2 Other Structural Considerations 28
4.2.4.3 Adhesion Failure 28
4.2.5 Maintenance Repair and Inspection Considerations 29
4.2.6 Practical Inspection Considerations 37
4.2.7 Possible Aging Limits to Metal and Composite Bonding 39
5.0 Costs & Benefits Analysis 40
5.1 Cost 40
5.2 Benefits 42
6.0 References 42
7.0 APPENDIX 44
7.1 Appendix 1: Historic review of existing guidance 44
7.2 Appendix 2: Quality control plan for composite bonding in OEM 56
7.3 Appendix 3: Recommended AC 20-107B Updates 74
7.4 Appendix 4: Recommended AC25.571-1D Updates 79
8.0 List of Acronyms 122
4
Page 5 of 123
1.0 Executive Summary

On January 26, 2015, the FAA published a notice of a new task assignment for the Aviation Rulemaking
Advisory Committee (ARAC). In short, the FAA assigned and ARAC accepted the task to provide
recommendations regarding revision of the damage tolerance and fatigue requirements of Title 14, Code
of Federal Regulations (14 CFR), part 25, including subparts C and E of 14 CFR part 26. In addition, the
ARAC accepted a related task for development of associated advisory material for metallic, composite,
and hybrid structures (structure that includes a combination of composite and metallic parts and
assemblies). Under the Transport Airplane and Engine (TAE) Subcommittee, the Transport Airplane
Metallic and Composite Structures Working Group (TAMCSWG) provided advice and recommendations
on the tasking. The TAMCSWG provided a final report, which included recommendations on a broad
variety of related topics to TAE and ARAC. This initial final report, released on June 27, 2018, is
publicly available at:
(https://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/TAMCSWG%20Re
commendation%20Report.pdf).
During the review and acceptance of this report by ARAC, three separate follow-on tasks required an
extension of the original tasking to include:
1. Develop requirements and guidance material for single load path (SLP) structure
2. Provide further clarification on how to address disbonds and weak bonds as a manufacturing
defect in both monolithic bonded and sandwich structure (composite and metal)
3. Provide requirements and guidance on how to address crack interaction when establishing
inspection programs
None of these three tasks change the primary recommendations made in 2018. Each of the three topics
used the same approach applied in the original tasking effort, which includes:
A. Evaluate current § 25.571, subparts C and E of part 26, and guidance material
B. Recommend Rule or Guidance changes
C. Estimate the Costs and Benefits associated with any changes
With concurrence from TAE and ARAC, the Working Group decided to address each of the three
extension topics in standalone reports supplemental to the original report released in 2018. The final
report on the topic of SLP structure, released on November 20, 2020, is publicly available at:
https://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/TAMCSWG%20SLP
%20Recommendation%20Report%20December%202020%20(Submitted%2012-11-2020).pdf. This
report addresses the second topic, bonded structures. At the time of the release of this report, the
TAMCSWG was still developing the report to address the third topic on crack interaction. Although each
report has its own recommendations, there is some overlap between the subjects. For example, the
TAMCSWG recommended that guidance should note current best design practice for SLP principal
structural elements (PSE) does not include bonded structural details within the critical load path of such
parts. In addition, any considerations that would allow exceptions to the best practice should be identified
during certification.
5
Page 6 of 123
As discussed in this report, the TAMCSWG recommends no additional rule changes beyond that
described in the initial 2018 report. As a result, this report provides the recommendations and rationale for
guidance changes, the rationale for no rule changes, and lastly the cost and benefit analyses associated
with these recommendations for the topic of bonded structures. It also discusses the knowledge transfer
challenges in sharing Original Equipment Manufacturer (OEM) (herein also referred to as type certificate
holder, TCH) composite structural substantiation experiences such as those used for repair and inspection
procedures development with end users, which include the airlines, cargo air transportation and
maintenance organizations. Such efforts will be even more important in the future, as the use of
composite and metallic hybrid bonded assemblies expand and increase in complexity.
As detailed in the final 2018 TAMCSWG Report, bonded structural repair, rework and concessions
received significant coverage. That report recommended no rule changes because repairs must meet the
same certification standard as the original or modified structure. However, the 2018 TAMCSWG Report
recommended that the FAA add guidance in Advisory Circular (AC) 25.571-1D and AC 20-107B to
address bonded repairs. This guidance would clarify that repairs accomplished in a production facility
can occur in-service if incorporating the same stringent quality controls. Since field repair substantiation
is difficult, the TAMCSWG recommends support by the TCH and regulator to develop affordable,
approved data for repair design, which meet the original certification regulations. It is important to note
that the TCH often adds their own requirements to certification regulations and, if essential to safe
applications, the TCH must help ensure sufficient knowledge transfer exist for field repair efforts to avoid
any future problems. All of the 2018 TAMCSWG Report recommendations in this area remain valid.
In addition, the 2018 TAMCSWG Report recommended the FAA clarify that the same stringent structural
damage capabilities (SDC) stated in FAA policy letter PS-AIR-20-130-01 applies to in service and
production repairs. Expectations prescribed in AC 20-107B for production repairs/rework/concessions
accomplished by the TCH and its suppliers, are within the size limit established by TCH to meet no less
than limit load if repair fails. The wording in both documents needs to be consistent to avoid any
confusion. This report not only clarifies that expectation but also clarifies that any bonded baseline
structure classified as a PSE, typically has a consistent SDC, or equivalent level of fail safety, in today’s
existing company-specific design criteria.
This report further addresses bonding considerations during product design, production and maintenance.
Field inspection and repair practices are critical items covered in a dedicated section of the report. Over
the last 15 years, standards organizations such as Composite Materials Handbook 17 (CMH)-17 and SAE
Commercial Aircraft Composite Repair Committee (CACRC) have further benchmarked current bonding
practices. During those efforts, the OEM, airlines and maintenance organizations have identified the root
causes of field problems, many of which started with a general lack of overall inspection and repair
standardization. This remains a significant challenge for industry, given all of the new composite
applications currently occurring for modern aircraft.
The industry is pursuing more bonded structure standards, considering the limited few that publicly exist.
There is also a need for new resources and facilities, with skills, equipment and tooling to deal with the
quickly expanding applications. The FAA considers this challenge as a serious safety threat that must not
be overlooked for the industry to efficiently move forward and realize the advantages possible with more
standard design details (e.g., repair materials, structural features), procedures, and an associated
knowledge base that promotes the ease of distance learning and continuous education. The CMH-17 next
revision will have many additions in practical guidelines and best industry practices for bonded structure.
6
Page 7 of 123
The TAMCSWG bonded structure extension effort started by seeking clarity from the FAA on the tasking
statement, which simply requested support on how to address disbond and weak bonds as manufacturing
defects. Bonding is an essential subject for composite structural integrity and appears in many sections of
the primary related guidance, AC 20-107B, including design and fabrication development, material and
process control, static strength, fatigue & damage tolerance and continued operational safety. Bonding is
not mentioned in §25.571 or AC 25.571-1D, despite the fact it was a significant safety concern for past
metal-bonded PSE details. Figure 1 gives a synopsis of the bonded structure extension efforts, whereby
priorities for safety risk mitigation appear in order with the highest priority on top. This notional
hierarchy helped guide the TAMCSWG efforts in documenting the proposals contained within. It is the
TAMCSWG’s position that all of the recommendations shown in this figure need guidance updates,
without specific rule changes. Standards organizations should continue to work the challenges of
knowledge transfer by documenting more consistent and efficient standard practices for structural bond
design, structural substantiation, maintenance inspection and repair processing (in process quality control
and post-process non-destructive inspection (NDI)).
Figure 1. Bonded Structural Integrity Priorities listed from top to bottom in order of importance.
It is clear that stringent material and process controls are an essential prerequisite for use of bonded
structures in critical structures. As noted in AC 20-107B, PSE are critical structures for Transport
Category Aircraft. In principle, all bonded structures that may fail in flight due to a lack of such controls
and potentially depart the aircraft, may cause safety problems for other structures and; therefore, best
industry practice is to establish stringent material and process controls for bonding.
Figure 1 also lists safety priorities for use of bonded structures. Manufacturing defects called weak bonds
for metallic structure and weak or understrength bonds for composite structure are unacceptable, and their
existence needs to be extremely rare. They should also be no larger than structural redundant features,
7
Page 8 of 123
which can reliably retain limit load until found with proven inspection procedures. Note that this industry
expectation goes beyond past protocol, to include substantiation of damage tolerant repeated load
tolerance. Any significant bond adhesion failures found in process qualification, certification testing,
production or service use are unacceptable and require immediate corrective action. Traditional damage
tolerance procedures used for metallic and composite structures for fatigue (slow and arrested growth),
accidental damage and environmental degradation have proven acceptable for bonded structures subjected
to stringent material and process controls, assuming proper coverage of the other design and failure
conditions shown in Figure 1. Nevertheless, the industry prefers the composite bonded design approach
involving “no growth,” whereby structural details and related design strains are kept at levels where
damage growth is suppressed. These general thoughts require further attention in updates to AC 25.571-
1D and AC 20-107B, as noted in this report, including example detailed changes provided in appendices.
In combination, the bonded structural integrity priorities identified in Figure 1 recommends that the
design use of SLP with bonded structural details in the critical load path be avoided (in essence, it is
believed that such structure may have critical flaw sizes that are too small to safely control even with
stringent bond material and process controls). Under certain circumstances, a given bonded SLP design
may overcome this limitation without specific redundant design features through low design stress levels
and other considerations, which yield sufficient damage tolerance and service life goals.
This report justifies the need, and provides detailed specific recommendations, for changes to AC 20-
107B and AC 25.571-1D, as identified in appendix 3 and appendix 4, with the former continuing to
contain most bonding guidance. All items listed in Figure 1 have importance with priorities previously
defined and the recommendations given in appendices provide example updates. The existing composite
guidance is very good at giving bonded structure material and process controls the highest priority of
issues described in Figure 1.
One significant update recommended for AC 20-107B is the dual classification of the large SDC,
currently covered as the structural redundancy expectation in the section for Material and Fabrication
Design Development (Paragraph 6c: Structural Bonding), to now also be explicitly treated as a Category
2 damage threat for Paragraph 8 (Proof of Structure – Fatigue & Damage Tolerance) because a scheduled
inspection will be needed to ensure it was found. This recommendation was added because a disbonding
or delamination threat for some structural details may be hard to find using the selected damage detection
methods (note that most composite damage detection initially use visual methods to first detect damage
prior to NDI inspection for a complete damage characterization) and the large Category 3 damage is
defined such that it will be found within a few flights of occurrence.
When using visual detection methods such as surveillance or detailed visual approaches, the disbond or
delamination must be large and the structure should have sufficient damage tolerance to be found during
heavy maintenance checks with access to fuselage or torque box internal structures. Such classification
requires a fatigue no growth demonstration of a traditional SDC-type disbond defined in company-
specific damage tolerance design criteria (DTDC) for a Category 2 damage. TAMCSWG members all
agreed on the size of the traditional SDC-type damage but two members did not want classification of
such damage as Category 2 due to the added recurring costs of periodic inspections and added structural
substantiation to find such damage per selected inspection methods and a specified interval without a
defined threat associated with that damage. In effect, two members did not want added costs of related
damage tolerance risk mitigation for arbitrary damage scenarios. Most members believed it was good
practice to closely inspect the structure with substantiated maintenance procedures for evidence of large
8
Page 9 of 123
disbonds as a practical safeguard even though the intent of stringent bond material and process controls is
to ensure such events are extremely rare.
Most of the AC 25.571-1D recommended updates brought bonding into damage descriptions, including
the potential that early stages of weak bond formation would potentially have a significant effect on
damage tolerance analyses. AC 21-26A also requires updates. This AC contains very generic guidance
on Bonding (materials, process parameters and quality control plan), identified in §10.c.(3) Secondary
Bonding of AC 21-26A, without any recommendation on design principle or any recommendation on the
complex interactions between both materials and design principles. The TAMCSWG recommends
creating a cross reference to AC 20-107 B and not update AC 21-26A to avoid any not consistent
information.
2.0 Bonded Structure Task Extension

2.1 Extended Tasking Description and Work Plan Summary
The FAA requested further clarification from the working group on how to address disbond and weak
bonds as manufacturing defects. This appeared to be a simplification of the task to be performed and
subsequent discussion with the FAA made it clear that industry should address both metal and composite
bonding (for both serial production of the base structure and factory or field repair), including
relationships with material and process control, as noted by the current Paragraph 6 of AC 20-107B.
In addition, the FAA requested TAMCSWG to provide additional advice and recommendations on any
secondary considerations for bonded structure, including options given in the current AC 20-107B based
on 10 years of experience since the publication date in September, 2009. In particular, the FAA requested
the TAMCSWG to agree on Structural Damage Capability (SDC) or the existing words already appearing
in AC 20-107B (implying fail safety) as a supplement to stringent material and processing control of
bonded structure. The FAA further noted that a specific SDC for bonded structure is evident in many
transport applications to date; however, other product types have used very large damage sizes as opposed
to specific arresting features. Some further FAA clarification for details on the specific tasking also
appear below, which summarizes the technical basis for existing content in AC 20-107B.
• Bonding has a number of manufacturing defects that need consideration in a threat assessment
for structural fatigue and damage tolerance substantiation. Of these, the two main types
include: 1) small disbonds & other bond discrepancies (e.g., porosity) and 2) understrength or
weak bonds not reliably detected by factory post-bond inspections. Existing composite
guidance controls the former manufacturing defects in a manner similar to small or rogue
flaws for metallic fatigue and damage tolerance. In the vast majority of cases, small composite
defects can be classified as Category 1 damage and proven to be allowable based on a no-
growth demonstration for a lifetime of fatigue, while retaining strength at ultimate loads (with
small disbonds at the limits of factory NDI detection likely critical versus acceptable porosity).
In the past, industry has generally complied with composite defect and damage guidance
recommendations by demonstrating No-Growth, Slow Growth or Arrested Growth options in
analyses supported by tests as described in the existing AC 20-107B.
9
Page 10 of 123
• Understrength bonds are manufacturing defects that result from under specified or controlled
manufacturing processes (chemistry). The resulting bond may have mechanical properties that
are below the specification minimum values and/or require further consideration once
discovered. These defects may occur within the range of manufacturing quality at the time
they are discovered and should be further addressed in the static strength and damage tolerance
evaluations as described in the existing AC 20-107B. Note that the terminology understrength
bonds has been adopted to distinguish bond phenomena that may still allow the use of damage
tolerance principles in reliably controlling damage growth until found and repaired, whereas
weak bonds have not.
• “Weak bonds” are also a manufacturing defect that is outside of the range of expected
production quality (i.e. a quality escape). These can be confusing when compared to other
manufacturing defects considered for purposes of fatigue and damage tolerance substantiation.
Although it is clearly a manufacturing defect, if sufficiently large, it is unlike any other
manufacturing defect that are typically used by industry (i.e., all others are relatively small and
either starter flaws for metal fatigue or allowable defects for composites).
• When weak bonds are large and of an unknown size and distribution, they become a serious
safety threat. They are typically caused by contamination of the bonding surfaces, ultimately
leading to lost adhesion. They have implications for static (ultimate) strength and must be
addressed quickly with a terminating action. The evaluation and disposition must consider the
specifics of the bonding and the residual strength of the structure. Without SDC/fail-safety,
such problems would often require grounding the affected airplanes until the terminating
action can be applied. It is well recognized throughout the industry that this issue cannot be
managed using structural analysis and tests or reliably detected by practical maintenance
procedures, including NDI. Weak bonds may also degrade due to environment and real-time
aging or repeated load in a way that will not allow reliable prediction of when a maintenance
action is needed to address the safety concern. As a result, the use of stringent material and
process quality controls is the primary constraint to allow bonding in a PSE and further
mitigate safety risks associated with weak bonds through use of a secondary constraint of
structural redundancy. As posed in current guidance (AC 20-107B), recommended industry
bonding protocol notes that: “stringent/reliable manufacturing in-process quality control
practices are in place to ensure that any weak bonds are: 1) extremely rare (justifying a specific
size constraint) and 2) localized to a size at or within arresting design features.”
Under the TAMCSWG, a Structural Bonding task group (TG) was formed, which included subject matter
experts in bonding from OEM, airlines and the FAA. The TG established a work plan that is summarized
below (details appear in Section 2.4):
 Review Existing References, Including Existing Guidance and Industry Standards

 Identify Guidance versus Standards Recommendations
 Address Consistent Design and Maintenance Practices for Bonding
Early in the study, the TAMCSWG Structural Bond TG realized that no specific existing rule changes
would be needed for structural bonding but the rationale for this decision still needed to be documented.
The detailed work plan described in Section 2.4 yielded several deliverables as listed below:
10
Page 11 of 123
Deliverables: Produce report containing the following recommendations
 Recommendations on appropriate performance-based requirements

 Recommendations on any new guidance or changes to existing guidance
 Recommendations for continued work on standard best industry bond maintenance practices
 Qualitative and quantitative costs and benefits of the recommendations
2.2 Introduction
Several FAA documents exist on “Structural Bonding,” with a strong focus over the last 15 years on
composite technologies from initial product design to maintenance and repairs activities. These topic
areas have been the basis of a few guidance documents issued by the FAA, covering metal and composite
bonded structure. In 2005, the FAA released a policy statement called Bonded Joints and Structures -
Technical Issues and Certification (Ref. 4). In 2009, bonding was also covered in AC 20-107B,
Composite Aircraft Structure (Ref. 5). In 2014, a policy on bonded repair size limits was released to
ensure the thoughts already contained in AC 20-107B were consistently understood for the production of
aircraft products and field repair (Ref. 6).
Additional tasking for structural bonding as related to fatigue and damage tolerance has as much to do
with a need for industry guidelines as it does for regulatory guidance updates. There is a general lack of
sufficient knowledge transfer on the subject of structural bonding. In general, safe bonded structure for
PSE starts with stringent material and process controls. Adhesion science for metal and composite
aircraft structure has a strong theoretical basis but the specific relationships between available substrate
and adhesive material types, bond preparation, and further control of other processing steps lack
understanding at the overall system level. Changes in any of the materials or processes can lead to less
reliable bonding practices and changes in long-term strength and durability. As a result, bond process
qualification often requires numerous process trials with the specific materials and process steps to
identify a successful process window and the numerous in-process controls needed to ensure success.
Post-process NDI is required for manufacturing defects, including those that are properly controlled
through fatigue, damage tolerance and related practical maintenance procedures. Unfortunately, the
manufacturing defects that relate to weak or understrength bonds in metallic and composite bonded joints,
respectively, and the onset and/or growth of weak bonds cannot reliably be detected using practical NDI
currently suitable for factory or field use. As a result, the primary safety risk mitigation currently
available for bonded structure comes through stringent in-process controls to ensure a very small risk of
weak or understrength bonds that are of a size within the bounds of redundant design features (e.g.,
mechanically fastened, co-cured or an additional, separately bonded detail) or use of an increased SDC in
design.
In recent years, Composite Material Handbook 17 (CMH-17) emphasized the need for structural bond
content in base design, material and process control, structural substantiation, manufacturing & repair
implementation and any other areas where guidelines were needed to help the industry control bonding
for acceptable application needs. Bonded structure content will exist in Polymer Matrix Composite
(PMC) Volumes 1 through 3, Rev. H and Sandwich Volume 6, Rev. A. These details are long overdue
considering the number of aerospace applications to date but conservative industry practice and
11
Page 12 of 123
application limits have sustained acceptable levels of safety throughout the commercial transport industry
without these advancements being made public.
In addition to published documents, two Industry/FAA Workshops were held in 2004 (Seattle, WA and
Gatwick, England) with the objective to document the technical details that need to be addressed for
bonded structures, including critical safety issues and certification considerations. Some conclusions
appear in the FAA report (Ref. 1).
A survey contained in the report covered three main technical areas:
1. Materials and processes

2. Manufacturing and design integration
3. Product development, substantiation, and support
2.3 Summary of the Bonding Task from 2018 Final Report

In the original tasking for the TAMCSWG, bonding only appeared as a bolted or bonded repair task. The
findings from that effort recommended no rule change to §25.571. In effect, any repairs, bolted or
bonded, must meet the same certification standard as the original or modification structure (Ref. 7).
Additional guidance recommendations added to AC 25.571-1D address bonded repairs. Although AC 20-
107B and AC 43-214 address composite structure compliance matters, including fatigue and damage
tolerance, bonding is a process not solely unique to composite structure, and presents a challenge for
continued airworthiness. Additional guidance to the FAA Policy Statement on Bonded Repair Size Limit
(BRSL), PS-AIR-20-130-01, and harmonized European Union Aviation Safety Agency (EASA)
Certification Memo CM-S-005 (Ref. 6) was also recommended. This guidance would clarify that repairs
accomplished and substantiated by the OEM in a production facility are acceptable in-service if achieving
the same stringent quality controls. Since field repair substantiation is difficult, the guidance should also
recommend support by the TCH and regulator to develop affordable, approved data for repair design,
meeting all the original certification requirements.
Additionally, the T recommended the FAA clarify wording in FAA policy letter PS-AIR-20-130-01 and
AC 20-107B to be consistent and avoiding any confusion. Finally, recommendations for cross-references
between the various guidance and policy should help ensure consistent field and factory practice,
assuming the same level of bond quality control.
2.4 Detailed Work Plan

OEM/Maintenance Repair Organization (MRO) Sub-team to draft a bonded structure report: Chantal
Fualdes, Allen Fawcett, Doug Jury, Eric Chesmar
NAA draft report support: Larry Ilcewicz (FAA), Simon Waite (EASA)
Review Existing References. Identify gaps in documentation for current industry best practices and
regulatory guidance materials for bonded structure, noting differences between metal and composite
12
Page 13 of 123
bonded structures. This should include the technical subjects of structural bond design, material and
process control, structural substantiation, production and repair. Some existing industry documents to
review include industry reports, published technical references and other industry guidelines (e.g., CMH-
17). Most important regulatory documents to review are mentioned above. The following areas need
consideration:
● Published reports of service difficulties, incidents or accidents involving bonding

● Published industry reports covering the key technical subjects and any unpublished unique
approaches used by different OEM representing the TAMCSWG or others approached by the
ARAC working group
● Focus on AC 20-107B structural bonding content, which was commented in the initial ARAC
activity ending in 2018, with additional points to cover material environmental degradation
● Any other guidance materials covering bonded technologies, including sandwich structure
● Any likely technology advancements that could make the guidance obsolete
Identify Guidance versus Standards Recommendations: One particular point of reference requiring
attention is how to adopt the previous §23.573 rule language as acceptable best industry practice, as
needed for future guidance. This is an important issue because the TAMCSWG did not anticipate such
prescriptive rule language for the future. Since the content of §23.573 is generally accepted by industry, it
was achieved by adding the same words to an industry standard guideline in CMH-17, with some
reinforcing general loads kept in regulatory guidance. In practice, many bonded joints and attachments
use fail-safe design practices as related to this previous small airplane regulation for composite damage
tolerance. Alternate load paths achieved using fasteners or additional splices attached in a second bonding
operation are common. Due to the mechanisms of bonded and bolted joints, design of the joint or
attachment capability assumes only the bond or bolts are transferring loads.
Some existing guidance materials that address an important aspect of bonded structure, including
stringent quality control need update. For example, past industry/regulatory discussions on AC 21-26A
have realized it is limited in scope and somewhat outdated. Some comments/recommendation are needed
in moving forward per current FAA plans to establish performance-based guidance as appears in such
areas of AC 20-107B.
As related to design and structural substantiation, limited rules and guidance on the subject of bonded
structure exist. As a result, the sub-team effort will review content in ACE100-2005-10038 (Ref. 4) to
highlight areas or emphasis for guidance update or publication in industry standards.
A close review of the current industry-initiatives active with CMH-17 and CACRC with a goal to provide
best detailed industry practices for bond material and process control, design, analysis, structural
substantiation and maintenance (repair in-process controls) is another important step in the work plan.
One area needing the most significant work will come from review of documentation on maintenance
practices. Currently, much of the maintenance industry is fully dependent on OEM assistance because
related supporting technologies for inspection, repair design, structural substantiation, processing, and
related knowledge transfer are proprietary and not universally shared.
Address Consistent Design and Maintenance Practices for Bonding: As discussed previously, bond
material and process control is paramount to safe applications. Some of the biggest challenges occurring
with bonded structure come in how to achieve control in the field versus the factory. In principle, both
can coexist and achieve the same goals; however, significant knowledge transfer provides a strong basis
13
Page 14 of 123
for that accomplishment. The fact that different airplane products may use differing approaches for
controlling the required quality of a bonded structure or repair to a structure, knowledge transfer is even
more important to success.
The work plan will include some future recommendations on how the challenges in knowledge transfer
between OEM, operators and maintenance organizations will benefit from regulatory guidance and
industry standards efforts. The primary focus of guidance will be on PSE parts requiring some constraints
in repair size limits. The guidance will also be limited to those areas of knowledge transfer that relate to
critical design details and essential material and process controls for production and service repair.
Industry standards will focus on essential technical details for bonded repair substantiation and repair
technician training.
3.0 Rules recommendations

3.1 Rule changes
The TAMCSWG reviewed the existing rules that support the development of materials, the effects of their
environments and associated mature quality control plans. This review considered both technologies,
metallic and composite, and their bonding characteristics. ARAC members considered the critical steps in
the design and validation of bonding processes from both OEM and Maintenance & Repair Organizations
(MRO). The TAMCSWG understood that bonding is an assembly of technologies with a sensitivity to
fabrication methods and associated potential manufacturing defects. Other potential threat sources to
address include accidental damages, aging and repeated loads.
The following are relevant excerpts from current published CFR the TAMCSWG considered to address
the discussed structural bonding concerns.
CFR §25.601 – General
The airplane may not have design features or details that experience has shown to be hazardous or
unreliable. The suitability of each questionable design detail and part must be established by tests.
CFR §25.603 – Materials
The suitability and durability of materials used for parts, the failure of which could adversely affect
safety, must--
(a) Be established on the basis of experience or tests;
(b) Conform to approved specifications (such as industry or military specifications, or Technical Standard
Orders) that ensure their having the strength and other properties assumed in the design data; and
(c) Take into account the effects of environmental conditions, such as temperature and humidity, expected
in service.
CFR §25.605 - Fabrication methods
(a) The methods of fabrication used must produce a consistently sound structure. If a fabrication process
(such as gluing, spot welding, or heat treating) requires close control to reach this objective, the process
14
Page 15 of 123
must be performed under an approved process specification.

(b) Each new aircraft fabrication method must be substantiated by a test program.
CFR §25.609 - Protection of Structures
Each part of the structure must -

(a) Be suitably protected against deterioration or loss of strength in service due to any cause, including -
(1) Weathering;
(2) Corrosion; and
(3) Abrasion; and
(b) Have provisions for ventilation and drainage where necessary for protection.
CFR §25.613 - Material strength properties and material design values
(b) Material design values must be chosen to minimize the probability of structural failures due to
material variability…..
(c) The effects of environmental conditions, such as temperature and moisture, on material design values
used in an essential component or structure must be considered where these effects are significant within
the airplane operating envelope.
These paragraphs are explicit and address varying materials, their associated manufacturing processes,
operating environments and design validation. They address the link between materials, fabrication
methods and other design details addressed in structural sizing.
CFR §25.571 is of a major importance in the evaluation of any bonding processes durability.
Damage-tolerance and fatigue evaluation of structure.
(a) General. An evaluation of the strength, detail design, and fabrication must show that catastrophic
failure due to fatigue, corrosion, manufacturing defects, or accidental damage, will be avoided throughout
the operational life of the airplane…….
(b) Damage-tolerance evaluation. The evaluation must include a determination of the probable locations
and modes of damage due to fatigue, corrosion, or accidental damage. Repeated load and static analyses
supported by test evidence and (if available) service experience must also be incorporated in the
evaluation…….
Qualification and structural substantiation should provide sufficient data to demonstrate reliable bonding
processes and materials, including the issues associated with manufacturing scaling. Fatigue, Damage
Tolerance and Fail-Safe practices remain valid for structure constructed using a well-qualified bonding
process that is under control. They will help cover the rare, local disbonding that may occur even for
reliable bonding processes. The industry-recommended guidance updates in Section 4.2 for fail-safety (or
more generally SDC) and damage tolerance cover damage threat, design, damage tolerance and inspection
expectations within the realm of current industry best practices without a need for rule changes.
15
Page 16 of 123
In conclusion: Existing paragraphs, CFR §25.601/25.603/ 605 /613 and CFR §25.571 are sufficient and
correctly address the regulations needed for both composite and metallic reliable bonding manufacturing
processes and the structural ability to sustain required loads under their operating environments.
4.0 Guidance recommendations

4.1 Historic Perspectives on Existing Guidance
The most complete regulatory guidance that currently exists for bonded structure is a policy statement
called Bonded Joints and Structures - Technical Issues and Certification, which was issued in 2005 (Ref.
4). Although released as a small airplanes policy, it was derived from an interface with the industry for
many aircraft product types, including transport airplanes, small and transport rotorcraft, engines and
propellers. It addresses three types of bonding:
a) composite to composite,
b) metal to metal, and
c) composite to metal.
Appendix 1 details the historical background gathered through benchmarks of Industries practices. Main
processes steps are developed with associated experiences and recommendations, on:
- Materials and process controls qualifications procedures

- Highlights between metal and composite bonding process controls
- Challenges in substitution (substrate materials, adhesives, bond process, etc.)
- Challenges in Manufacturing: manufacturing defects and inspections challenges
- Design and Structural substantiation
4.2 Experiences of OEM and Best Practices Guidance

Improvements
4.2.1 AC 25.571-1D
This advisory circular provides guidance pertaining to the requirements for damage tolerance and fatigue
evaluation of transport category aircraft structure, including the evaluation of widespread fatigue damage
(WFD) and establishing a limit of validity of the engineering data that supports the structural-maintenance
program (hereafter referred to as LOV). The requirements of § 25.571 apply equally to metallic and
composite structure, although the focus of this AC is metallic structure. Refer to AC 20-107B for
guidance on composite structure and for material and process control guidance relative to both composite
and metal bond. All recommended changes proposed for AC 25.571-1D from the 2018 Main TAMCSWG
Report (Ref. 7) remain valid. Below are generic descriptions of many additional word or phrase updates
proposed for metal bond for AC 25.571-1D with added linkages to AC 20-107B where appropriate. See
Appendix 4 for the specific word or phrase additions used in edits recommended for AC 25.571-1D.
16
Page 17 of 123
Proposed change (1): First proposed change is a change of “corrosion damage” to “environmental
damage” and “crack” to “damage” where appropriate. Note that there are still locations in this AC where
“corrosion” and “crack” are appropriate for the given wording.
Reason for change: To be consistent with rule updates.
Proposed change (2): See Appendix 4 for the exact wording. Proposed change for the primary purpose of
adding metal bond in a given paragraph.
Reason for change: Multiple purposes recognizing metal (or metal to composite) bonded structure may
require consideration.
Proposed change (3): Proposed change is to 5(a)(1) under Introduction. It states that further guidance
exists in AC 20-107B on metal bonding with a focus on material and process control.
Reason for change: Cross reference to other guidance of relevance.
Proposed change (4): Proposed change is to 5(a)(6) under Introduction. The sentence affected is;
“Replacement times, inspections, or other procedures to address fatigue cracking and disbonding in metal
bonded details must be established as necessary” This introduces disbonding in metal bonded structure
relative to the discussion on replacement times and inspection.
Reason for change: Unique behavior of metal bonded structure may require consideration.
Proposed change (5): Proposed change is to 5(c) under Introduction, Structure to be Evaluated. This adds
bonded joints to the list of structure to be evaluated.
Reason for change: Unique behavior of metal bonded structure may require consideration.
Proposed change (6): Proposed change is to 6(a)(4) under Damage Tolerance Evaluation, “design features
that should be considered in attaining a damage-tolerant structure include the following:”. Added (4)
“Using disbond arrestment for metal bond joints as described in paragraph 6c(3) of AC20-107B and
focusing on material and process reliability as stated in paragraphs 6c(2) and 6c(4) of AC20-107B.”
Reason for change: Consideration of design features that provide damage arrestment in metal bonded
joints, including recognition that stringent bond material and process controls are still paramount.
Proposed change (7): Proposed change is to 6(d)(7) under Damage Tolerance Evaluation, Extent of
Damage, “The following are examples of partial failures that should be considered in the evaluation:”.
Added (7) “A detectable disbond of a stiffener or tear strap between arrestment features.”
Reason for change: Consideration of disbonding representing partial failure in metal bonded structure.
Proposed change (8): Proposed change is to 6(h)(2) under Damage Tolerance Evaluation, Damage-
tolerance Analysis and Tests. Updated (2) to include other environmental effects, “The repeated loads
should be as defined in the loading, temperature, and humidity spectra while considering environmental
effects caused from hydraulic fluids, fuels, cleaners and other detrimental materials found in operations.”
17
Page 18 of 123
Reason for change: Other environmental considerations for bonded structure damage tolerance.
Proposed change (9): Proposed change is to 7b.(1) under Establishing a LOV, WFD. Adding multiple
stringer disbonds and/or weak bonds as possible items that could have an influence on WFD for metal
bonded structure, “Global damage may occur in a large structural element, such as a single rivet line of a
lap splice joining two large skin panels (multiple site damage). Such damage may be affected by multiple
stringer disbonds or weak bonds in a panel that is using bonded structure to resist crack growth.” The end
of 7.b.(1) was further updated with an added sentence to note: “The existence of metal bonded structure
that has other aging mechanisms, including hydration phenomena, which strongly depends on moisture
entrapment, will further complicate such degradation.” As a result, such phenomena would need to be
evaluated using other procedures because the tests and analyses considered for WFD may not be updated
to cover a repeatable or reliable simulation of accelerated hydration. Therefore; the onset of hydration
noted for any metal bonded structure of such significance would invalidate other LOV assessments and
require action.
Although disbonding could potentially be a WFD item it is not supported under the current rules as how
WFD is calculated. It is also not an item currently simulated in a full-scale fatigue test or similar testing
and would be difficult to address without better understanding of accelerated aging. Analysis for
mechanical growth under environmental conditions may help to determine possible issues with failure
modes but currently not reliable in understanding disbond growth. Consider tracking the fleet for any
evidence of corrosion near important metal bonded structure as a better secondary consideration for
ensuring this issue does not become a challenge for LOV of metal structure. As discussed in the 2018
report, Section 3.8.3, the baseline MSG-3 inspection program is the recommended means to track the fleet
for any evidence of corrosion near metal bonded structure.
Proposed change (10): See Appendix 4 for the exact wording. Add definition of “environmental damage”
in Appendix 2 of AC 25.571-1D.
Additionally, the premise of paramount importance is that we have a robust bond process where the
existence of multiple weak bonds or failing bonds is remote. This is discussed throughout this report and
is also the primary thesis controlling bonding within AC 20-107B. If properly achieved, it would require
a systemic process failure to achieve multiple stringer disbonds and affect WFD. This needs to be noted
within updates to AC 25.571-1D but that document has little existing supporting guidance to ensure that
stringent bond process control is achieved. As a result, the reference to AC 20-107B simply needs to be
reinforced throughout the document when bonded metal structure is any part of the critical structures
affecting load paths, damage growth and other damage accumulation, particularly the phenomena of
hydration, for metal structure having damage tolerance expectations and an LOV.
UK CAA WG NAA participant member also recommended that for consistency, AC 120-104:
Establishing and Implementing Limit of Validity to Prevent Widespread Fatigue Damage, the objective to
ensure protection for bond strength is maintained throughout the airplane LOV when such bond is relied
on for protection from WFD (through enhanced manufacturing/process control, design and inspection
programs) then such awareness should be highlighted in this AC as well. This recommendation was not
extensively debated but no WG member shared any objection to this suggestion.
18
Page 19 of 123
Reason for change: The influence of metal bond hydration is an obvious factor affecting aging, whether
or not it is coupled with WFD in metal structure. It is supported by wording change from corrosion
damage to environmental damage; however, there is no further guidance in AC 25.571-1D. Related
sentences were added to the end of the definition of WFD in Appendix 1 and Step 4 of fatigue
considerations in Appendix 3.
4.2.2 AC 20-107B
The procedures outlined in AC 20-107B provide guidance material for composite structures, particularly
those that are essential in maintaining the overall flight safety of the aircraft and are considered acceptable
to the FAA for showing compliance with certification requirements of civil composite aircraft. This
circular is published to aid in the evaluation of certification programs for composite applications and these
proposed changes reflect the status of composite technology. As noted at the start of this advisory circular,
periodic modifications will reflect the continued evolution of composite technology and the data collected
from service experience and expanding applications. All recommended changes proposed for AC 20-
107B from the 2018 Main TAMCSWG Report (Ref. 7) remain valid.
The additional changes proposed for AC 20-107B below focus on a need for SDC (Structural Damage
Capability1) or fail safety and calls for periodic inspection to reliably find disbonds between arrestment
features substantiated as a category 2 damage threat. The former clarification is needed in Paragraph 6, as
relating both SDC and fail safety applied as design attributes, while the latter clarification is needed in
Paragraph 8 for inspection reliability and damage tolerance. In addition, the primary emphasis of
stringent material and process controls, while treating bonding as an integrated system is further
reinforced. Finally, there was a need to clarify the historical 23.573 requirement in AC 20-107B as
suitable for all product types, with an emphasis on the quality system. In response to changes in Part 23
regulation to performance-based rules, industry has adopted the past expectation in best bonded structure
design practices documented as CMH-17 guidelines (Ref. 2). This should be recognized in updates to AC
20-107B, while considering some exceptions for parts on other product types (e.g., rotor blades).
Proposed change (1): Proposed change is to 8(a)(1)(c)(ii) Category 2. See Appendix 3 for the exact
wording. Add SDC or a failsafe condition for a disbond between arrestment features as a Category 2
damage threat to require inspections to find the damage, making it similar to the inspection done for
visible impact damage. The change also recommends similarities in the inspection type used.
Reason for change:
The guidance material is clear in regard to the necessity of a residual strength check with a failed
bondline between arresting features. By adding this material to the Category 2 definition it is asking for
this damage state to be treated like other category 2 damage. This necessitates an inspection to look for
the damage state to ensure detection of the disbond and the airplane does not remain under regulatory
load requirements for its remaining life. See AC20-107B figure in Appendix 3. It is not a desired state to
remain below ultimate load for an extended period. Also added to this paragraph is a recommendation
stating that General Visual Inspection (GVI) is considered inadequate to visually detect bondline failures
between arrestment. Instead, a detailed visual inspection (DVI) will find bondline cracks at a bonded
flange edge. Industry will need to determine what is the most efficient, including a need for instrumented
1
Structural Damage Capability, SDC, is the attribute of the structure (that) which permits it to retain its required residual
strength in the presence of large damage. This definition is from 2003 Generalized Structures Harmonization Working Group.
19
Page 20 of 123
NDI for some structural design details and other factors affecting detection. In addition, there are likely
some cases where DVI and instrumented NDI would be ineffective for metal-bonded structures. See
section 4.2.4.1 for discussions of the design criteria that could be tied to a large disbond damage threat, a
specified inspection method and appropriate repeat inspection interval that requires structural
substantiation data but provides additional damage tolerance in the event local processing mistakes that
yield such damage. As with many design criteria the details can be based on specific structural
capabilities and needs in specified locations.
Proposed change (2): Proposed change is to 6(c) Structural Bonding: See Appendix 3 for the exact
wording. Add language to ensure the reliability of structural bonds both during manufacture and in-
service. The design and execution of any structural bonded joint uses tests and analyses to demonstrate a
strong and durable bond along with consideration of the full processing windows allowed by the
governing specifications. The definition of a “Bonded System” is a joint consisting of the adherend
material, surface preparation method, adhesive, and bonding process conditions used. Each component of
the Bonded System needs thoughtful selection and rigorous evaluation for any variables that could affect
bondline quality. Evaluate any proposed changes in a Qualified Bonded System made during
manufacturing or the life of the production system by multiple methods that interrogate adhesion,
consistent bondline performance, and durability across the spectrum of variables.[15].
Reason for change:
Add treating bonding as a system and any change in the system must be investigated (prep, adhesive,
adherents, bond process) and tested within the process envelope. This lesson learned, derived by the
OEMs from program experiences has been communicated in CMH-17, CACRC and other forums. It will
be a part of CMH-17 Volume 3 Chapter 10 revision H release as well.
Also, as an added recommendation, use of bonding in single load path structure, where failure of the
bond would result in the airframe’s inability to maintain regulatory load levels (limit loads), is consistent
with the other recommended AC 20-107B changes and updates in this section.
Proposed change (3): See Appendix 3 for the exact wording. Proposed changes to 6(c)(3), 6(c)(3)(a) and
6(c)(3)(b) all under Structural Bonding. The purpose of this change was to remove 23.573 reference,
which no longer exists, but to keep its intent. In addition, this same wording needs to be appropriate for
factory and field repair. Initially BRSL policy (PS-AIR-100-14-130-001) did not include factory repair
but was intended for operator in-service repairs only.
A stronger emphasis is needed linking the SDC or failsafe criterion of a single disbond between
arrestment back to quality. This is to emphasize that the design must have a highly reliable bonding
system to allow this damage tolerant failsafe check to consist of only a single disbond. Updates should
address the fault of relying on proof loading for the detection of weak bonds.
Reason for change:
o Needed an update for the old §23.573 reference.

o Changed the first sentence in paragraph 6(C)(3)(a) “For any factory or in-service bonded
joint including repair” to emphasize that bonded repair, in-service or factory installed,
should satisfy limit load residual strength with a failure; the same as a factory production
bond. This relates to an update to the BRSL policy to affect the same change.
20
Page 21 of 123
o Add a link to paragraph 6 to emphasize quality and state that assumption of single disbond
between arrestment features still relies on strict adherence to stringent process control
requirements.
o Clarified the drawbacks to proof loading and its inability to detect weak bonds.
Proposed change (4): See Appendix 3 for the exact wording recommendations. Propose change is to 10(c)
Substantiation of Repair. The purpose was to add BRSL policy guidance to the section covering bonded
repair.
Reason for change:
10(c) was updated to emphasize that when stating “Bonded repair is subjected to the same structural
bonding considerations as the base design” that also meant that they must meet limit load with a failed
bond between arrestment, as stated in bonded repair size limits (BRSL) policy.
4.2.3 AC 21-26A Quality System for the Manufacture of

Composite Structure
AC 21-26A includes very generic guidance on ‘bonding’ materials, processes parameters and quality
control plan, with no particular emphasis to structural bonding as reported in the extract from the existing
AC below.
Extract from AC21-26A (07/23/2010) shown below refers to “Bonding” as part of a quality control plan
in Paragraph 10.a:
a. General. The following are manufacturing process controls that should be included in a manufacturer's
quality system:
(1) The PAH (Production Approval Holder) should develop integrated quality and production control
procedures for operations that define product configuration, selection of materials, tooling and facility
equipment, Calibration, sequence of manufacturing operations, critical in-process parameters and
processing tolerances, and conformity to quality standards.
(2) Environmental parameters (temperature, humidity, chemical contamination) should be defined and
controlled, as required, where composite parts and structures will be produced, in particular, cutting, layup,
and bonding areas.
Paragraph 10.c (note, only relevant excerpts are included here; unrelated excerpts are omitted):
c. Assembly of components. The following are manufacturing controls unique to the assembly of
manufactured composite parts and structures that a manufacturer's quality system should include:
(1) Sandwich construction.
(b) Cured laminates should be inspected for dimensional conformity. Faying surfaces should be
properly cleaned and protected from contamination before subsequent assembly and bonding
operations.
21
Page 22 of 123
(3) Secondary Bonding.
(a) Cleaning procedures for surfaces to be bonded together should specify the chemicals and abrasives
to be used on faying surfaces. Standards for determining properly cleaned surfaces and methods for
protecting clean surfaces from contamination (including peel plies) should be available at the place of
manufacture.
(b) Manufacturing standards should establish adhesive bondline thickness and pressure to be applied
along the bondline during the cure cycle.
(c) Tool proofing procedures should demonstrate the capability of the tooling to maintain correct
bondline thickness, equal pressure distribution along the bondline and properly cured adhesive.
(d) Before the application of adhesives, the production parts should be preassembled and inspected in
the tooling to determine that the expected bondline thickness and pressure distribution on the bondline
will be within design limits. Shims required to fill bonding gaps should only be used in accordance
with an approved quality system procedure.
To avoid conflicting information in two separate guidance documents addressing the same topic the
proposal is to delete the paragraphs on bonding in AC 21-26A.
Reason for change:
All points mentioned in AC 21-26A are covered with more detail (processes parameters) and dedicated
design guidance in the AC 20-107B in:
(1) Paragraph 6 & 6a: Material and Fabrication Development, Material and Process Control points out
very generic guidance on need of a reliable process, within Paragraph 5, need to identified key
characteristics and process parameters for monitoring. And,
(2) Paragraph 6c: Structural Bonding, also applies to metal bonds, as it is stated bonded structures
include multiple interfaces (e.g., composite-to composite, composite-to-metal, or metal-to-metal).
AC 20-107B is much more complete and detailed than what is presented in AC 21-26A today.
Therefore, the TAMCSWG recommendation is to update AC 21-26A to include a cross reference to AC

20-107B specifying, for any bonding technologies including design and quality control, the AC 20-107B
is the relevant document.
22
Page 23 of 123
4.2.4 Bonded Structural Considerations

4.2.4.1 Structural Redundancy – SLP and SDC
SLP discussion
The guidance for composite materials given in AC 20-107B recommends that the use of SLP design or a
design that behaves like a SLP metallic structure be avoided. Although the AC sufficiently addresses
these concepts for composite structures, Bonding requires clarification with the additional wording
proposed in appendix 3. The proposed wording in appendix 3 states; “Even with this in place (rigorous
material process control), bonding in single load path structure may not practically be used without further
considerations as safety cannot be ensured through maintenance practices alone.” Outside of bonding, no
clarification is needed to the AC to adequately address structural redundancy and beyond by following the
5 Categories of Damage achieving the safety objective for these materials and construction.
This guidance developed by the structural bonding sub-team does not cover SLP bond-lines by
recommending fail-safe features to maintain residual strength to limit loads.
Single load-path designs are only acceptable where deemed necessary due to the constraints of the design,
but because disbonds are more difficult to detect than damage considered obviously detectable, additional
evaluations and procedures are necessary in defining a bonded SLP inspection program. By adding
guidance for disbond arrestment to category 2 structure as recommended in the edit of AC 20-107B in
appendix 3, inspection required to ensure limit load structural capability with a failed bondline is
maintained for the airframe service objectives. For SLP structure compared to designs with SDC, this
typically dictates an instrumented NDI to look for disbonds before they could become critical. This
damage state will likely be non-visible and much more difficult to find than looking for a large disbond
between arresting features in Multiple Load Path (MLP) structure. Still the recommendation currently
stands for bonded SLP structures as the inspection intervals used to capture disbond growth require
structural methods and testing that are not well established within an existing design environment. Also
noted here, is an added maintenance recommendation in applying an instrumented NDI burden for bonded
SLP. Furthermore, NDI detection of weak bonds is not normal practice and, as a result, bonded SLP for
metal bonded structures is strongly discouraged.
As discussed in the final TAMCSWG report, the historical record supports the continued emphasis on
MLP construction for most of the airframe structure. However, a review of the accident records and
OEM experience does not indicate an issue with SLP construction if applying the principles of damage
tolerance. Although for SLP bonded structure, this OEM experience has very limited application and
service history as compared to metallic construction and needs further consideration. It is worthy of note
that bonded rotor blades (both metal and composite), which have traditionally been SLP, have had several
catastrophic bond failures leading to loss of life (Ref. 3).
• SLP composite structures are acceptable if supported by a proper damage tolerance based
inspection program. However, an understanding of reliable analysis methods, testing and a
suitable inspection program to establish inspection intervals for composite bonded SLP joints have
little past experience for critical transport structure and likely depend on initial flaw size
assumptions. In addition, accidental and environmental damage tend to rely on conservative
design criteria that, by definition, would likely not include visually obvious damage for a SLP.
23
Page 24 of 123
• For composite material construction in general, the concepts of MLP and SLP do not have the
same level of definition as for metallic construction for reasons described in the previous bullet.
Also, the benefits of fastened vs. bonded structures are not fully established. The safety objectives
are outlined in AC 20-107B and require no rule change to support them. However, for SLP
bonded structure the TAMCSWG recommends further guidance in AC 20-107B.
As noted for other SLP, SLP bonded designs should have much higher reliability compared to redundant
bonded designs or those with SDC. Although this is a good basic statement, high reliability of bond
materials and processes is already required regardless of structural redundancy. However, bondline in-
process controls and service inspections for SLP repair designs should be the most rigorous possible to
ensure safety is maintained, bringing significant economic impacts into such decisions.
• If MLP structure is impractical, the applicant should perform these additional steps to support the
SLP design
o Minimization of environmental and accidental damage (i.e. consider protection, different

materials)
o Perform a fatigue test (including consideration for any real-time environment and aging
effects) or complete fatigue analysis based on test to demonstrate an acceptable level of
durability and environmental reliability. This would be a challenge considering current
knowledge relating to accelerated tests in this area but future developments may be possible.
o Develop a manufacturing process control and tracking plan document, including a thorough
assessment of processing windows and all possible interactions between various parts of the
Bond System. In the end, The document should include details of the bond surface
preparation and subsequent handling controls leading up to the bond assembly and cure, and
how they are to be controlled in time, exposure to environment and contamination since these
are essential parts of these documents for a given bond system.
o A fleet leader strategy would benefit such practice (similar to what is done with rotor blades),
including regular NDI inspections and more extensive destructive testing when possible.
However, it should be noted that airlines and other transport airplane owners are not required
to participate in such efforts and/or share the results with OEM. Regardless, any reports of
bondline degradation in primary structure is a reportable condition under 21.3(c)(8).
Note, NAA participants with this WG have strongly endorsed the value of applicants
employing a fleet leader strategy to assess service-aged bond integrity, which may include
enhanced inspections beyond normal maintenance (NDI) and, or destructive teardown on
appropriate, high-timed sacrificial samples.
o SLP bondlines are particularly critical with respect to quality escapes (i.e. weak bonds) and
use of a conservative approach to setting inspection intervals is recommended.
24
Page 25 of 123
Structural Damage Capability discussion
Structural Damage Capability (SDC) is the attribute of the structure which permits it to retain its required
residual strength in the presence of large damage. The overall purpose is to prevent catastrophic failure
resulting from damage not accounted for in damage tolerance analysis. SDC is a characteristic of the
design of a structure, and is therefore, not specifically tied to any one aspect of a maintenance program.
However, current TAMCSWG recommendations are to supplement the SDC and/or fail safe design
recommendations with data supporting reliable Category 2 damage tolerance classifications. This is still
relying on stringent bond process controls that would very rarely allow the large damage formation within
the extent of redundant design features or larger areas covered by design criteria. Transport experience
has indicated that bond processing challenges remain an issue that requires such safety measures.
The TAMCSWG Bond TG discussed defining SDC within AC 20-107B as general design attributes set as
company design criteria for purposes of maintaining consistent design practices and some additional level
of safety for a particular part, location or feature of the structure that would benefit from a specified level
of robustness. Details of a given SDC may be product, part and location specific, enveloping a range of
damage scenarios from damage threat assessment (a generalized “redundancy parameter”), facilitate
efficient maintenance practices and supplement the categories of damage as defined in AC 20-107B. This
definition of SDC, unlike Category 3 damage, does not require it be in a structural location whereby the
damage would be found in a short period of service time. It is still consistent with primary expectations
for bonded structure that process controls are sufficient to ensure such damage is extremely rare; hence an
allowance that it can be of that size for long periods of time. Although these discussions seemed relevant
since current composite Categories of Damage allow applicants to define their own related damage
tolerance design criteria for such purpose, the TAMCSWG decided not to redefine SDC as a generalized
term used for composite damage tolerance design criteria because that is significantly different than the
original definition derived for metallic structure at a time when composite damage tolerance was
considered separately and not included in AC 25.571 guidance.
Instead, the specific damage tolerance design criteria (DTDC) used for updated Categories of Damage
encompass the above discussions, while not causing confusion with the term SDC that has been
considered for metallic structures and accepted by industry only if there is no specific regulatory
requirement or recommendations given in metallic guidance. As a result, AC 20-107B could continue to
encourage industry define specific composite DTDC to cover structural bond design and process needs, as
is currently the case for guidance supporting categories of damage given in Paragraph 8 (see Ref. 2 for
composite industry guidelines in this area, including the current discussions that encourage large disbonds
subjected to Category 2 expectations to substantiate inspection intervals based on damage tolerance and
practical DTI field inspection methods). Note that the following examples for DTDC involve bonding but
similar approaches may be applied to other damaged composite structure to supplement damage tolerance.
 Specific DTDC applied for Category 2 damage or other Category 3, large damage scenarios in
areas not obviously detectable to an extent it would be reliably found while still protecting safety.
In this case, the DTDC would specify how damage is simulated in test and analysis, as well as
define the detection/inspection procedure used to reliably find the damage. When the damage
threat is larger the risk that it exists must be very rare, as currently noted for both the fail safe and
SDC condition. The difference comes in generating the necessary structures data to allow such
rare but large damage to exist for long periods based on the supporting damage tolerance data and
a long inspection interval. As implied by current AC 20-107B supporting logic, the closer such a
25
Page 26 of 123
damage threat gets to limit load capability, the potential for its existence must be extremely rare.
However, the long inspection interval must be substantiated as part of the damage tolerance data.
o Example 1: DTDC for a large disbond within the spacing of arrestment features for bonded
stiffening elements where visual detection schemes would find the damage using the same
existing DVI procedures applied for Category 2 impact damages detectable within a torque
box or fuselage shell structure. The detailed inspection would look for a disbond due to a
weak or understrength bond, as well as a severe impact event that does not include other
evidence of such an impact (e.g., fiber breakout over wide areas).
o Example 2: DTDC for the bondline within the critical load path of a SLP structure
whereby the design can sustain a conservatively small but detectable disbond with no
growth and Limit load strength over repeated load cycles protected by maintenance
inspection intervals.
o Example 3: DTDC for a hidden structural design bondline that does not require specified
“arrestment features” to sustain a large arrested disbond and limit load for an inspection
interval.
These examples also help the reader realize that DTDC would not only be reserved for a large damage in
acreage structure but also for other design criteria of a smaller damage that spans a significant part of a
cross-section. It should also retain attributes of being easily detectable bondline damage in SLP structure
that reliably demonstrates “no growth”. In effect, the DTDC used for a company-specific barely visible
impact damage (BVID), category 1 damage follows the same logic and requires a given companies
approach used in defining allowable damage for different parts of a composite structure and further
identified in maintenance manuals that zone allowable damage limits (ADL) throughout the structure.
Coming back to the existing definition of SDC, it still has relevance in comparison to bonded structure
fail safety, even when obvious redundant design features don’t exist (e.g., bonded structure capable of
large SDC, without fastened redundant design features). In this case it remains supplemental to damage
tolerance for bonded composite, metal and composite to metal structures and should be considered an
appropriate alternate design means of compliance because the primary safety risk mitigation is maintained
through stringent process controls that very rarely allows large areas of disbonding, which is still expected
to have the fail safe or SDC capability to safely cover those occurrences.
Gulfstream pointed out that the use of a category 2 DTDC may not be appropriate for metallic structures
because the primary threats to bondline integrity are due to hydration and associated corrosion. These
threats should be managed through the MSG-3 ED inspections as discussed in the 2018 report, Section
3.8.1. While the specific disbonding of the adhesive layer may not be detectable, evidence of corrosion in
the metallic structure adjacent to the bond will provide a visual indication of damage to be investigated
further.
For metal bond structure, several NAA members recommended that the corrosion prevention and control
program (CPCP) include a fleet leader component for tracking any corrosion noted in the vicinity of
bonded joints and if present, rendering the structure for further inspection that may or may not allow an
extension in the corresponding LOV.
However, as discussed in the 2018 report, Section 3.4.2, a Fleet Leader approach has not been applied or
recommended:
26
Page 27 of 123
It was discussed among manufacturers whether a fleet leader program is a current practice and it was concluded
that no systematic fleet leader approach is applied.
A specific fleet leader program is not recommended because:
 There are no provisions in Part 25 to implement a fleet leader program beyond mandating special
inspections for the ‘high time’ airplane in the ALS. This would be very burdensome for the
affected operator and would not be practical.
 The MSG-3 program is a ‘fleet leader’ program in that it is calendar based, is universally applied
to the fleet and has provisions for tracking, feedback of results and even fleet leader inspections.
These inspections should form the basis of the corrosion protection program and be referenced in
the ALS as discussed in the 2018 report, Section 3.8.3.
 Instead of the above recommendation, the guidance should state that the applicant should clearly
identify in the ICA (per CFR 25.1529) the follow-on NDT and other procedures necessary when
evidence of corrosion exceeding the limits is found in the vicinity of bonded joints, and that the
findings should be reported IAW 14 CFR 21.3 and implications on the LOV evaluated as a service
difficulty.
Damage tolerance is the ability of structure to sustain anticipated loads in the presence of damage until it
is detected through inspection or malfunction, and repaired. It should be emphasized that SDC is not a
replacement for damage tolerance – SDC adds robustness to the inherent structural design and typically
aids any damage tolerant inspection practices through ease of detection. As a result, SDC like fail safety
addresses unforeseen damage and complements existing damage tolerance inspection requirements. It
does not generate any additional inspection or inspection threshold requirements; these should already be
accounted for by existing baseline and damage tolerance based maintenance programs. However,
inherent SDC for a given design may prove to be a replacement for structural redundancy when specific
arrestment features are not required in achieving desired load levels when large, clearly obvious damage
is present (depending on load levels and design details, this is sometimes the case for sandwich
construction capable of meeting damage tolerance load requirements with larger damage than a redundant
structural design).
Again SDC is defined as an inherent design attribute and is not specified by regulation, instead it is
adopted by a company through their own design criteria for consistent design practices for many different
damage threat considerations. It complements the more formal inspection programs derived through
damage tolerance evaluation (DTE). At a high level, types of damage could include wear, environmental
deterioration, impact, heat damage, disbond and delamination. General sources of damage could be from
loading in service, the environment, accidental damage, maintenance errors, discrete events and
manufacturing defects. The evaluation of a given critical structure for SDC is intended to ensure that, in
the event of a certain level of damage, the remaining intact structure is capable of carrying the required
residual strength loads. In this aspect it can be thought to represent a generalized fail safe condition.
When assigning an additional DTDC to a hidden SDC-type damage, requiring proof of structure
involving repeated loads, residual strength and corresponding inspection methods/intervals, it is best to
refer to it as a DTDC and not use the acronym SDC, which usually only provides proof of residual
strength.
27
Page 28 of 123
4.2.4.2 Other Structural Considerations

The remaining focus of this discussion will be on bonding in MLP structure. For SLP structure see the
previous dedicated section focusing on that subject at the start of Section 4.2.4.1.
i. Bonding definition per AC 20-107B: 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.
ii. MLP definition for bonding: Multiple load path structure with damage arrest features, i.e.
bonded composite structures which incorporate ‘damage containment features’.
This is applicable to co-bonded and secondarily bonded critical structure and applies to composite-to-
composite, composite-to-metal and metal-to-metal bonds in multiple load path (MLP) structure. To
satisfy DTDC the structure should:
(1) Establish that non-obvious damage to a bond line due to manufacturing, environmental or
accidental causes, does not create or cannot propagate to a condition where less than limit
load capability for the critical structure remains; or,
(2) Prevent disbonded structural configurations possessing less than limit load residual
strength capability by tangible features of the design that will arrest disbond propagation.
(3) Achieve predominately cohesive or interlaminar failure modes demonstrating high

bondline quality. This is possible when using stringent process controls, incorporating
proven surface preparation methods that achieve a clean and active bond surface.
Any disbond which would result in structure having less than ultimate load capability for the design
service goal (DSG) of the aircraft, must:
(1) Be detectable by visual means which may be accomplished by using the baseline
maintenance program (ED/AD); or,
(2) A repeated instrumented inspection (NDI) shall be required as part of the baseline in-
service inspection plan. This is expected to have significant cost impact, particularly in the
case of metal bonded structure where a threat relating to weak bond hydration phenomena
may also be very difficult to substantiate.
4.2.4.3 Adhesion Failure

Adhesion failures, which indicate the lack of chemical bonding between substrate and adhesive materials,
are considered an unacceptable failure mode for both MLP and SLP structure in all test types and under
any design environment. Changes to qualified bonding systems (substrate, surface preparation, adhesive
or processing) should be assessed for risk and validated by test as appropriate. Other issues to consider:
(1) Damage arrestment features may be needed to reduce the risk of disbonded areas on
adjacent stiffeners overlapping in a structural cross section. For example, fastening
28
Page 29 of 123
stringers to the skin at each frame reduces the risk of a disbond in one frame bay
propagating into the next bay where an adjacent stringer may also have a disbond.
(2) If significant changes in structural stiffness, geometry, or both, follow from a structural
disbond or partial disbond, the effect on flutter must be assessed as a result of the structural
disbond.
(3) Cyclic load testing should demonstrate no detrimental damage growth unless an arrested
growth or slow growth approach is used. See AC 20-107B for further guidance on these
approaches.
(4) Limit load residual strength should be demonstrated after cyclic loads testing. Appropriate
environments should be accounted for.
4.2.5 Maintenance Repair and Inspection Considerations

This TAMCSWG identifies a potential gap between the technical knowledge between TCHs using
complex bonding systems in the product design and the non-TCH organizations which are engaged with
the on-going maintenance. Certain industry and regulatory coordinated activities have intended to help
mitigate this knowledge gap with the shared objective to ensure the safety objectives are seamlessly met
between TCHs and other properly delegated MROs.
The FAA and Industry have made a concerted effort for knowledge transfer (documentation and course
development) as related to composite bonded and bolted repair substantiation, as well as a need to report
any challenges and the subsequent root cause analyses of base bonded structure or repair failures found in
the field. Of particular concern are any challenges that involve adhesion failure of the structural bonds.
In recent years, the FAA and EASA have supported several free seminars given by Max Davis at the SAE
Commercial Aircraft Composite Repair Committee (CACRC) and CMH-17 Meetings on bond failure
forensics, with some emphasis on metal bonding.
The SAE CACRC made a concerted effort for knowledge transfer by establishing multiple training
curriculums for inspectors, technicians, engineers, managers and auditors. Table 1 below provides the
report numbers, document names and most recent publication dates.
AIR4938C Composite and Bonded Structure Technician/Specialist Training Document Sep 19, 2018
AIR5278 Composite and Bonded Structure Engineers: Training Document Oct 13, 2016
AIR5279 Composite and Bonded Structure Inspector: Training Document Oct 13, 2016
AIR5719A Teaching Points for a Class on “Critical Issues in Composite Maintenance, Repair and Overhaul” Sep 05, 2018
ARP6262A Basic Composite Repair Technician Certification Standard Sep 10, 2019
Table 1. CACRC Standards for composite training.
Further industry & regulatory partnerships exist in advancing the science of structural failure analyses
performed with failed structures subjected to post-crash fire conditions, where significant evidence may
be altered and require special considerations or advanced techniques to generate useful results. Known
causes of past adhesion failures (e.g., various forms of surface contamination, including evidence of
29
Page 30 of 123
certain chemicals, peel ply residue, amine blush, etc.) remains an emphasis within this work because they
suggest improper bond execution and/or an unqualified bond system. In many cases, these processing
challenges were minimized by design practices and good manufacturing records. However, there is still
evidence that the problems and related solutions have remained unpublished as a specific industry
problem and became recurring in the experiences of other applications. Regulatory efforts to share this
safety knowledge throughout the industry have been successful but work needs to continue researching
typical root causes and adopting in-process controls to eliminate the potential. Unfortunately, the field is
generally the last to receive knowledge needed to avoid bonding problems. As such, this TAMCSWG
recommends continuation of these types of industry & regulatory collaborative activities.
Content in the following section summarizes past composite guidance focused on bonded structures as
part of the continued work on standard best industry bonded structure maintenance practices. The content
best belongs in future industry standards, maintained by an international standards organization that
represents the industry interest in safe and efficient engineering and related maintenance practices.
Service Experiences, Including Benefits from Fleet Surveillance
Many of the technical issues discussed in Appendix 1 under the headings of Material and Process
Control, Manufacturing Challenges, and Design & Structural Substantiation are important to
maintenance implementation, including bonded repair and inspection. This subsection will emphasize the
unique aspects related to damage detection, subsequent inspection for a full characterization of the
damage and the proper execution of a substantiated bonded repair.
An assessment of the full extent of damage that requires a bonded repair is the starting point for current
discussions. In most cases, damage detected visually still requires NDI of the damaged area to
characterize the full extent of damage. Once characterized and found to be within repair size limits given
in the structural repair manual (SRM), it may be determined whether previously substantiated repair
procedures exist. If not, considerable pre-repair efforts need to establish a qualified bonded repair system
to specify with a repair design and gather the necessary structural substantiation data (usually bounded by
the tests and analyses performed). The same SRM-based qualified bonded repair system may be a
candidate for use outside the repair size limits given in an SRM but not without additional structural
substantiation, including consideration of regulatory guidance covered in the next subsection.
Service experience of bonded structures and repairs provide the final proof of a properly executed and
reliable bonding process. Discovery of bond adhesion failures in the base structure or a bonded repair in
service justify immediate directed inspections and repair actions. Thorough production or repair records
are important to tracing the probable cause of such a problem. Some experts believe that service
monitoring of bonded structures or repairs, including selected NDI, and teardown inspections for retired
aircraft, provides data to correlate accelerated test results from qualification and in-process control with
real time service exposure. The FAA has led research in this area with help from industry. Please see
some case studies assembled with the help of airlines and documented to initiate additional research,
guidance and training developments (Ref. 8). In addition to the CMH-17 Revision H efforts in Volume 3,
Chapter 14 to provide guidelines and industry best practices for bonded repair substantiation, the FAA is
developing a related short course on this subject that is scheduled to be available to industry by 2021.
Future plans to continue research, includes studies on aged repairs following years of service and the
repair of aged composite and metal substrate materials/structures to ensure that approved surface
30
Page 31 of 123
preparation and other bonded repair process steps remain effective. The TACMACSWG recommends the
FAA continue to sponsor these activities and to make timely publications sharing the results with industry
and National Aviation Authorities (NAAs) in supporting or guiding any future guidance or policy, as
appropriate.
Repair Size Limits
In late 2014, the FAA released policy (Ref. 6), which reviewed the regulatory basis and established
guidance in setting size limits for bonded repair to critical composite (monolithic and sandwich structures)
and metallic structure. Bonded repair of critical structure (as defined in AC 20-107B) must first be
constrained to the sizes allowed by substantiating design data. This policy informs Aircraft Certification
Office (ACO) engineers and designees that due to inspection limitations, bonded repair must be further
limited to a maximum size whereby the structure retains limit load residual strength with a complete or
partial failure of the bond within the repair or base structure arresting design features. EASA has a
corresponding Certification Memo CM-S-005.
The FAA and EASA documented bonded repair size limits, which are consistent with other composite
guidance (Ref. 5), provide additional details on the limits of structural repair substantiation. In some
cases, repair size limits defined by the substantiating data are smaller than that constrained by the
maximum size capable of limit load residual strength with a complete or partial failure of the bond within
the repair or base structure arresting design features. This will naturally occur if a given OEM does not
assume liability for larger repairs performed per approved documentation. In fact, it is common industry
practice to give some repair facilities larger limits than other shops based on past repair achievements
and/or added in-process quality controls.
The current policy for bonded repairs follows similar safety risk mitigation procedures adopted by
industry for structural bonding and rework with critical structures. General best practices for many
critical structures use failsafe design features whenever safety threats exist for manufacturing defects,
accidental damage, fatigue loading and environmental degradation. Bonding challenges exist in each of
these areas. The first issue associated with “rare bond processing mistakes” leads to common design
criteria that ensures the structure has sufficient bond strength to carry limit load if bonding is lost between
arresting design features. This has often been referred to as the use of “chicken fasteners” but that is
clearly not the case when realizing that many critical structural designs can’t carry limit load if disbonding
occurs in adjacent bays of bonded structural details (e.g., wing stringers disbonding past two mechanically
fastened rib stations ). When considering accidental damage caused by significant impact damage events
for thinner skin gages (e.g., outer wing skins for a wide body transport and empennage skin panels for
narrow body transport), the disbonding occurring at skin/stinger interfaces may approach this critical size
because the resulting peak shear loads cause that much damage. Finally, environmental degradation is
always a challenge for further bond degradation, particularly in the case of metal bonding.
Bonded repairs require approved design and strict processing control to ensure good quality for specific
materials and processes used. Common process errors such as high humidity, improper surface prep,
bondline contamination, insufficient temperature control (overall heat management to avoid overheating
or under-cure), loss of vacuum or pressure, and use of materials outside time and temperature or calendar
life limits can cause low bondline strengths. Finally, no reliable post-process NDI techniques currently
exist to ensure a bonded repair has full strength.
31
Page 32 of 123
FAA approved substantiation data is required to demonstrate compliance with regulations. The data starts
with approved material and process specifications followed when installing a repair. Experience has
shown that when experienced technicians install approved repair designs using proper tooling, equipment
and procedures in accordance with specifications there is reasonable confidence the bondline will achieve
full strength. The substantiating data that supports proof of structure for the bonded repair must also
include the tests or analyses supported by tests that meet the applicable regulatory requirements for
fatigue and damage tolerance, static and dynamic strength, material and fabrications specification,
statistical material design values, flutter behavior, and lightning protection.
An industry composite working group met over several years prior to release of this policy to discuss the
technical issues for bonded structural repairs and the best practices needed to show compliance with the
regulations. Supplementary background information compiled in these meetings is included in a public
reference (Ref. 9). Attachment 1 to Ref. 6 further documents some of the discussions associated with
experience in bonded field repairs and a need to follow approved documentation, while avoiding reverse
engineering approaches for specific critical composite structure.
AC 20-107B (Ref. 5) provides some further discussion of the bonded structure or repair qualification,
quality controls and reliable procedures needed to ensure weak bonds are rare. The bonded repair size
limits are first constrained by the data collected in establishing sound fabrication processes and
substantiating the design. In addition, the bonded repair may be no larger than needed in demonstrating
residual strength for a failed repair. All other approaches applied in establishing bonded repair size limits
must have approved substantiating data, inspections or other procedures, as necessary, to prevent
catastrophic failure. Residual strength requirements with the repair failed must be shown by tests or
analysis supported by tests. Some structures have limit load capability, even with a very large failed
repair. If significant changes in structural stiffness and/or geometry result from the failed repair, analysis
for flutter and other aeroelastic instabilities are performed to ensure the failed repair does not lead to other
flight safety issues.
Documentation on all repairs added to the maintenance records for the specific part number supports
future damage disposition and repair activities performed on the same part. It also helps ensure the
associated data, including repair design and process details, structural substantiation evidence, and
inspection procedures, are available to those evaluating airworthiness. Some specific guidance on the
engineering data and procedures, including the information needed for repairs not in compliance with the
existing Design Approval Holders’ Manuals, appears in AC 43-214 (Ref. 10).
Any failed bonded metal or composite repairs should be reported through the normal incident or accident
reporting process (e.g., failure, malfunction, or defect reports required by 14 CFR 21.3 or service
difficulty reports required by 14 CFR 121.703).
The inspection of bonded repairs, including the specified inspection methods, interval and detection
criteria, must be defined based on substantiating tests, analyses, trials, and other safety risk mitigation
procedures. With so many, different organizations reacting to the challenges of generally non-standard,
best industry composite and bonded structure maintenance procedures, the TAMCSWG recommends that
the FAA continue to seek international standards in this area.
32
Page 33 of 123
OEM to Operator/Maintenance Knowledge Transfer
An Industry/Regulatory Composite Working Group (IRCWG) has addressed bonded structure, damage
tolerance and maintenance since 2005. Industry knowledge of many field design and application details
for these subjects were not widely documented in public reports before these efforts. Charter members
for the IRCWG were Airbus, Boeing, EASA and the FAA. Figure 2 shows some of the important
milestones relating to IRCWG efforts over the time of its existence. The group remained active during
current ARAC WG efforts, helping to educate members not readily involved in composite applications.
As also noted in Figure 2, other members joined in this effort from the Bombardier and Transport Canada
Civil Aviation (TCCA) near 2011. In fact, most TAMCSWG members having experiences in bonding
contributed to the milestones shown in Figure 2. Those TAMCSWG members felt that it may be difficult
to continue such support at this level into the future given retirements and other related factors.
Figure 2. A timeline showing Composite Damage Tolerance and Maintenance Initiatives affecting related
FAA, EASA and TCCA regulatory guidance releases and educational materials.
33
Page 34 of 123
Early meetings in 2005 and 2006 were associated with the development of a Composite Certification
Tutorial presented before CMH-17 Meetings and a composite maintenance, safety awareness, course
developed for the industry and FAA Flight Standards Inspectors. The composite maintenance course,
which was co-developed with the SAE CACRC, has a related standards document on the key objectives
and teaching points to facilitate the development of an international course standard. This document has
undergone periodic updates over time and most recently revised as AIR-5719B (Ref. 11). The IRCWG
also led three industry/regulatory workshops (2006-2009), expanding industry and regulatory
involvement, and creation of CMH-17 Volume 3, Revision G updates for fatigue, damage tolerance and
maintenance. The related efforts made best industry practices public, forming a basis for the primary
regulatory guidance under development, AC 20-107B (Ref. 5), released in 2009. This regulatory
guidance as harmonized with EASA AMC 20-29, includes the most complete coverage on fatigue and
damage tolerance and related maintenance practices for composite structures.
Note that the Composite Maintenance Technology (CMT) Course, taught for Flight Standards Inspectors
for more than 10 years, was also available to the industry through Wichita State University (WSU) for
several years after it was first developed. The WSU CMT course had industry instructors from United
Airlines and Delta Air Lines when it was last taught. It is currently under reconsideration at WSU and
potentially restarted in the coming years. The FAA course remains available to the FAA only through
ABARIS Training Resources, Inc.
In 2011 and 2012, the CMH-17 Revision G documents were released, supporting the more general
guidance from AC 20-107B with means of compliance details for an industry that has not achieved the
same level of standardization as metallic applications. One of the primary reasons for delays in
standardization is that the composite fatigue, damage tolerance and maintenance practices are far more
data intensive and dependent on design criteria, empirical design values and related design constraints;
and hence, company-specific structural design and processing details than metallic designs.
Metallic damage tolerance uses mature analytical methods and shared material data to address crack
growth and establish maintenance practices for many different structural details. Growth of a limited
number of small cracks typically do not affect composites. Instead, the damage tolerance of bonded
composite structural details depends on accidental damage that include countless matrix cracks, relatively
large delamination in multiple layers and fiber failures, which is difficult, if not impossible to analyze due
to an unbounded number of interacting damage metrics, which affect damage stress concentrations and
load redistribution. This is true even though composite damage assumed for purposes of design typically
only grows in residual strength tests with increased loads approaching final failure. However, growth is
not evident in smaller accidental damage or manufacturing defects under realistic fatigue load conditions.
As a result, tests and supporting analyses demonstrate that these defects may exist for the life of the
structure, without loss of Ultimate load strength capability. Use of composite structures is desirable in
modern aircraft design due to significant weight savings (about 20 to 25%), the associated reduced fuel
costs, as well as advances towards reduced manufacturing and maintenance costs.
Composite damage tolerance focuses on residual strength predictions which may be semi-empirically
managed using stress concentrations and load redistribution factors similar to metals when assuming the
largest accidental damage sizes behave similar to large notches (e.g., Category 3 company-specific,
design criteria). Even smaller accidental damages use a process for deriving the appropriate design values
and no-growth demonstrations for conservative Category 1 and Category 2 design criteria. Stiffened
panel tests of sufficient size help establish conservative design curves for static strength (with allowable
barely visible impact damage, BVID) and clearly visible impact damage (CVID) damage tolerance repeat
34
Page 35 of 123
inspection intervals. Unfortunately, OEM have not combined efforts to standardize these design criteria,
conservative design value test practices and the specific materials and processes used to manufacture
composite fuselage, wing, empennage and control surface principle structural elements (curved shell
structures, torque boxes and the associated attachment details). With the current state of the industry and
standards for associated materials and processes, it seems unreasonable for such standardization to occur.
However, efforts are underway to make the specific design practices more visible, allowing end users
(airlines and cargo transport companies) and third party maintenance organizations to better understand
how design criteria and constraints can facilitate affordable solutions for related engineering problems
that require significant structural testing.
The areas where composite damage tolerance analyses have advanced to support the specific damage
threats include checks for lost bonded structural capabilities between base design arrestment features and
lost bonded repair skin patch/element details. In both of these cases a representative damage state can be
defined and simulated in the analyses to predict disbond or delamination growth and the effect on
structural residual strength. Such analyses require an assessment of the in-plane stress concentration,
including loads redistributing due to element buckling and any growth occurring between bonded
elements. The approach for the former still relies on semi-empirical data and/or failure criteria for the
specific skin laminates, which may have in-plane stress concentrations such as holes or other structural
design details (e.g., as applied in meeting expectations to define bonded repair size limits for limit
residual strength assessments). The design and related analysis approach for lost bonded attachments
between bolted structural arrestment details have used more analytically-based fracture mechanics
approaches. The associated fracture toughness data to address composite design details may require more
material properties (Mode I, II and III fracture properties) and interaction criteria for the most general,
mixed mode cases arrested by fastened design details. When growth is possible, this effort may require
affordable NDI options or it becomes further complicated because visual detection of larger disbonds
require internal access to composite structures and; hence, the desirable inspection interval has longer
time periods to accommodate the higher costs associated with access.
Figure 2 shows that efforts to create additional composite safety awareness courses spanned the times
from 2011 through 2013, covering both structures and manufacturing disciplines. The most extensive
course was for structures technology, which spans two full weeks of classroom time to cover material and
process control, design, structural substantiation, manufacturing interface, maintenance interface and
other considerations. In this same timeframe, Bombardier and Transport Canada became active members
of the IRCWG, supporting CMH-17 efforts for Volume 1 & 3, Revision H and Volume 6 (Sandwich),
Revision A, all of which had related bonded structures, damage tolerance and maintenance initiatives that
expanded with the onset of the current ARAC TAMCSWG efforts. In 2014, the IRCWG Bonded Repair
Initiatives completed initial efforts in developing the detailed basis for CMH-17 and CACRC guidelines
supporting bonded repair size limits. The FAA and EASA published related guidance late in 2014. In
2015, a fifth Damage Tolerance and Maintenance Workshop conducted in combination with a special
session of the TAMCSWG (at Bombardier in Montreal, Canada) helped provide some of the first public
information on experienced industry guidelines for hybrid composite fatigue, damage tolerance and
maintenance practices. Both bonded repair structural substantiation and High Energy Wide Area Blunt
Impact (HEWABI) damage also had special sessions at the workshop.
As shown in Figure 2, the FAA initial release of the HEWABI policy statement came in 2016. Concerns
for significant disbonding and delamination with HEWABI occurring to bonded and co-cured composite
structures relate to observations that very large areas of such damage are possible, without obvious
external visual evidence of failure because the skin panels may spring back following such an event.
35
Page 36 of 123
Detection of the significant lost structural integrity is possible using practical NDI procedures, including
those spanning large areas of the structure with lower-frequency bending waves but the trigger for such an
inspection depends on reliable reporting of the occurrence of impact damage. The TAMCSWG Final
Report (Ref. 7) has ARAC discussions on other considerations relating to HEWABI, including
recommendations for future FAA policy updates.
The IRCWG Meetings held from 2017 into 2020 have focused on further efforts that support composite
maintenance technology, knowledge transfer from OEM to operators and maintenance repair
organizations. Two main areas have been active. The first relates to sandwich disbond phenomena,
which can potentially lead to additional undesirable failure modes (e.g., fluid ingression, freeze/thaw
honeycomb core degradation) that can yield lost structural integrity. This phenomenon is undesirable and
is very difficult to predict beyond the initial disbond growth, as the additional failures are very complex
and dependent on several contributing variables, many of which lack practical understanding and
solutions. As a result, the focus of the effort is to establish sandwich panel designs whereby relatively
large disbonds are quickly arrested or unable to grow. Ref. 12 provides a summary of this
industry/regulatory initiative, which has plans for CMH-17 Vol. 3 (Rev. H) and Vol. 6 (Rev. A)
documentation by 2022.
The other area of recent IRCWG focus was that of substantiation of bonded repairs (SoBR), which
traditionally proved to be a challenge for the field of both metals and composites. The Safety
Management portion of CMH-17 PMC Volume 3, (Chapter 17) provided a continued operational safety
(COS) basis for this initiative in Revision G (released in 2012) when it documented real-world case study
highlights relating to Ref. 8. Multiple field repairs developed without the assistance of an OEM and
beyond repair options documented in a Structural Repair Manual for the specific part on a given product
have proved to lack structural integrity, leading to unsafe conditions. The delinquent repair typically
linked to a root cause involving inappropriate/unqualified material or process substitutions, avoidance of
tooling, and little or no proof of structural substantiation for the actual repair design/process details
performed and approved by designated engineering representatives of the FAA. The SoBR WG
(comprised of both OEM and non-OEM industry and regulatory subject matter expert representatives) is
presently working to update CMH-17 PMC Volume 3, Chapter 14 for Rev. H (plans for a 2022 release).
In addition to documenting SoBR information, the FAA is also investing in the development of a related
short course to be made available for regulatory industry designated engineering representatives
supporting both OEM and field design efforts; the TAMCSWG encourages and advocates the FAA to
take lead for this training development and execution. The overall goal to support both these deliverables
is to establish guidelines and document best design, analysis, test and processing practices, assuming that
the repair may not be based on publicly available information (without support from the OEM). This
leads to bonded composite or metal structural challenges that differ for conventional metal construction
where reverse engineering procedures are relatively straight forward and without the added tasks
commonly needed for composites and bonding (material & process qualifications, fabrication & bond
assembly tooling development; repair process trials; simplifying design criteria; structural tests and
empirical analysis developments; and more complex internal load estimates). This essential part of the
work, designated as prerequisite SoBR tasks, were the first, major addition to Chapter 14, taking more
than a year to create.
Many of the efforts by an independent maintenance organization with design approval authority remain
focused on the details of a given damage scenario and repair, providing the benefits of a focus, whereas
OEM repair development efforts often address multiple repair scenarios and the more general capabilities
36
Page 37 of 123
of many airlines or repair organizations involved in product maintenance. As a result, the specific task
focus and any engineering assumptions may be simplified and the cost or weight optimum solutions will
often depend on differing cost centers due to a lack of previous data for the part repaired. The SoBR Task
Group determined that one of the best ways to demonstrate such repair challenges is to create a series of
case studies for specific repair details affect the repair solution. All case studies meet the same regulatory
expectations for related technical issues, but show how the precise location of the repair and certain
knowledge held by the repair team may promote simplifying SoBR assumptions and; then, follow by
explaining why that solution would not work for a different damage scenario occurring to the same part.
One final FAA & industry initiative of note for purposes of advancing composite and bonded
maintenance knowledge transfer is the possible future use of an advanced Technical Standard Order
(TSO). A TSO may be one regulatory mechanism whereby the additional work to approve SoBR options
is completed prior to facing a repair or inspection challenge not available in existing data. The FAA is
already pursuing two classes of design data under the TSO: 1) basic material qualification information,
including basic material allowables & associated material procurement and process specifications and 2)
long-lead design data generation (e.g., empirical design values, criteria, processing Quality Control trials
and related constraints essential for affordable composite developments). Both classes of data support
affordable or more efficient design, particularly when occurring in organizations not currently classified
as an Organization Designation Authorization. The use of a TSO for maintenance purposes could
include:
 global standardization of specific composite practices applied to past, current and future airplanes
 added structural repair design options, created by a partnership of end users & part manufacturers
 OEM, airline customers and selected maintenance partnerships expanding approved specific part
maintenance options for inspection, repair and operational functionality
 industry consortium establishing new maintenance options for after-market airplane usage
Key members of the TAMCSWG recognize that their support to the many years of composite knowledge
sharing described in this section may not be sustainable. The several industry & regulatory actions
undertaken to-date (reference Figure 2) have resulted in clear progress in minimizing the knowledge gap.
And, accordingly, the TAMCSWG recognizes the advantage of assembling such experiences and
knowledge in a more formal way through the international standards organizations that have documented
such information to date. Future efforts should continue with the help of a sustainable industry/regulatory
sub-team and new members recruited from all organizations currently gaining transport airplane
experience, even if many existing working group members retire by re-assembling those that remain via
other forums.
4.2.6 Practical Inspection Considerations

Quality management is important to many aspects of bonded repair. Some combination of in-process
controls and post-bond inspections are required. As is the case for structural bonding in a factory, NDI
alone provides necessary, but not sufficient, evidence on the achievement of proper bonding. Other repair
in-process controls applied to surface preparation, adhesive mixing, bond assembly, and cure provide the
necessary complement to post-bond NDI.
Two SAE CACRC standards were written to document industry best practices for metal bond (AIR 6291
[Ref 14]) and composite bonded repairs (AIR 6292 [Ref 15]). Each report provides detailed explanation
37
Page 38 of 123
of the process steps, including: use of tooling, roles and responsibilities of personnel, material storage, in-
process controls and inspection. The report includes case studies that illustrate typical field problems and
how they can be avoided. Both reports are the responsibility of the CACRC Procedures Task Group and
undergo periodic updates for purposes of reaffirmation. The report standardized the common best
practices among OEMs and MROs, however it assumes an approved part-specific Repair Document for
all the part and material specific requirements. A future CACRC standard is in draft for damage
characterization and reporting. The document is intended to standardized industry best practices with the
goal of reducing time for interactions with the OEM and other repair support. Repair design and its
substantiating data first requires accurate damage description and NDI findings, followed by coordination
with a number of supporting parties or individuals.
Another part-specific document that integrates the bond process and design and certification is the
inspection for and disposition of manufacturing processing defects and discrepancies. As discussed
previously, design data development and structural substantiation support control of manufacturing flaw
sizes via documentation of the tolerances for normal manufacturing deviations. These documents are
necessarily along with enough detail to properly cover the range of materials used. For example,
honeycomb documentation can be over 20 pages for the tolerances for cell shapes, node disbond, potting,
splicing, orientation, surface waviness, edge waviness, chamfering, machining, cleaning. etc.
Documentation for the manufacturing deviations of prepreg and laminate should include tolerances for
waviness, orientation, yarn or weave distortion, wrinkles, porosity, ply splicing gaps and overlaps, resin
starvation, resin rich, inclusions, trimming, machining, marking, use of filler plies, compaction
temperature allowed. The assembly should include guidance on deviations such as cure cycle deviations,
thermocouple placement, inclusions, uneven faying surfaces, surface depressions, contour warpage, hole
quality, fiber breakout of holes, delaminations and disbonds, etc. The deviation documentation should
include, at a minimum, the limits to accept or reject, and the option to include documented limits and
procedures if rework is possible. These in-process manufacturing quality standards, which are used
during the OEM manufacturing, also apply for in-service repairs and should be implemented in the
manuals available to MROs for repairs. As a result, they should be part of MRO training and quality
control program. We recommend inclusion of such details in manuals, in training materials and as
potential area for standardizations such as CMH17 or SAE-CACRC.
The quality control process for repairs or manufacturing should include a write-up for any deviations and
review by engineering. The engineering review will result in accept, reject or rework, as justified by stress
analysis and/or testing that is consistent with the original design certification basis including materials and
processes. For in-service repairs by MROs, if the data is not accessible then consultation with the OEM is
required.
Once a repair is completed the part will be reinstalled an aircraft and subject to the existing aircraft
maintenance program and inspections. Therefore, during the repair design consideration is given to
whether the exiting instructions for continued airworthiness are still applicable including change of the
failure mode, change to visual indications of failure, and the effect of the repair on the non-destructive
testing. NDI methods and equipment for repair inspections may have to be adjusted, or additional
reference standards produced, to account for increase in porosity. This is due to the attenuation of repair
material that is different from the original, additional bondlines and surface roughness.
OEMs typically collect data regarding typical minor defects (e.g., porosity, resin thinning, fiber distortion,
etc.) for bonded repairs as the repair techniques and processes are established for fleet support. Revised
limits for typical bond anomalies may be published with the OEM structural repair manual procedures.
38
Page 39 of 123
Additionally, some anomalies may be acceptable with the addition of mandated inspections using NDI
techniques although this is typically avoided.
This section was assembled by a few TAMCSWG members that have knowledge in this area. Other
OEM, MRO or airline experiences may also have related knowledge. There has been great promise of
advanced inspection procedures for a very long time but there are no guarantees for such technology and a
team of users are needed to make judgments on what is and isn’t practical for the field environments.
4.2.7 Possible Aging Limits to Metal and Composite Bonding

There is a distinct difference between metal and composite bonding aging mechanisms, favoring the latter
for long-term reliable performance. Metal bonded structure and repairs will typically degrade through a
complex process of hydration that will depend on design details, process quality and remain undetected by
current practical NDI methods. When hydration is active, failures will first appear with some mixed
mode surface characteristics indicating both adhesion and cohesive failures. Composites are sensitive to
several different forms of contamination, including moisture and known contaminates (e.g., fragments of
peel ply, amine blush); however, in many cases they don’t have the equivalent phenomena of hydration
where the bond continues to degrade unpredictably from a weak bond to no strength. Instead, composite
bonding problems often yield an understrength bond that may allow subsequent reliable estimates of
growth, residual strength and reliable inspection intervals. The TAMSCWG recommends future research
to understand such composite challenges.
Both metal and composite bonding have aging mechanisms that are extremely dependent on stringent in-
process control of many critical steps, with the process itself yielding manufacturing defects that remain
the problem in weak or understrength bond degradation. The important process considerations include: a)
substrate surface preparation, b) adhesive mixing and application, c) bond process known contamination
and environmental controls, with some added concern for moisture challenges for on-wing field repairs,
d) mating surface contact and heat management throughout cure, and e) assurance that the overall bond
system is qualified. There should never be material substitutions based solely on individual mechanical or
physical properties because the bond system requires compatible substrate and repair materials (patch and
adhesive), and process steps as identified above. Any indication of adhesion failures during bond
qualification testing, structural substantiation, production and repair applications is cause to be suspicious
of the bond system. It is either not properly controlled during processing or is using unqualified materials
and requires immediate attention. It is not plausible or possible to manage adhesion failures through
damage tolerance practices that predict related damage accumulation with reliable inspection methods and
intervals. Similarly, life demonstrations that end in adhesion failures also suggest that the life estimates
and any perceived conservatism is unreliable.
The aging limits for metal and composite bonded structure has been challenging to document because
many problems that occurred in early applications were not documented as the aging occurred relatively
quickly and often involved numerous bond process and design challenges for companies new to the
specific adhesive materials applied to such critical applications. As a result, the company derived
improved bond process and design practices, while the challenges remained undocumented in public
literature. As this is one area where the state of the art is still controlled by hard learned lessons, which
are not shared throughout the industry, the TAMCSWG recommends that industry document past
experiences for future avoidance of the same mistakes occurring with those not previously exposed to
39
Page 40 of 123
significant structural bond experiences. Again, the best location for such documentation would be
international standards documents that welcome such knowledge shared after the wounds have healed and
industry members have moved into better bonded structure aging experiences.
5.0 Costs & Benefits Analysis

This section focuses on the cost and benefits analysis of the changes to guidance discussed in Section 4.
These proposed changes capture the current industry practices employed by the companies supporting the
TAMCSWG. Most of these changes are already part of current OEM practices, nevertheless for
completion of the report, some cost details are provided in the following sections
5.1 Cost
We propose to review 3 points as potential cost impact
- 1. Cost of redundant design specifically to illustrate this principle: the “Disbonds and
related delaminations of each bonded joint greater than this must be prevented by design
features. Additional costs are associated with some typical designs requiring ‘chicken bolts’
(bolts and implementation cost and also the weight impact). Reference Figure 3 for illustration
of application of such fasteners.
Estimated number of anti-peeling rivets (chicken rivets) is around 1000 for conventional
composite fuselage mainly around all types of doors / access holes.
The total cost is about $2.9k for drilling and installing these fasteners. (assumption of lockbolts
with semi auto or auto drilling and -3 or -3A dia).
Figure 3. Illustration of use of mechanical fasteners (chicken rivets/bolts) in structural bond

applications.
- 2. Cost of a robust quality control plan
Two levels are presented: standard one (stabilized production) and “reinforced” ones on earlier
production of new technologies with process control specimen for bonding performances) at
production level and also in bonded repair conditions (repairs level including MRO)
40
Page 41 of 123
Current industry practices for bonding processes already include some stringent qualification
processes with, potential temporary bonding performance tests done on new design and/or new
technologies/manufacturing processes/cost of such additional tests is on top of any materials and
manufacturing processes and can be represented by a peeling test (G1C as example)
The associated cost induces serial productions cost: Today G1C cost is around $580.
Cost for G1C, example on VTP
If we assume $1200 per specimen, 3 specimen per autoclave cycle representing both skins, 600
airplanes per year. Total cost for specimen is $2.2M. This is just specimen manufacture, testing
and report.
- 3. Cost of an inspection principle for life extension and potential large Cat 2 DTDC, as a
potential mitigation on life extension , to detect any ‘aging’ phenomena or scheduled
inspection need.
“AC 20-107B, 8.c. Combined Damage Tolerance and Fatigue Evaluation. Generally, it is appropriate for a given structure
to establish both an inspection program 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 programs (including NDI and destructive tear-down inspections), and
appropriate statistical assessments of accidental damage and environmental service data considerations. “ for bonded
structure on PSE.
In Manufacturing:
- The detection by "Visual Inspection" is possible in "obvious" cases. In most cases this is done with
ultrasonics.
In-Service:
- Usually there are other indications that lead us to perform a visual inspection of the bond-lines. For
example, impact damage, or a top-layer delamination, provide an indication of possible debonding. By
experience it can be detected by visual inspection if there is a gap between the skin and the stringer foot.
At a touching distance, with specific light conditions (including torch), inspectors must look for a "black"
line (= the gap) that is a visibly evident color (a grey color for example). In an in-service aircraft, the
surface must be cleaned, otherwise identification of a disbond can be challenging:
Regarding the inspection time (In-Service), the most efficient technique currently is to use an ultrasonic
roller probe. Time necessary for inspection can be an average considered as 15 minutes per stringer per
meter. On the top cover (Wing/HTP….) it should be faster (good ergonomic position), on the lower cover
it is a difficult job (much worse ergonomic position).
Assuming approx. 240 m of stringer in 1 skin, this is ~60 hours. It could take 1 week for the upper skin of
a wing, and around 1.5 weeks for a lower skin.
41
Page 42 of 123
5.2 Benefits
A robust quality control plan and associated qualification data are part of the bonding technologies
qualification under §25.603 and 605, and therefore not included, additional effort for a robust quality
control plan is already common practice for structural bonding in the Industry. This is considered
acceptable given the benefits to safety and industrial impact.
Design precaution as “chicken bolts” when implemented, should remain reasonable effort understanding
the MLP of a given detail design, but should not be a strict requirement to address MLP (see previous
sections addressing redundancy and sufficient SDC).
Life Extension: Past experience for extending life for bonded structure has not resulted in any
additional inspections and costs compared to bolted structure or for metallic structure, except in cases
where in-service reliability issues had previous resulted in a decrease of inspection interval in order to
reduce schedule interruptions.
Most of these cases are due to corrosion of aluminum honeycomb sandwich structure, or galvanic
corrosion of metal in hybrid graphite composite parts.
6.0 References
1. Tomblin, J., Strole, K., Dodosh, G., Ilcewicz, L., DOT/FAA/AR-05/13 “Assessment of Industry
Practices for Aircraft Bonded Joints and Structures”, 2005.
2. CMH17 (Revision H) - Chap3 (Structural bonding, Chap 10 (Design and Analysis of Bonded Joints),
Chapter 14 (Supportability and Maintenance), approved draft content, final release date 2023.
3. Momm, G., Ilcewicz, L., Ashforth, C., Fleming, D., “Bond Related Aircraft Accidents/Incidents: A
Review", Society for the Advancement of Material and Process Engineering neXus Proceedings, June
29-July 1, 2021.
4. PS-ACE100-2005-10038: Bonded Joints and Structures-Technical Issues and Certifications

Considerations.
5. AC 20-107B, 2009, Composite Aircraft Structure (add the harmonized EASA AMC document released
in the same timeframe).
6. FAA Policy Statement, Bonded Repair Size Limits, 11/24/14, PS-AIR-20-130-01 (harmonized with
EASA Certification Memo CM-S-005).
7. Transport Airplane Metallic and Composite Structures Working Group (TAMCSWG) Final Report –
Recommendation Regarding Revision of the Damage Tolerance and Fatigue Requirements of Title 14,
Code of Federal Regulations (14 CFR), Part 25, including subparts C and E of 14 CFR Part 26, June
27, 2018.
8. DOT/FAA/TC-14/20, November, 2014, Nonconforming Composite Repairs: Case Studies, Charles

Seaton and Sarah Richter
42
Page 43 of 123
9. Industry and Regulatory Interface in Developing Composite Airframe Certification Guidance”, Cindy
Ashforth, Rusty Jones and Larry Ilcewicz, published in the Proceedings for the American Society for
Composites 29th Technical Conference, September 8-10, 2014.
10. AC 43-214, Repairs and Alterations to Composite and Bonded Aircraft Structure [4/2013] [Note: AC
145-6 was cancelled.]
11. AIR 5719B, March 26, 2018, Teaching Points for a Class on “Critical Issues in Composite
Maintenance, Repair and Overhaul”, SAE Aerospace Information Report.
12. “Scaling Crucial to Integrated Product Development of Composite Airframe Structures”, Larry
Ilcewicz, Cindy Ashforth, in: Beaumont, P.W.R. and Zweben, C.H. (eds.), Comprehensive Composite
Materials II, (2018) 3.2, vol. 3, pp. 26–90. Oxford: Academic Press, © 2018 Elsevier Ltd. All rights
reserved.
13. “Primary Adhesively Bonded Structure Technology (PABST), Design Handbook for Adhesive
Bonding,” D.L. Potter, Air Force Program, March 1977 to January 1979, Final Report, AFFDL-TR-79,
Douglas Aircraft Company, November, 1979.
14. AIR 6291, “Guidelines for Repair Process Evaluation of Aluminum Bonded Structure,” SAE
CACRC, July, 2014.
15. AIR 6292, “Guidelines for Repair Process Evaluation of Fiber Reinforced Composite Bonded
Structure,” SAE CACRC, release date to be determined, currently in process.
43
Page 44 of 123
7.0 APPENDIX
7.1 Appendix 1: Historic review of existing guidance

The most complete regulatory guidance that currently exists for bonded structure is a policy statement
called Bonded Joints and Structures - Technical Issues and Certification, which was issued in 2005 (Ref.
4). Although released as a small airplanes policy, it was derived from an interface with the industry for
many aircraft product types, including transport airplanes, small and transport rotorcraft, engines and
propellers. It addresses three types of bonding: a) composite to composite, b) metal to metal and c)
composite to metal.
In 2004, tasks to benchmark industry practices for structural bonding initiated. The efforts included a
survey and two bonded structures workshops (June 2004 in Seattle, Washington and October 2004 in
London, United Kingdom) to engage experts from around the world. These efforts addressed the full
scope of certification from type design to production and continued operational safety, ultimately leading
to a strong industry basis for the 2005 FAA policy statement (Ref. 4). Technically, the policy covers (1)
material and process qualification and control, (2) design development and structural substantiation, (3)
manufacturing implementation and experience, and (4) maintenance implementation and experience.
FAA Technical Report [DOT/FAA/AR-05/13] documents the results of data collected in the survey and
2004 workshops (Ref. 1).
In 2009, content from the 2004 policy statement was generalized and combined with five more years of
experience gained from an industry interface to create bonding content added to several sections in AC
20-107B, Composite Aircraft Structure (Ref. 5). In the same timeframe, studies performed with several
airlines evaluated bonded repair for transport airplanes. At this point in history, some of the maintenance
work previously performed by airlines started off-loading to maintenance repair organizations as a cost
savings initiative. Some problems with composite bonded and bolted repairs led to a number of case
studies jointly documented by the FAA and selected airlines (Ref. 8). The findings from these studies
were such that there were more case studies than the FAA had funding to document, leading to an
additional interface with the composite maintenance industry. In 2014, the FAA created another policy
statement, Bonded Repair Size Limits, PS-AIR-20-130-01 (Ref. 6). This policy reinforced the same
bonding expectations outlined in AC 20-107B for base structure and repairs but with additional details
and under a title emphasizing repair applications.
Material and Process Controls
All existing regulatory guidance emphasizes stringent material and process control as the primary
requirement for safe and long-lasting applications of bonded structure. Without attention to bonded in-
process controls, such structural joints can become unreliable and degrade at an unpredictable rate,
making safety management nearly impossible to achieve using modern day damage tolerance principles
and practical maintenance practices. Industry recognizes that bonded structure relies on in-process
material and fabrication controls to ensure success. Post-process inspection methods, including state-of-
the-art nondestructive techniques are unable to reliably detect understrength or weak bonds caused by a
number of challenges that, left unchecked, may arise during the course of several bond-processing steps.
The FAA policy statement called Bonded Joints and Structures - Technical Issues and Certification from
2005 (Ref. 4) discusses the related issues within the four key areas summarized below.
44
Page 45 of 123
Qualified Materials and Processes Demand a Systems Approach
Qualification procedures demonstrate the stiffness, strength, durability and reliability of bond materials
and processes for aircraft applications. Qualification tests evaluate structural performance, environmental
effects and long-term durability. For composites, qualification testing is initially performed for new
materials and the processes used for fabrication purposes. This material qualification becomes a
prerequisite to subsequent bonding process qualification. The series of material and bond process
qualifications constitute an overall bond system qualification that starts with the base material
qualifications and ends with a final qualification that systematically combines the base material
qualification, adhesive qualification, and a final qualification that combines all key bond process steps
essential for all representative bonded structural joints. Any major changes within this bond system may
require a new bond system qualification. Unfortunately, all contributing factors leading to a successful
bond system qualification are not understood theoretically and; hence the need for the empirical data trials
that demonstrate bond qualification.
For bond processes applied to composites or metals, such efforts start with defining key bonding
processing steps and selecting compatible substrate, adhesive, surface preparation procedures, other
processing details and any ancillary materials essential to achieving a chemical bond. In coordination
with qualification, it is also important to establish (1) processing tolerances, (2) material handling and
storage limits, and (3) key characteristics and process parameters to monitor in quality control. Most
bond failures and service problems trace to invalid qualifications, material or process step substitutions,
uncontrolled processing limits or insufficient quality control of key production or repair bond process
steps. For example, substituting apparently similar adhesives or surface preparation process steps with a
given substrate can result in bond failures.
Bond fabrication procedures should include trials that demonstrate compatibility between the substrates,
adhesive, and processes. Some of the most important process steps relate to substrate storage, handling,
and surface preparation. Reliable adhesive bonding depends on:
1) a surface free of contamination,
2) a chemically active surface, and
3) a dry surface.
The storage, handling, and surface preparation procedures needed to accomplish all three of these
characteristics will depend on the specific substrate and adhesive materials. There are distinct differences
for composite and metal substrate materials. Sandwich core materials such as honeycomb and foam will
also have unique process differences, depending on the base material type. Film adhesives have storage
and handling requirements similar to pre-impregnated, uncured composite materials. Paste adhesives will
likely have different components that require precise mixing before application.
Another important aspect of the bonding process is adhesive cure. The bonding surfaces must contact the
adhesive with sufficient pressure and temperature to accomplish cure and bond adhesion. The cure cycle
defines the sequence, ramp rates, and dwell times for temperature and pressure application. Explore bond
process tolerances to define the acceptable range for resin mixing, surface preparation, and cure
processing steps in documenting preliminary specifications during material compatibility trials. Such
trials serve a purpose before proceeding with complete material and process qualifications. It is also wise
to perform some bond process trials with representative structural geometry and tooling to ensure valid
bonding procedures beyond laboratory trials and into structural scales.
45
Page 46 of 123
Bonding materials and processes are qualified for use in structural applications. The overall goal of
qualification testing is a basic characterization, which best represents the materials and processes in the
application. As a result, specific specimen types and test conditions used in qualification likely depend on
the application. Most programs use some qualification tests to help set benchmarks in chemical, physical,
process, and mechanical properties, which combine with other quality checks for subsequent material and
process control. Enough unique batches of materials, independent bonding process trials and test
repetitions ensure a representative population for reliable benchmarks, albeit at the lower scales. It is
noteworthy to mention that successful qualifications often follow established material selection
procedures, which check several candidate materials in case some prove to be a challenge that affects
schedule milestones. Alternate choices to start may cost a little more but the payoff comes in avoidance
of negative schedule impact near the start. It also gives different functional disciplines to help decide the
best choices with some data in areas of interest.
Substrate materials used in aircraft products are typically qualified before bond processes. Adhesive
material qualification may also occur separate from bond process qualification. This is a common
industry practice when an adhesive combines with several different substrate materials because it is
desirable to control the adhesive material with a set of properties that are not dependent on each specific
bonding application. As discussed previously, a separate bond process qualification supports each unique
combination of materials because of the complex interface between substrate and adhesive, which
depends on many variables (for example, material compatibility, surface preparation and cure kinetics).
Further guidance on adhesive and bond process qualifications appear in Ref. 4. The industry uses several
different physical, chemical, and mechanical tests for adhesive material and bond process qualification.
Physical and chemical tests may be used to control surface preparation. Although useful for material
characterization and design, shear tests do not provide a reliable measure of long-term durability and
environmental degradation associated with poor bonding processes. Some form of a peel test has proven
more reliable for evaluating proper adhesion. Any adhesion failure, which appears as evidence of
chemical bond failures between substrate and adhesive materials found during the course of bond system
qualification are unacceptable and require further evaluation before progressing with qualification.
Adhesive and substrate material selections should also consider the bonded joint design configuration,
loading requirements, manufacturing process constraints, environmental conditions and chemical
resistance to fluids found in service. Reduction in strength properties at the maximum and minimum
operating temperature supports each application. Both temperature and moisture content affect the
properties of polymer composite substrate and adhesive materials, with a significant decrease in strength
above the wet glass transition temperature (Tgwet). Simple guidelines often used in selecting composite
substrate materials is for the Tgwet to be 50 °F greater than the maximum operating temperature of
structural applications. The analogous guideline for adhesive materials is for the Tgwet to be 30 °F greater
than the maximum operating temperature. Use more rigorous environmental testing for specific design
detail when selected polymer materials do not meet such guidelines.
Differences between Metal and Composite Bonding
There are many similarities in the processing controls used for successful metal, composite and composite
to metal bonding, starting with control of the joint tolerances to ensure good contact in an assembled joint
and precise application of the cure cycle, including heat management, heating/cooling ramps and time at
the peak cure temperature. Many experts consider surface preparation to be the most important process
step for structural bonding. There are distinct differences in the surface preparation techniques used for
46
Page 47 of 123
metal and composite substrates. Phosphoric acid anodizing, sol-gel and grit-blast/silane processes are
examples of surface preparation techniques that have worked for aluminum substrates. Sanding, media
blasting, and peel ply surface preparation techniques exist for composite bonding, but success depends on
the specific substrate and adhesive combinations, as well as other processing variables. Bonded sandwich
construction, which uses honeycomb or foam core material (composite or metal), requires specific
procedures for core surface control applied to achieve successful bonding.
The corresponding in-process and post-process NDI controls applied for composite and metal bonding
also have similarities and differences. The in-process methods used to determine the success of achieving
good contact between mating surfaces before applying adhesive often use an ancillary material such as
verafilm, which requires close control within the factory or shop to avoid contamination. This are also
important in-process checks for achieving bond-line thickness control. Cure cycles use thermocouples
and other aids to ensure proper temperature, vacuum and pressure controls. Surface chemical testing and
water drop testing have had good success in determining if a prepared metal or composite substrate
surface has proper activation to continue the bonding process. For composites, a plasma treatment
following the surface prep processing step has provided additional assurance in removing any
contaminate prior to the final bonding process steps. Through transmission, pulse-echo and guided wave
ultrasonic methods vary in wave frequency and amplitude content to inspect metals or composites but are
reliable post-process NDI methods.
As discussed previously, post-process mechanical testing helps further ensure bond success and forms a
basis for the qualification of specific substrate, adhesive and process combinations or for any changes to
the bond materials or processes over time. A wedge specimen that combines peel loads and extreme
environmental conditions has proven to be a reliable accelerated lab test for detecting unacceptable metal
bond processes, which would subsequently degrade over time and lead to adhesion failures in service.
Other specimen types used to evaluate weak or understrength bonds for composites include double
cantilever beam or a traveling wedge test. Bonded sandwich specimens often use rolling drum peel or
flatwise tension tests but more recently a single cantilever beam has proven more reliable for similar
assessments, although the processes and mechanisms of sandwich bonding is distinctly different than both
metal and composite bonding. Nevertheless, some form of peel testing appears most successful in
establishing reliable bonding processes for bonded sandwich applications as well as solid substrate
bonding.
Substitution Challenges
Extensive field experience has shown the suitability of a given qualified adhesive, substrate and bond
processes applied in a particular application, assuming the execution of all related in-process controls.
This would supersede the need for additional post-process tests unless questions arise on whether a
particular bond problem exists. Although convenient, avoid any significant substitution in the specific
qualified adhesive, substrate materials and bond process steps unless performing additional qualification
testing. There may also not be properly defined (or understood) boundaries and insufficient
documentation for approved substitutions under a given repair program. The temptation is always
greatest in the field environment when one of the qualified materials is not available, no longer exists or
process steps can’t be performed due lack of special equipment or ancillary materials. The associated
rework for an unsuccessful bonding operation is not worth the risk and if a bad bond passes inspection
and is returned to the field there are potentially high safety risks because bond material and process
control is the primary means of achieving reliable structural bonds.
47
Page 48 of 123
Regardless of meeting guidelines, any changes in material properties at temperatures above the maximum
operating temperature (for example, runway sun exposure) also need to be understood for their potential
effect on subsequent bond processing such as needed for repair. Facility controls on minimum and
maximum factory or shop temperatures, moisture and altitude can all affect the bonding and repair
processes. An understanding of the intended manufacturing or repair facility’s tooling concepts and
process steps is also useful in achieving reliable bonded structure. Material suppliers often have data that
can aid in selecting compatible materials for use in bonding but that may not meet the full rigor of a bond
system qualification focused on specific process steps applied for a given application. The necessary time
to qualify new combinations of substrate, adhesive and bond process steps is always worth the added time
and expense when considered against the safety concern and potential lost time and cost that may come
from using unqualified bond systems.
Bonded Structure Checks and Emerging Technology Evaluations by TAMSCWG
The TAMCSWG members, which have utilized bonded structures in the PSE for their aircraft products,
perform stringent in-process and post-process controls for production and field applications. There is a
clear consensus that such efforts are the most important and primary steps for structural bonding of
materials and manufacturing processes. The bond system first requires qualification and then, the related
serial/continuous quality control. Each OEM has differing levels of periodic checks to ensure continued
success and in the current proprietary state of the technologies, require such freedom to economically
achieve similar safety goals.
Some TAMCSWG members still make extensive use of metal bonded structures as dictated by
experiences. Most members use co-cured composite structures and apply bonded structures with the
added in-process controls felt necessary to achieve success in a somewhat more demanding set of bond
fabrication steps, including surface preparation. All members using bonded structures start with a system
qualification for specific combinations of substrate, adhesive and critical bond process steps. Whenever
using peel ply for surface preparation, it needs quality controls as a material critical to the success of
bonding, often including destructive bond cleavage test trials for specimens created with each new batch
of peel ply received at the factory. The bond process cell uses a controlled environment, free of
contamination and tolerance control for bond process tooling are always applied. Knowledge transfer of
key process control parameters, serial control of material and process verifications, some post-process
quality control tests and first part manufacturing destructive tests are essential precautionary actions
whenever moving production facilities to new partners.
Finally, bonded structures in service always receive periodic fleet management or surveillance by way of
visual inspection, usually during the Maintenance Steering Group (MSG-3) process. It is common to use
visual inspection when applying redundant design practices for bonded structure that will maintain limit
load in the rare case of a significant disbonding scenario within arresting features.
Many TAMCSWG members are currently evaluating new methods to improve the reliability of bonded
structure. Emerging technologies are likely for improvements to structural bond in-process controls and
post-process nondestructive inspection in the future. Despite past challenges, bonded structure continues
to advance reliability through a multi-faceted approach that starts with stringent material and process
controls. Documentation of these advances in expanded knowledge transfer of traditionally proprietary
data appear as significant updates to industry references such as CMH-17 (Ref. 2). Staying with a theme
of bond material and process control being paramount to structural integrity, some bond materials and
processes are restricted and not used on PSE.
48
Page 49 of 123
Other main points identified on the state of the art of Best Industries Practices for material and
manufacturing processes appear in the DOT/FAA/AR-05/13 (Ref. 1). One thought extracted in the
section on MATERIAL AND PROCESS QUALIFICATION AND CONTROL notes: “the specific
combinations of materials and processes used for bonding must be qualified for structural applications”.
This is currently reinforced by the performance-based regulations (e.g., Title 14 CFR 25.603), which state
that the structural suitability and durability of materials used in aircraft products must account for
environmental effects and be established by experience or tests. In addition, a companion regulation (e.g.,
14 CFR 25.605) state “fabrication methods must produce consistently sound structure.” The data
generated in material and process qualification serves as a basis for subsequent quality control. Use an
approved process specification to ensure sufficient reliability for fabrication methods such as bonding.
Over the last twenty years, the FAA has conducted research in bonding material and process qualification
and control with the help of industry. Some initial key areas of focus include composite bonding surface
preparation and the ancillary materials (removable surface layers such as peel plies and release fabrics)
used by industry. The research showed the importance of qualifying all the materials and process steps
used to develop a reliable bond (Refs. 1, 2). It also identified different test methods suitable for making
such a judgment. This work showed that release fabrics, which contain chemical release agents, are
unacceptable for use on composite surfaces that will be bonded because subsequent surface preparation
steps, such as grit blasting and sanding, cannot remove all the contamination. Peel plies, which do not
contain chemical release agents, should have different product designations. Use of peel plies in the
bonding process and whether sufficient surface preparation occurs with their removal appears to depend
on the specific substrate & adhesive combinations; the process used to cure the parts and other bonding
steps. Control multiple processing cycles at high temperature, such as occurs in element rework, must
also be controlled within proven limits because they affect peel ply performance in subsequent surface
preparation. Research continues in this important area, and the industry has adopted the practice of
distinguishing release fabrics from peel plies.
Manufacturing Challenges
Material and process control is an essential prerequisite for manufacturing implementation, but scaling
issues need early consideration to realize key facets of controlling the materials and processes at the time
of qualification. When implementing new bonding facilities and fabrication processes, manufacturing
trials help develop an understanding of structural details that permit reliable producibility. Scaling issues,
which directly relate to structural details, are likely for several bond process steps including surface
preparation, adhesive application, and cure control.
Tooling used for bond assembly and cure will depend on mating part geometry, cured tolerance controls,
and other factors that also relate to design details. An iterative process of defining structural details and
performing manufacturing trials, and testing for performance has proven successful for new design
development in the past. Such efforts become more efficient as a manufacturer gains experience in
structural bond applications.
Special facilities and procedures manage and control materials and key bonding process steps at the
product scale. The associated issues relate to cleanliness, environmental conditions, storage, material life,
processing records, staff training, and maintenance. Material control discussed in the previous section
start with procurement specifications applied to ensure batch-to-batch consistency. Factory procedures
and records manage the storage conditions, shelf life, out life and handling of all uncured materials to
ensure they meet the associated specification requirements. Cold storage conditions and handling
49
Page 50 of 123
procedures (for example, time required in the ambient environment before unpacking for use to avoid
condensation) are needed for some types of adhesives. The environmental storage conditions of some
substrate materials may also need to be controlled (substrate materials and bonding processes affected by
pre-bond moisture). Develop facilities and procedures to control of the bond assembly environment,
equipment, tooling, and training of factory personnel to avoid sources of contamination. Process
specifications outline the important in-process and post-process controls that ensure success. The
specifications often identify Key Characteristics (KC) and Key Processing Parameters (KPP), to control
during individual processing steps to avoid potential manufacturing defects.
Primary Manufacturing Defects and Associated Inspection Challenges
The most concerning challenge in bonded structure manufacturing defects comes from potential weak or
understrength bonds for both metal and composite bonded joints. Unlike many manufacturing defects,
these types of defects can be of significant size and escape detection through post-process NDI. The weak
bond or understrength flaws may also further degrade over time in a manner that is reliably predictable or
not reliably predictable. As a result, any bond process step that may lead to such primary manufacturing
defects must have sufficient in-process controls to ensure that these defects are extremely rare and, in the
remote chance that they form, must be smaller than allowed by redundant design features.
As discussed previously, many experts consider surface preparation to be the most important process step
in avoiding structural bond manufacturing defects. Depending on the specific materials in a given bond
system, surface preparation challenges also often depend on controlled process step timing (e.g., mixing
and application of paste adhesives), success in executing abrasion techniques (abrasion, grit blasting), peel
ply aging phenomena and the elimination of any other sources of contamination.
Manufacturing scaling issues for a proven bond system should not change when applied to a given
structure. As a result, scaling issues need careful consideration when selecting a surface preparation for
bond process qualification. The substrate surface morphology and chemistry, which exist when using a
qualified surface preparation process, should not change in production implementation or the qualification
testing may be invalid. Since specific bonded part geometries are often more complex than specimens
used for qualification, additional processing challenges exist. Some production process controls used to
monitor surface preparation include visual checks, polarized light checks, water break tests, chemical
analysis, and mechanical tests using samples from bonded witness panels. Once a surface is prepared,
some processes rely on time constraints during bond assembly, requiring a repeated surface preparation if
the bonding operation is not completed within the specified time.
Control expendable materials used in composite and metal bonding processes to manage sources of
contamination and avoid changes in bond process steps. For example, chemicals and blast media used for
different surface preparation techniques are controlled, discarded, and replaced as needed to maintain
process standards. Factory maintenance of facilities, equipment, and tooling ensures the cleanliness and
material and process controls needed for repeatable production of bonded structure.
There has been considerable experience generated over the years from use of peel ply to prepare
composite bonding surfaces of bonded stiffening attachments for transport aircraft primary structural
elements. The most common use of peel ply is for surface preparation of pre-cured stiffeners for co-
bonding with uncured composite skins for empennage and wing skin panels. Most of the challenges with
particular peel ply types were found during the bond system qualification efforts but a few escaped initial
qualification studies and were not understood until production experiences in large-scale fabrication.
50
Page 51 of 123
Some of the challenges occurred with aircraft released to service. The root cause was tracked to a lack of
sufficient peel ply batch material testing, factory mistakes (e.g., substitution of release fabrics for
approved peel plies) and the influence of other factory processing steps (e.g., multiple cure cycles for
purposes of cured stiffener rework, degrading the peel ply before removal). These challenges highlighted
the inability of post-process NDI to detect the problem but even though they were not realized until later,
structural redundancy achieved safe flight until repair and factory records were sufficient to properly
solve the problem through airworthiness directives.
For the manufacturing of any metal bonded structure, many OEM rely on experienced metal bonding
shops, such as Fokker, Gulfstream and Textron. The TAMCSWG contacted the former for a discussion
on their experience and both Textron and Gulfstream contributed to this report as a member of the ARAC
Team. Cessna first developed adhesive bonding of metal structure in the mid 1960’s in secondary
structure. During the late 1960’s, metal-to-metal bonding was extended to primary structure with design
and certification of the Cessna Citation (Model 500). Cessna continued to expand the use of metal-to-
metal bonding during the 1970’s in both Part 23 and Part 25 airplanes. The expansion was both
methodical and intentional, resulting in an approach and philosophy used by Cessna on the Cessna
Citation III (Model 680) in early 1980’s. This approach continues to provide the foundation used today at
Textron Aviation and is based on both the lessons from previous experience. Data from other industry
leaders in metal bond, and extensive development tests allows Cessna to take advantage of the benefits of
metal-to-metal bonded structure such as reducing stress concentrations due to fasteners, reduce weight,
improve joint sealing, and enhanced appearance.
Airbus had some lessons learned on the A300, as they collected significant in-service experience. Early
A300 metal-bonded shell design details did not use chromate acid anodizing, which lead to bond line
corrosion. All major companies had challenges with early metal bonded structures. Although from the
early days of bonding, one of the best references for metal bonded structures derived from the Primary
Adhesively Bonded Structure Technology (PABST) Air Force Program documented by Douglas Aircraft
Company (Ref. 13). Many OEMs with bonding experience have developed design/manufacturing
improvements that benefited products that use the technology. Unfortunately, the knowledge transfer is
just starting through organizations such as CMH-17 and SAE CACRC. The process of knowledge
sharing should continue for purposes of safety because many OEM have developed additional experience
and lessons learned that will continue to promote safe and efficient process/design improvements.
Bonded sandwich construction, which uses honeycomb or foam core material (composite or metal),
requires specific procedures for core surface control applied to achieve successful bonding. The use of
some solvents on honeycomb core surfaces can cause subsequent bonding problems. The surface
preparation procedures used for wood sandwich core materials (e.g., balsa) typically include abrasion.
Other bond process steps must also have in-process controls that need proper scaling for production
applications. There are geometric, fit-up and other timing issues to consider in bond assembly. Control
cured dimensional tolerances and warpage for mating parts. Since the bondline thickness affects the local
bond stress distribution and strength, also monitor it using process checks. Assembly jigs and procedures
can provide pre-bond gap assessment. Processing aids (for example, verafilm) assess the tight tolerances
needed for some bonding processes. Handling requirements and procedures exist to control the film
adhesive lay-up process. The mixing and application of paste adhesive require additional processing steps
and controls. The mixing ratios of paste adhesive constituents and filler content are controlled and
monitored. Tight controls also help determine the completeness of the mixing process. Depending on the
51
Page 52 of 123
type of paste adhesive used, implement bond assembly time constraints from adhesive mix to mated
surface contact. Monitor and maintain tolerances of assembly jigs over time.
Control the cure of bonded structures to ensure that the adhesive properly wets the substrate surfaces and
dwells at temperatures needed in fully developing the properties for intended applications, without
overheating. As discussed previously, the scaling issues associated with bonding large-scale airframe
structures are complex. Heat transfer, bond surface contact pressure, and adhesive characteristics during
different stages of the cure cycle all combine to affect the final state of the bond at local points throughout
the structure. Typically apply manufacturing trials for new combinations of parts, tooling, and
equipment. Establish tolerances and implement in-process controls to locally manage the bond cure cycle
and avoid overheating. Cure tooling and the equipment used to apply temperature to structures during
bonding is controlled and maintained. Validate and regularly calibrate procedures used for in-process
control.
Use of continuous training for factory technicians and quality personnel involved in various bond process
steps in specific areas of responsibility. Identify adhesion failures found during bond qualification,
factory production or field repairs involving bonding and correct the associated root cause. Keep records
on material usage, process steps, and quality checks applied to each bonded structure. Experience has
shown that factory or service problems associated with weak bonds or de-bonding traced to specific
material batches or manufacturing mistakes can be minimized even if related parts have reached service.
Likely Future Advances
Manufacturing quality management is important to many aspects of bonding. Use a combination of both
strict in-process controls and post-bond inspections. Currently, the NDI of bonded structure provides
necessary, but not sufficient, evidence of proper bonding. There is always hope that technology
advancements will yield reliable NDI measurements of the final bond strength but that hope has existed
since the 1960s and most progress has come in destructive test methods applied locally to produce local
failures, which are detectable with conventional NDI, after applying high energy pulses to understrength
bonds. Looking towards the future, the most promising NDI techniques are using oblique angle
ultrasound or guided wave propagation over a range of frequencies with amplitudes or velocities that are
sensitive to the onset of weak or understrength bonds. Witness panel tests consider the combined effect of
several process steps but for a simplified geometry. As a result, other post-process quality measures and
controls can provide supplemental checks on the real structure but in order to avoid the manufacturing
defects of primary concern, stringent in-process controls are most effective.
Secondary Defect Considerations
Current NDI methods, such as ultrasonic methods, can locate areas of de-bonding, porosity and foreign
inclusions (for example, significant pieces of peel ply or backing paper left in the bond line) but are
unable to reliably detect defective bonds resulting from contamination or incorrect materials or
processing. Small fragments of peel ply left on a bonding surface, may generally not be detectable by
current factory NDI methods and depending on the size of affected areas, potentially leading to
understrength composite bonds.
Most small manufacturing defects detected by current factory NDI are generally not a problem because
they will not grow and, with supporting data, controlled through conservative factory or repair
manufacturing defect dispositions. As a result, they often do not become important for damage tolerance
52
Page 53 of 123
substantiation. Nevertheless, they still require analysis and test substantiation. For example, allowable
defect limits are defined for small de-bonds, porosity and relatively small foreign inclusions in PSE This
may require considerable empirical data generated to ensure that the defect won’t grow to demonstrate
Ultimate strength will not be lost for the life of the bonded structure. As discussed above, minimize the
primary defect conditions of weak or understrength bonds resulting from contamination, inappropriate
material substitutions or incorrect bond processes through in-process checks. Apply proven in-process
controls to surface preparation, adhesive mixing, bond assembly and cure.
Design and Structural Substantiation
Most bonded joints and attachments generally have the primary purpose to transfer shear loads. Local
peel forces are also present in a bond stress distribution, but typically controlled using structural details
designed to minimize such stress. The stress distribution and strength of a bonded joint or attachment
relates to the substrate geometry (for example, thickness, taper angles), bondline thickness bond overlap
length and, if using composite substrates, laminate lay-up or fiber architecture. Residual stresses can be
an important design consideration, depending on the directional differences in thermal expansion and
stiffness of substrate materials. Any bond between metal and composite substrate will typically yield the
largest residual stresses. Many bonded joints and attachments are designed to be fail-safe (see the
subsection entitled Structural Redundancy for additional discussions). Achieve alternate load paths by
using fasteners or additional splices attached in a second bonding operation. Due to the mechanisms of
joints with bonded and bolted features, design the joint or attachment capability assuming only the bond
or bolts over any given segment of the joint are transferring loads. The bond will dominate load carrying
until failure and needs Ultimate load capability, while the bolts typically meet the failsafe condition of
Limit load capability with a failed bond.
An integrated product team (IPT) helps address important manufacturing, tooling, and maintenance
considerations for bonded joint design. One related IPT goal is to design structural detail reliably
produced in the factory to meet the performance requirements, while minimizing manufacturing defects.
Similarly, the IPT needs to recognize the maintenance implications of future inspection and repair
activities for bonded structural details, which do not allow easy disassembly.
Analysis methods used by the industry to design bonded joints and attachments range from crude models
for preliminary design to simple two-dimensional analyses added to software-based tools, which include
more refined structural definition. Crude models, which convert shear flow and other loads to an average
shear stress, usually calculate bonded joint capability using very conservative design values. Despite the
inherent conservatism, such an approach requires considerable testing of specific design detail in
structural substantiation or overload factors that conservatively cover bonded joint reliability.
Both simple analyses and software-based tools predict local shear and peel stress distributions, which help
design joint parameters for optimal performance. Some models include nonlinear elastic and plastic
adhesive behavior for further joint optimization. Design sufficient bond overlap length to ensure plastic
deformation occurs without a risk to bond integrity or damage accumulation. Design criteria and
guidelines often ensure constraints that minimize bonded joint data needs. In one guideline, design the
overlap length to carry all loads by adhesive plastic deformation, with sufficient elastic trough away from
the joint ends to provide creep resistance. Software models of adhesive joint geometry and load
conditions allow further design refinement (for example, analysis of joggles).
53
Page 54 of 123
Use design criteria & objectives, analyses, and test data for timely disposition of manufacturing defects
and service damage found in the factory and field, respectively. Sophisticated analysis methods used to
predict the effects of bond defects and damage scenarios continue to evolve; however, most applications
to date depend on test data. This is particularly true when considering damage as complex as that caused
by foreign object impact.
The design of bonded repairs uses many of the same design procedures and analysis tools applied to
bonded joints and attachments. A typical bonded repair considers the patch geometry, scarf angle, and
bond-line thickness. Residual stresses resulting from a difference in the laminate lay-up, stiffness, and
thermal expansion properties between the bonded patch and base part also need consideration in repair
design and analysis. The associated placement tolerances for repair patches may require some attention to
avoid conservative assumptions of related stress concentrations.
As discussed in AC 20-107B (Ref. 5), the overall approach applied for composite structural substantiation
dictates design data development. The same philosophy applies for bonded structures. Some benefits are
possible using a building block approach with refined analyses and test correlations for structural details,
which range in size and assembly completeness (coupons, elements, subcomponents and components).
Alternative approaches, based on crude analyses and a conservative demonstration of strength at the large
scale, typically have more constraint. There is more freedom to expand beyond the specific structural
details, damages, defects, and repairs addressed in large-scale tests if there is a more refined correlation
between the analysis and tests, within the allowances of design criteria and other constraints within the
building block approach.
Design data development includes characterization for minimum and maximum service temperatures, as
well as the moisture content possible after years in service, typically established as conservative design
criteria. A threat assessment of service damage should define the full scope of structural tests and
analyses. The materials, conditions, and processes used for repair in the factory and field often differ and
need substantiation within the building block approach. Train technicians involved in bonded joint testing
to identify adhesion failures. Consider any adhesion failures noted through the course of structural
substantiation unacceptable and identify the source before proceeding to additional tests and analyses.
Address the long-term durability of bonded joints by understanding degradation mechanisms and tracking
long-term performance. As discussed in previous sections, bond process qualifications usually initiate
these efforts using accelerated test procedures that conservatively force an assessment of the chemical
bonding. Correlations between accelerated tests and actual long-term performance will ensure sufficient
conservatism. This is also true in evaluating the long-term environmental exposure to temperature,
moisture and other fluids found in service by substantiating accelerated testing known to be more severe
in the short-term. Element and subcomponent tests provide further proof of acceptable bonding processes
applied at larger structural scales.
Final substantiation of static strength, fatigue, and damage tolerance relies on large-scale test components
or tests that contain full-scale details manufactured using production processes. Careful attention to test
boundary conditions and attachments will yield representative results. Building block analyses and tests
support design value determination for most of the effects of structural details, damage, defects and repair,
again with careful attention to proper simulation of structural behavior. However, large-scale tests
provide final overall proof of the design and manufacturing characteristics of configured structures, which
include bonded joints, cutouts, damage, repairs and combined loads. This includes validation of load path
predictions and final strength assessments, based on structural detail design values. For example,
54
Page 55 of 123
integrally bonded airframes may have secondary load paths and complex failure modes that are difficult
to predict, without careful consideration of manufacturing tolerances and load redistribution following
individual failures.
Practical consideration of moisture and temperature property degradation in large-scale tests often uses
overload factors derived from smaller scale tests. One issue that is difficult to address directly in large-
scale tests is the completed cure of the adhesive and the availability of related peak moisture and
temperature-dependent properties at the structural level. In addition to the process controls measuring
thermal profiles to ensure sufficient temperature conditions for the required cure cycle during fabrication,
some laboratory testing of samples cut from the bonded structure can provide the necessary substantiation
of manufacturing processes.
55
Page 56 of 123
7.2 Appendix 2: Quality control plan for composite bonding in

OEM
Several TAMCSWG members provided presentations on example quality control plans for composite
bonding. The following includes the material shared by WG members (Bombardier, Dassault, Airbus,
Textron) and invited participant (Fokker).
56
Page 57 of 123
Figure A2.1 (sheet 1 of 3): Bombardier presentation to TAMCSWG on structural bonding
57
Page 58 of 123
58
Page 59 of 123
59
Page 60 of 123
Figure A2.2 (sheet 1 of 3): Dassault presentation to TAMCSWG on structural bonding
60
Page 61 of 123
61
Page 62 of 123
62
Page 63 of 123
Figure A2.3 (sheet 1 of 5): Airbus presentation to TAMCSWG on structural bonding
63
Page 64 of 123
64
Page 65 of 123
65
Page 66 of 123
66
Page 67 of 123
67
Page 68 of 123
Figure A2.4 (sheet 1 of 3): Textron presentation to TAMCSWG on structural bonding
68
Page 69 of 123
69
Page 70 of 123
70
Page 71 of 123
Figure A2.5 (sheet 1 of 3): Fokker presentation to TAMCSWG on structural bonding
71
Page 72 of 123
72
Page 73 of 123
73
Page 74 of 123
7.3 Appendix 3: Recommended AC 20-107B Updates

Update over existing guidance is highlighted. Each paragraph proposed to change is followed by the
reasoning for that change. Since there are other aircraft products covered by AC 20-107B, the
TAMCSWG recognizes that the changes below may need to be generalized to allow differing “best
practices” for small airplanes, rotorcraft and even smaller transport business jets such as those members
who may elect to follow the current bonded structural expectations of AC 20-107B as stated in 6C(3)(a),
while further advancing bond material and process controls to ensure bond integrity and durability. The
use of DTDC as explained in Section 4.2.4.1 of this report provides such a generalization, even for SLP
structures that may need to lower stress levels to an extent that larger detectable disbonds would be found
before failure. For example, rotor blades have an SLP bond that is damage tolerant and typically follows
a slow growth curve that is typically self-inspecting when active via blade vibrational characteristics.
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. Certain inspection methods may not be adequate for particular damage states such as using
general visual to find disbonds in bonded structure. 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, disbonding, possibly between arresting features,
other detectable delamination or disbonds, 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.
Reason for change:
The guidance material is clear in regards to the necessity of a residual strength check with a failed
bondline between arresting features. By adding this material to the Category 2 definition it is asking for
this damage state to be treated like other category 2 damage. This necessitates an inspection to look for
the damage state to ensure that the disbond is found and the airplane does not remain under regulatory
load requirements for its remaining life. See AC 20-107B figure in Appendix 3. It is not a desired state to
remain below ultimate load for an extended period of time. Also added to this paragraph is a
recommendation stating that GVI is considered inadequate to visually detect bondline failures between
arrestment. Detail inspection is recommended to find bondline cracks at a bonded flange edge.
74
Page 75 of 123
6C 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. The bonding system typically consists of the substrate, adhesive,
surface preparation and the qualified bonding process. The bonding system must validate the system
performance throughout the material and process window. Characterization outside the process limits is
recommended to ensure process robustness. Reassessment of the bonding system must occur when
changes happen that may affect the performance of the system constituents. A qualified bonding process
is documented after demonstrating repeatable and reliable processing steps . 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. All metal interfaces in a bonded structure also have
chemically activated surfaces created by a qualified preparation process. Many technical issues for
bonding require cross-functional teams for successful applications. Applications require stringent process
control and a thorough substantiation of structural integrity. Even with this in place, bonding in single
load path structure may not practically be used without further considerations.
Reason for change:
Add treating bonding as a system and any change in the system must be investigated (prep, adhesive,
adherents, bond process) and tested within the process envelope. This is a lesson learned by the OEMs
and has been communicated in CMH-17, CACRC and other forums. It will be a part of several chapter
updates in CMH-17 Volume 3, revision H release as well.
Also added recommendation to only use bonding in single load path structure, where failure of the bond
would result in the airframe’s capability to maintain regulatory load levels (limit loads), when adopting
additional design, maintenance or other considerations that mitigate associated safety risks.
75
Page 76 of 123
6C (3) Previous to Amendment level 64, 14 CFR §23.573(a) set forth requirements for
substantiating the critical composite airframe structures, including considerations for
damage tolerance, fatigue, and bonded joints. These performance standards are
expected with Part 23 general aviation, large transport and rotorcraft category aircraft
(typically via special conditions and issue papers). Industry guidelines such as provided
in Reference 2 indicate that the design of bonded structures should meet the redundant
structural expectations identified below.
(a) For any factory or in-service bonded joint including repair: "the failure of which
would result in catastrophic loss of the airplane, 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 test or analysis supported by test. 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 that further helps ensure bond
environmental durability. 6(a) “Material and Process Control” and 6(b)
“Manufacturing Implementation” shown above should be adhered to. 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). Following
this rigorous approach allows the consideration of a single bond failure on a bond
assembly to ensure adequate safety. Performing static proof tests to limit load, which is
the second option, has shown not to reliably 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.
Reason for change:
o Needed an update for the old §23.573 reference

o Changed the first sentence in paragraph 6(C)(3)(a) “For any factory or in-service bonded
joint including repair” at the request of the airlines to emphasize that bonded repair, in-
service or factory installed, should satisfy limit load residual strength with a failure; the
76
Page 77 of 123
same as a factory production bond. This was discussed relative to an update to the BRSL
policy to affect the same change.
o Add a link to paragraph 6 to emphasize quality and state that assumption of single disbond
between arrestment is only allowed due to strict adherence to stringent process control
requirements, which further helps to ensure bond environmental durability.
o Clarified the drawbacks to proof loading and its inability to detect weak bonds.
Para 10. Continued Airworthiness

Sentences related to Repair substantiation are highlighted. Only 10(c) and paragraph 6(c)(3)(a) has
proposed changes.
b. Maintenance Practices.
(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 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.
c. Substantiation of Repair.
(1) When repair procedures are provided in FAA-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 AC. 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) including bonded repair size limits for critical structure.
Add to par 6.c: (see above for addition, reworded to fit existing paragraph): In-factory and in-service
repairs must be capable of limit load with a failed repair, and have the option of adding arrestment
features.
(2) Operators and maintenance repair organizations (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 to support any
subsequent maintenance activities.
77
Page 78 of 123
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.
Reason for change:
10(c) was updated to emphasize that when stating “Bonded repair is subjected to the same structural
bonding considerations as the base design” that also meant that they must meet limit load with a failed
bond between arrestment, as stated in bonded repair size limits (BRSL) policy
78
Page 79 of 123
7.4 Appendix 4: Recommended AC25.571-1D Updates

Note: The following updates are not intended to supersede any existing recommendations in reference 7,
rather to supplement those already suggested. The updates are shown with red revision bars in left hand
margin.
Advisory
Circular
Subject: Damage Tolerance Date: 1/13/2011 AC No: 25.571-1D

Initiated By: ANM-115
and Fatigue Evaluation of Structure
1. Purpose.
a. This advisory circular (AC) provides guidance for compliance with the provisions of Title 14,
Code of Federal Regulations (14 CFR) part 25, pertaining to the requirements for damage-
tolerance and fatigue evaluation of transport category aircraft structure, including evaluation of
widespread fatigue damage (WFD) and establishing a limit of validity of the engineering data
that supports the structural-maintenance program (hereafter referred to as the LOV). This AC
also includes guidance pertaining to discrete source damage and metal bonding.
b. The following appendices appear at the end of this AC:
● Appendix 1 – References and Definitions
● Appendix 2 – Full-Scale Fatigue Testing
● Appendix 3 – Process for Compliance with 14 CFR 25.571(a), (b) and (c) for Fatigue Damage
79
Page 80 of 123
● Appendix 4 – Examples of Alterations that May Require Full-Scale Fatigue Testing
● Appendix 5 – PSE, FCS and WFD-Susceptible Structure
● Appendix 6 – Acronyms and Abbreviations Used in this AC
2. Applicability.
a. The guidance provided in this document is directed to airplane manufacturers, modifiers, foreign
civil-aviation authorities, and Federal Aviation Administration (FAA) transport airplane type
certification engineers and designees.
b. This material is neither mandatory nor regulatory in nature and does not constitute a regulation.
It describes acceptable means, but not the only means, for demonstrating compliance with the
applicable regulations. The FAA will consider other methods of demonstrating compliance that
an applicant may elect to present. While these guidelines are not mandatory, they are derived
from extensive FAA and industry experience in determining compliance with the relevant
regulations. On the other hand, if the FAA becomes aware of circumstances that convince us that
following this AC would not result in compliance with the applicable regulations, we will not be
bound by the terms of this AC, and we may require additional substantiation or design changes as
a basis for finding compliance.
c. This material does not change, create additional, authorize changes in, or permit deviation from
regulatory requirements.
3. Cancellation. AC 25.571-1C, dated April 29, 1998, is canceled.
4. Background.
a. Since the early 1970s, there have been significant developments in the state-of-the-art and
industry-practice in the area of structural-fatigue and fail-safe strength evaluation of transport
category airplanes. Recognizing that these developments could warrant some revision of the
existing fatigue requirements of §§ 25.571 and 25.573, on November 18, 1976 (41 FR 50956),
the FAA gave notice of the Transport Category Airplane Fatigue Regulatory Review Program,
inviting interested persons to submit proposals to amend those requirements. The proposals and
related discussions formed the basis for the revision of the structural-fatigue-evaluation standards
of §§ 25.571 and 25.573, and the development of guidance material. To that end, § 25.571 was
revised, § 25.573 was deleted (the scope of § 25.571 was expanded to cover the substance of the
deleted section), and guidance material (AC 25.571-1) was prepared.
b. After issuance of AC 25.571-1 on September 28, 1978, additional guidance material, including
guidance on discrete source damage, was developed and incorporated in revision 1A, issued on
March 5, 1986. The AC was further revised on February 18, 1997; revision 1B added guidance
on the elements to be considered in developing scatter factors for certification. Revision 1C of
the AC was issued April 29, 1998, to add guidance pertaining to precluding widespread fatigue
damage within the design service goal of the airplane and determining thresholds for fatigue
80
Page 81 of 123
inspection. This revision removes guidance material for precluding WFD up to the design
service goal and replaces it with guidance material for precluding WFD up to the LOV.
5. Introduction.
a. General. The FAA considers the contents of this AC in determining compliance with the
damage-tolerance, fatigue, and discrete source damage requirements of § 25.571.
(1) The requirements of § 25.571 apply equally to metallic and composite structure. The focus
of this AC is metallic structure. Refer to AC 20-107B for guidance on composite structure
and further guidance on the material and process control of metal bonding .
(2) Section 25.571 requires applicants to evaluate all structure that could contribute to
catastrophic failure of the airplane with respect to its susceptibility to fatigue,
environmental, and accidental damage. The applicant must establish inspections or other
procedures (herein also referred to as maintenance actions) as necessary to avoid catastrophic
failure during the operational life of the airplane based on the results of these evaluations.
Section 25.571 also requires the applicant to establish an LOV. The LOV, in effect, is the
operational life of the airplane consistent with evaluations accomplished and maintenance
actions established to prevent WFD. Although the LOV is established based on WFD
considerations, it is intended that all maintenance actions required to address fatigue,
environmental, and accidental damage up to the LOV are identified in the structural-
maintenance program. All inspections and other procedures (e.g., modification times,
replacement times) that are necessary to prevent a catastrophic failure due to fatigue, up to
the LOV, must be included in the Airworthiness Limitations section (ALS) of the Instructions
for Continued Airworthiness (ICA), as required by § 25.1529, along with the LOV.
(3) Although a uniform approach to the evaluation required by § 25.571 is desirable, the FAA
recognizes that, in such a complex field, new design features and methods of fabrication, new
approaches to the evaluation, and new configurations could necessitate variations and
deviations from the procedures described in this AC.
(4) Compliance with § 25.571(b), Damage-tolerance evaluation, is not required if the applicant
establishes that it is impracticable to apply the regulation to particular structure. An example
of structure that may not be conducive to damage-tolerant design is the landing gear and its
attachments. In this case, the applicant may comply instead with § 25.571(c), Fatigue (safe-
life) evaluation. The FAA does not allow exclusive reliance on damage-tolerance-based
inspections for structure susceptible to WFD. The applicant must demonstrate that WFD is
unlikely to occur prior to the LOV for the airplane. An applicant may use damage-tolerance-
based inspections for multiple site damage (MSD)/multiple element damage (MED) to
supplement replacement or modification required to preclude WFD when shown to be
practical.
(5) The applicant should perform damage-growth and residual-strength testing to produce the
design data needed to support damage-growth and residual-strength analyses. Full-scale
fatigue-test evidence is required to support the evaluation of structure that is susceptible to
81
Page 82 of 123
WFD. Test evidence is needed to support analysis used to establish safe-life replacement
times.
(6) Replacement times, inspections, or other procedures to address fatigue cracking and
disbonding in metal bonded details must be established as necessary. These actions must be
based on quantitative evaluations of the fatigue characteristics of the structure. In general,
analysis supported by test evidence will be necessary to generate the information needed;
service experience may also be used. The applicant should identify the intended approach in
a compliance plan. All inspections, modification times, replacement times, and LOVs that
are necessary to prevent a catastrophic failure – based on the damage-tolerance, fatigue, and
WFD evaluations – must be included in the ALS of the ICA as required by § 25.1529.
(7) The applicant must establish inspections or other procedures for environmental damage and
accidental damage as necessary to prevent catastrophic failure. Guidance for establishing
environmental damage and accidental damage maintenance actions is included in section 6 of
this AC.
b. Typical loading spectrum expected in service. The loading spectrum used for damage-
growth and fatigue- damage-initiation assessments (tests or analyses) should be based on
measured statistical data of the type derived from government and industry load-history studies
and, where data is insufficient or unavailable, on a conservative estimate of the anticipated use of
the airplane. The principal loads that should be considered in establishing a loading spectrum are
flight loads (gust and maneuver), ground loads (taxiing, landing impact, turning, engine run-up,
braking, thrust reversing, and towing), and pressurization loads. The development of the loading
spectrum includes the definition of the expected flight plan, which involves climb, cruise,
descent, flight times, operational speeds and altitudes, and the approximate time to be spent in
each of the operating regimes. Operations for crew training and other pertinent factors, such as
the dynamic stress characteristics of any flexible structure excited by turbulence or buffeting,
should also be considered. For pressurized cabins, the loading spectrum should include the
repeated application of the normal operating differential pressure, and the superimposed effects
of flight loads and external aerodynamic pressures.
c. Structure to be evaluated. When assessing the possibility of fatigue failures, the applicant
should examine the design to determine probable points of failure in service. In this
examination, consideration should be given, as necessary, to (1) the results of stress analyses,
static tests, fatigue tests, strain-gauge surveys, and tests of similar structural configurations and
(2) service experience. Service experience has shown that special attention should be focused on
the design details of important discontinuities, attachment fittings, tension joints, splices, bonded
joints and cutouts such as windows, doors, and other openings. Locations prone to accidental
damage (such as that due to impact with ground servicing equipment near airplane doors) or to
environmental damage should also be considered.
d. Analyses and tests. Repeated load analyses or tests should be conducted on structures
representative of components or subcomponents of the wing, control surfaces, empennage,
fuselage, landing gear, and their related primary attachments. Analyses and tests need not be
conducted if it is determined from the foregoing examination that the normal operating stresses
in specific regions of the structure are of such a low order that significant damage growth is
extremely improbable. Test articles should include structure representative of attachment
82
Page 83 of 123
fittings, tension joints, splices, changes in section, cutouts, and discontinuities. Any method used
in the analyses should be supported, as necessary, by test or service experience. Typical
(average) values of material properties that account for the quantifiable effects of environment
and other parameters may be used in residual-strength, crack-growth, and damage-detection
analyses for damage-tolerance assessments and for discrete source damage. These are described,
respectively, in sections 6 and 9 of this AC.
6. Damage-Tolerance Evaluation.
a. General. The damage-tolerance evaluation of structure is intended to ensure that—should

fatigue, environmental, or accidental damage occur within the LOV of the airplane—the
remaining structure can withstand reasonable loads without failure or excessive structural
deformation until the damage is detected. The damage-tolerance evaluation should include the
following:
● identification of the structure to be evaluated,
● definition of the loading conditions and extent of damage,
● structural tests or analyses, or both, to substantiate that the design objective has been achieved,
and
● generation of supporting data for inspection programs to ensure detection of damage.
Although this evaluation applies to either single- or multiple-load-path structure, the use of
multiple load path structure should be given high priority in achieving a damage-tolerant design.
Design features that should be considered in attaining a damage-tolerant structure include the
following:
(1) Multiple load path construction, and the use of crack stoppers to control the rate of crack
growth and to provide adequate residual strength;
(2) Materials and stress levels that, after initiation of cracks provide a controlled slow rate of
crack propagation combined with high residual strength;
(3) Arrangement of design details to ensure a high probability that a failure in any critical
structural element will be detected before the strength of the element has been reduced below
the level necessary to withstand the loading conditions specified in § 25.571(b), thereby
allowing timely replacement or repair of the failed elements.
(4) Using disbond arrestment for metal bond joints as described in paragraph 6c(3) of AC20-
107B and focusing on achieving high material and process reliability as stated in paragraphs
6c(2) and 6c(4) of AC20-107B.
b. Damage-Tolerance Assessment Methodologies. Normally, the damage-tolerance assessment

consists of a deterministic evaluation of the design features described in this section. Sections 6c
through 6j below provide guidelines for this approach. In certain specific instances, however,
damage-tolerant design might be more realistically assessed by a probabilistic evaluation,
83
Page 84 of 123
employing methods such as risk analysis. Risk analyses are routinely employed in fail-safe
evaluations of airplane systems and have occasionally been used where structure and systems are
interrelated. These methods can be of particular value for structure consisting of discrete
elements, where damage tolerance depends on the ability of the structure to sustain redistributed
loads after failures resulting from fatigue, environmental, or accidental damage. Where
considered appropriate on multiple load path structure, a probabilistic analysis may be used if it
can be shown that (1) loss of the airplane is extremely improbable, and (2) the statistical data
employed in the analysis of similar structure is based on tests or operational experience, or both.
c. Identification of principal structural elements. As defined in this AC, a principal structural

element is an element of structure that contributes significantly to the carrying of flight, ground,
or pressurization loads and whose integrity is essential in maintaining the overall structural
integrity of the airplane. Principal structural elements include all structure susceptible to fatigue
damage, which could contribute to a catastrophic failure. Refer to appendix 5 of this AC for
clarification on how this term relates to the terms, fatigue critical structure (FCS) and WFD –
susceptible structure. Examples of such elements are as follows:
(1) Wing and empennage.
(a) Control surfaces, slats, flaps, and their mechanical systems and attachments (hinges,
tracks, and fittings);
(b) Integrally stiffened plates;
(c) Primary fittings;
(d) Principal splices;
(e) Skin or reinforcement around cutouts or discontinuities;
(f) Skin-stringer combinations;
(g) Spar caps; and
(h) Spar webs.
(2) Fuselage.
(a) Circumferential frames and adjacent skin;
(b) Door frames;
(c) Pilot-window posts;
(d) Pressure bulkheads;
(e) Skin and any single frame or stiffener element around a cutout;
(f) Skin or skin splices, or both, under circumferential loads;
84
Page 85 of 123
(g) Skin or skin splices, or both, under fore and aft loads;
(h) Skin around a cutout;
(i) Skin and stiffener combinations under fore and aft loads;
(j) Door skins, frames, and latches; and
(k) Window frames.
(3) Landing gear and their attachments.
(4) Engine mounts.
d. Extent of damage. Each particular design should be assessed to establish appropriate damage
criteria in relation to inspectability and damage-extension characteristics. In any damage
determination, including those involving multiple damage, it is possible to establish the extent
of damage in terms of the following parameters:
● detectability with the inspection techniques to be used,
● the associated, initially detectable damage size,
● the residual-strength capabilities of the structure, and
● the likely damage-extension rate.
This determination should consider the expected stress redistribution under the repeated loads
expected in service at the expected inspection frequency. Thus, an obvious partial failure could
be the extent of the damage for residual-strength assessment, provided that the fatigue cracks or
disbonds will be detectable at a sufficiently early stage of development. The following are
examples of partial failures that should be considered in the evaluation:
(1) Detectable skin cracks emanating from the edge of structural openings or cutouts;
(2) A detectable circumferential or longitudinal skin crack in the basic fuselage structure;
(3) Complete severance of interior frame elements or stiffeners in addition to a detectable crack
in the adjacent skin;
(4) A detectable failure of one element of components in which dual construction is used, such as
spar caps, window posts, window or door frames, and skin structure;
(5) A detectable fatigue failure in at least the tension portion of the spar web or similar element;
and
(6) The detectable failure of a primary attachment, including a control surface hinge and fitting.
(7) A detectable disbond of a stiffener or tear strap between arrestment features.
85
Page 86 of 123
e. Inaccessible areas. Every reasonable effort should be made to ensure inspectability of all
structural parts and to qualify those parts under the damage-tolerance provisions (see § 25.611).
f. Testing of principal structural elements. The nature and extent of residual-strength tests on
complete structures or on portions of the primary structure depends upon applicable previous
design, construction, tests, and service experience with similar structures. Simulated cracks
should be as representative as possible of actual fatigue damage. Where it is not practical to
produce actual fatigue cracks, damage can be simulated by cuts made with a fine saw, sharp
blade, guillotine, or other suitable means. If saw cuts in primary structure are used to simulate
sharp fatigue cracks, sufficient evidence should be available from element tests to indicate
equivalent residual strength. In those cases where bolt failure or its equivalent is to be simulated
as part of a possible damage configuration in joints or fittings, bolts can be removed to provide
that part of the simulation.
g. Identification of locations to be evaluated. The locations of damage to structure for damage-

tolerance evaluation should be identified as follows:
(1) Determination of general damage locations. The evaluation would include a determination of
the probable locations and modes of damage due to fatigue, environmental, or accidental
damage. Repeated load and static analyses, supported by test evidence and (if available)
service experience, would also be incorporated in the evaluation. Special consideration for
widespread fatigue damage must be included where the design is such that this type of
damage could occur. The location and modes of damage can be determined by analysis or
service experience, or by fatigue tests on complete structures or subcomponents. However,
tests may be necessary when the basis for analytical prediction is not reliable, such as for
complex components. If less than the complete structure is tested, ensure that the internal
loads and boundary conditions are valid.
(a) If a determination is made by analysis, take into account factors such as the following:
1 Strain data on undamaged structure to establish points of high-stress concentration as

well as the magnitude of the concentration;
2 Locations where permanent deformation occurred in static tests;
3 Locations of potential fatigue damage identified by fatigue analysis; and
4 Design details that service experience, of similarly designed components, indicates

are prone to fatigue or other damage.
(b) In addition, the areas of probable damage from other sources, such as severe
environmental or accidental damage, should be determined from a review of the design
and past service experience.
(2) Selection of critical damage areas. The process of actually locating where damage should be
simulated in principal structural elements (identified in section 6d of this AC) should take
into account factors such as the following:
86
Page 87 of 123
(a) Review analysis to locate areas of maximum stress and low margin of safety;
(b) Select locations in an element where the stresses in adjacent elements would be the
maximum with the damage present;
(c) Select partial-fracture locations in an element where high stress concentrations are
present in the residual structure; and
(d) Select locations where detection would be difficult.
h. Damage-tolerance analysis and tests.
(1) Analysis, supported by test evidence, should determine that:
(a) The structure with the extent of damage established for residual-strength evaluation can
withstand the specified design-limit loads (considered as ultimate loads); and
(b) The damage-growth rate under the repeated loads expected in service – between the time
the damage becomes initially detectable and the time the extent of damage reaches the
value for residual-strength evaluation – provides a practical basis for development of the
inspection program and procedures described in section 6j of this AC.
(2) The repeated loads should be as defined in the loading, temperature, and humidity spectra
while considering environmental effects caused from hydraulic fluids, fuels, cleaners and
other detrimental materials found in operations, particularly when bonded structure is used to
react metallic crack growth. The loading conditions should take into account the effects of
structural flexibility and rate of loading where they are significant.
(3) The damage-tolerance characteristics can be shown analytically by reliable or conservative

methods, such as the following:
(a) Demonstrating quantitative relationships with structure already verified as damage

tolerant;
(b) Demonstrating that the damage would be detected before it reaches the value for
residual-strength evaluation; or
(c) Demonstrating that the repeated loads and limit-load stresses do not exceed those of
previously verified designs of similar configuration, materials, and inspectability.
(4) The maximum extent of immediately obvious damage from discrete sources should be
determined, and the remaining structure shown to have static strength for the maximum load
(considered as ultimate load) expected during the remainder of the flight. Normally, this
would be an analytical assessment. In the case of uncontained engine failure, the fragments
and paths to be considered should be consistent with those used in showing compliance with
§ 25.903(d)(1) and with typical damage experienced in service. (See AC 20-128, “Design
Considerations for Minimizing Hazards Caused by Uncontained Turbine Engine and
Auxiliary Power Unit Rotor and Fan Blade Failures.”)
87
Page 88 of 123
i. Inspection.
(1) Detection of damage before it becomes critical is the ultimate control in ensuring the damage-
tolerance characteristics of the structure. For this reason, Amendment 25-54 revised § 25.571
to require that the applicant (1) establish inspections or other procedures, as necessary, to
prevent catastrophic failure from accidental, environmental, or fatigue damage, and (2)
include those inspections and procedures in the ALS of the ICA, as required by § 25.1529
(see also appendix H to part 25).
(2) Due to the complex interactions of the many parameters affecting damage tolerance – such as
operating practices, environmental effects, load sequence on damage growth, and
variations in inspection methods – take into account related operational experience in
establishing inspection procedures. Additionally, give careful consideration to the practical
nature of inspection procedures.
(3) Comparison with past successful practice is the primary means of substantiating inspections
or other procedures for accidental and environmental damage. For a new-model transport
category airplane, the Maintenance Review Board generally conducts such comparison to
substantiate inspections or other actions using the Air Transport Association of America, Inc.
(ATA) Maintenance Steering Group’s MSG-3 or other accepted version of the
“Operator/Manufacturer Scheduled Maintenance Development” procedures. If this process is
used, the required maintenance actions for accidental and environmental damage must be
documented in the Maintenance Review Board Report for the airplane model and must be
complete not later than when the first airplane enters service. These inspections or other
procedures, as necessary to prevent catastrophic failure of the airplane, must be included in
the Airworthiness Limitations section of the ICA. Alternatively, the applicant may reference,
in the ALS of the ICA, the maintenance documents that contain those tasks. The ALS should
also contain reference to any corrosion prevention and control program (CPCP) developed to
maintain corrosion to “Level 1” or better for that airplane model. “Level 1” corrosion is
damage occurring between successive inspections that is local and can be reworked/blended-
out within allowable limits as defined by the manufacturer’s service information, such as
structural-repair manuals and service bulletins.
(4) In some cases, the experience of an operator may indicate that different inspections or other
procedures are appropriate for that operator. Title 14 CFR 43.16 and 14 CFR 91.403(c)
provide a means for FAA approval of alternatives to the airworthiness limitations. The FAA
will evaluate such proposed alternatives, using the methods described in this AC or other
acceptable methods proposed by the type-certificate holder and operators, to ensure that the
objectives of 14 CFR 25.571 continue to be met.
j. Threshold for Inspections.
(1) Where it can be shown by observation, analysis, and/or test that a load path failure in multiple
load path “fail-safe” structure or partial failure in damage-arrest “fail-safe” structure will
be detected and repaired during normal maintenance, inspection, or operation of an airplane
prior to failure of the remaining structure, the thresholds can be established using either:
(a) Fatigue analysis and tests with an appropriate scatter factor; or
88
Page 89 of 123
(b) Slow- damage-growth analyses and tests, based on appropriate initial manufacturing
damage.
(2) For single load path structure and for multiple load path and damage-arrest “fail-safe”
structure – where it cannot be demonstrated that load-path failure, partial failure, or
damage arrest will be detected and repaired during the normal maintenance, inspection, or
operation of an airplane prior to failure of the remaining structure – the thresholds should be
established based on damage-growth analyses and/or tests, assuming the structure contains
an initial flaw of the maximum probable size that could exist as a result of manufacturing- or
service-induced damage.
7. Establishing an LOV.
a. Structural-maintenance program.
(1) If an airplane is properly maintained, theoretically it could be operated indefinitely.

However, it should be noted that structural-maintenance tasks for an airplane are not constant
with time. Tasks typically are added to the maintenance program as the airplane ages. It is
reasonable to expect, then, that confidence in the effectiveness of current structural-
maintenance tasks may not, at some future point, be sufficient for continued operation.
Maintenance tasks for a particular airplane can only be determined based on what is known
about that airplane model at any given time; from analyses, tests, service experience, and
teardown inspections. Widespread fatigue damage is of particular concern because
inspection methods cannot be relied on solely to ensure the continued airworthiness of
airplanes indefinitely. To prevent WFD from occurring, the structure occasionally must be
modified or replaced. Establishing all the replacements and modifications required to operate
the airplane indefinitely is an unbounded problem. This problem is solved by establishing
limit of validity of the engineering data that supports the structural-maintenance program.
All necessary modifications and replacements are required to be established to ensure
continued airworthiness relative to WFD up to the LOV. To operate beyond the LOV, the
full-scale fatigue-test evidence and the structural maintenance program must be re-evaluated
to determine if additional modifications or replacements are required. See paragraph 7.g for
the steps to extend the LOV.
b. Widespread Fatigue Damage.
(1) Structural fatigue damage is progressive. It begins as minute cracks, and those cracks grow
under repeated stresses. It can initiate as a result of normal operational conditions and design
attributes, or from isolated incidents, such as material defects, poor fabrication quality, or
corrosion pits, dings, or scratches. Fatigue damage can occur locally, in small areas or
structural design details, or globally. Global fatigue damage is a general degradation of large
areas of structure that share similar structural details and stress levels. Global damage may
occur in a large structural element, such as a single rivet line of a lap splice joining two large
skin panels (multiple site damage). Such damage may be affected by multiple stringer
disbonds or rare weak bonds in a panel that is using bonded structure to enhance fatigue
performance.
89
Page 90 of 123
Global damage may also be found in multiple elements, such as adjacent frames or stringers
(multiple element damage). Multiple site damage and multiple element damage cracks are
typically too small, initially, to be reliably detected with normal inspection methods. Without
intervention, these cracks will grow, and eventually compromise the structural integrity of the
airplane, in a condition known as widespread fatigue damage. Widespread fatigue damage is
increasingly likely as an airplane ages, and is certain if an airplane is operated long enough
without any intervention. The existence of metal bonded structure that has other aging
mechanisms, including hydration phenomena, which strongly depends on moisture
entrapment, will further complicate such degradation.
c. Steps for Establishing an LOV.
(1) Under § 25.571, persons applying for type certificates (TC) must establish an LOV for each
new type design. For new airplane models, or design changes to existing models that are
added to the TC, the type-certificate holder must either establish an LOV for the new or
design-changed model, or show that the LOV for the originally certificated model can also be
applied to the new or design-changed model. The LOV is the period of time (in flight cycles,
flight hours, or both) up to which it has been demonstrated that widespread fatigue damage is
unlikely to occur in an airplane’s structure by virtue of its inherent design characteristics and
any required maintenance actions. An airplane may not operate beyond the LOV. To
support establishment of the LOV, the applicant must demonstrate, by test evidence and
analysis at a minimum and, if available, service experience, or service experience and
teardown-inspection results of high-time airplanes, that WFD is unlikely to occur in that
airplane up to the LOV. An LOV applies to an airplane structural configuration common to a
fleet.
(2) The process for establishing an LOV involves four steps—
● Identifying a “candidate LOV.”
● Identifying WFD-susceptible structure.
● Performing a WFD evaluation of all susceptible structure.
● Finalizing the LOV and establishing necessary maintenance actions.
(a) Step 1 – Candidate LOV. Any LOV can be valid as long as it has been demonstrated
that the airplane model will be free from WFD up to the LOV based on the airplane’s
inherent fatigue characteristics and any required maintenance actions. Early in the
certification process, applicants typically establish design service goals or their
equivalent and set a design service objective to have structure remain relatively free
from damage, up to the design service goal. A recommended approach sets the
“candidate LOV” equal to the design service goal. The final LOV would depend on
both how well that design objective was met and the applicant’s consideration of the
economic impact of maintenance actions required to preclude WFD up to the final LOV.
(b) Step 2 – Identify WFD-Susceptible Structure. The applicant should identify the
structure that is susceptible to WFD to support post-fatigue-test teardown inspections or
residual-strength testing necessary to demonstrate that WFD will not occur in the
90
Page 91 of 123
airplane structure up to the LOV. Appendix 5 of AC 120-104 provides examples and

illustrations of structure where multiple site damage or multiple element damage has
been documented. The list in appendix 5 is not meant to be inclusive of all structure that
might be susceptible on any given airplane model and it should only be used for general
guidance. It should not be used to exclude any particular structure. The applicant
should do the following when developing the list of structure susceptible to WFD:
1 Establish criteria that could be used for identifying what structure is susceptible to
WFD based on the definitions (see appendix 1) of multiple site damage, multiple
element damage, and WFD. For example, structural details and elements that are
repeated over large areas and operate at the same stress levels are obvious
candidates. The criteria should be part of the applicant’s compliance data.
2 Provide supporting rationale for including and excluding specific structural areas.
This should be part of the applicant’s compliance data.
3 Identify the structure to a level of detail required to support post-test activities that
the applicant will use to evaluate the residual-strength capabilities of the structure.
Structure is free from WFD if the residual strength meets or exceeds that required by
§ 25.571(b). Therefore, the post-test activities, such as teardown inspections and
residual-strength tests, must provide data that support the determination of strength.
● For teardown inspections, specific structural details (e.g., holes, radii, fillets,
cutouts) need to be identified.
● For residual-strength testing, the identification at the component or

subcomponent level (e.g., longitudinal skin splices) may be sufficient.
(c) Step 3 – Evaluation of WFD-Susceptible Structure. Applicants must evaluate all

susceptible structure identified in Step 2. Applicants must demonstrate, by full-scale
fatigue-test evidence, that WFD will not occur in the airplane structure prior to the LOV.
This demonstration typically entails full-scale fatigue testing, followed by teardown
inspections and a quantitative evaluation of any finding or residual-strength testing, or
both. Additional guidance about full-scale fatigue-test evidence is included in appendix
2 of this AC.
(d) Step 4 – Finalize LOV. After all susceptible structure has been evaluated, finalize the
LOV. The results of the evaluations performed in Step 3 will either demonstrate that the
strength at the candidate LOV meets or exceeds the levels required by § 25.571(b), or
not. If it is demonstrated that the strength is equal to or greater than that required, the
final LOV could be set to the candidate LOV without further showing. If it is
demonstrated that the strength is less than the required level, at least two outcomes are
possible.
1 Final LOV may equal the candidate LOV. However, this would result in
maintenance actions, design changes, or both maintenance actions and design
changes to support operation of airplanes up to LOV. For MSD/MED, an applicant
may use damage-tolerance-based inspections to supplement replacement or
91
Page 92 of 123
modification required to preclude WFD when those inspections have been shown to
be practical and reliable.
(aa) Maintenance actions. In some cases, maintenance actions may be necessary

for an airplane to reach its LOV. These maintenance actions could include
inspections, modifications, replacements, or any combination of these. The
applicant must substantiate the maintenance actions per the guidance
contained in this AC.
● For initial certification, these actions should be both specified as

airworthiness-limitation items and incorporated into the ALS of the ICA.
● For post-certification airplanes, these actions should be specified as service

information by the TC holder and may be mandated by FAA airworthiness
directives. Refer to AC 120-104 for additional maintenance-action
guidance.
(bb) Design changes. The applicant may determine that developing design
changes to prevent WFD in future production airplanes is to their advantage.
The applicant must substantiate the design changes per the guidance
contained in this AC.
2 Final LOV may be less than the candidate LOV. This could preclude having
maintenances actions or making design changes.
(aa) In addition to the technical considerations, the LOV may be based on several
other factors, including—
● Maintenance considerations.
● Operator input.
● Economics.
d. Airworthiness Limitations section (ALS). In accordance with 14 CFR 21.50, the type-
certificate holder must provide the ICA, which includes the ALS, with the airplane. However,
the type-certificate holder may or may not have completed the full-scale fatigue-test program at
the time of type certification.
(1) Fatigue testing is not completed. Under 14 CFR 25.571, the FAA may issue a type certificate
for an airplane model prior to the applicant’s completion of full-scale fatigue testing,
provided that the Administrator has approved a plan for completing the required tests. Until
the full-scale fatigue testing is completed and the FAA has approved the LOV, the type-
certificate holder must establish a limitation that is equal to one-half the number of cycles
accumulated on the test article. (See appendix 2 in this AC for more information about the
test article.) At the time of type certification, the applicant should show that at least one
calendar year of safe operation has been substantiated using fatigue-test evidence. Under
appendix H to part 25, the ALS must contain a defined limitation equal to one-half the
number of cycles accumulated on the fatigue-test article approved under § 25.571. This
92
Page 93 of 123
limitation is an airworthiness limitation. No airplane may be operated beyond this limitation

until the fatigue testing is completed and an LOV is approved. As additional cycles on the
fatigue-test article are accumulated, this limitation may be adjusted accordingly. Upon
completion of the full-scale fatigue test, applicants should perform specific inspections and
analyses to determine whether WFD has occurred. Additional guidance about post-test WFD
evaluations is included in appendix 2 of this AC.
(2) Fatigue testing is completed. After the full-scale fatigue test has been completed, the
applicant must include the following in the ALS (see appendix 2 of this AC for additional
guidance):
● Under appendix H to part 25, the ALS must contain the LOV stated as a number of total
accumulated flight cycles or flight hours approved under § 25.571.
● Depending on the results of the evaluation under Step 3, the ALS may also include
requirements to inspect, modify, or replace structure.
e. Type-design changes (Amendment 25-96 or later). Any person applying for an amended type
certificate or a supplemental type certificate to introduce a type design change that adds or affects
WFD-susceptible structure must demonstrate that new and affected structure are free from WFD
up to the LOV of the airplane. This demonstration may include analysis supported by fatigue-
test evidence (see appendix 2 of this AC), analysis that correlates to relevant existing full-scale
fatigue-test results, or both. Where analysis supported by test evidence demonstrates freedom
from WFD, the applicant may use one of the following approaches to demonstrate freedom from
WFD. One approach is based on fatigue-crack initiation and relies on fatigue data. Another
approach is based on crack growth and requires the application of fracture-mechanics methods.
Inspections or other procedures necessary to prevent catastrophic failure from accidental,
environmental, or fatigue damage (including WFD) up to the LOV must be included in the ALS
of the ICA, as required by § 25.1529. (See also appendix H to part 25). As an alternative for
accidental and environmental damage, the documents containing the ICA may be referenced in
the ALS of the ICA. See section 6i of this AC for further guidance.
f. Repairs (Amendment 25-96 or later ). Any person performing a major repair that adds or
affects WFD-susceptible structure must demonstrate that any new and affected structure is free
from WFD up to the LOV of the airplane. If a repair does not add or affect WFD-susceptible
structure, no further WFD evaluation is required. Where analysis supported by test evidence
demonstrates freedom from WFD, the applicant may use one of the following approaches to
demonstrate freedom from WFD. One approach is based on fatigue-crack initiation and relies on
fatigue data. Another approach is based on crack growth and requires the application of fracture-
mechanics methods. Refer to appendix 5 of AC 120-93 for the repair-approval process. If WFD
is determined likely to occur before the LOV is reached, the applicant must either—
(1) redesign the proposed repair to preclude WFD from occurring before the airplane reaches the
LOV, or
(2) develop maintenance actions to preclude WFD from occurring before the airplane reaches the
LOV. For repairs, an applicant must identify and include these actions as part of the repair
data.
93
Page 94 of 123
g. Extended LOV. If an applicant proposes to extend an LOV, they must comply with the
requirements of 14 CFR 26.23. Refer to AC 120-104 for guidance on extending an LOV.
Typically, the data necessary to extend an LOV includes additional full-scale fatigue-test
evidence. The primary source of this test evidence should be full-scale fatigue testing. This
testing should follow the guidance contained in appendix 2 of this AC.
8. Fatigue Evaluation.
a. General. The evaluation of structure under the following fatigue- (safe-life) strength-evaluation
methods is intended to ensure that catastrophic fatigue failure – as a result of the repeated loads
of variable magnitude expected in service – will be avoided throughout the structure's operational
life. Under these methods, the fatigue life of the structure should be determined. The evaluation
should include the following:
(1) Estimating or measuring the expected loading spectra for the structure;
(2) Conducting a structural analysis, including consideration of the stress concentration effects;
(3) Performing fatigue testing of structure that cannot be evaluated, based on previous testing, to
establish response to the typical loading spectrum expected in service;
(4) Determining reliable replacement times by interpreting the loading history, variable-load
analyses, fatigue-test data, service experience, and fatigue analyses;
(5) Evaluating the possibility of fatigue initiation from sources, such as stress corrosion,
disbonding, environmental (e.g., corrosion) and accidental damage, and manufacturing
defects, based on a review of the design, quality control, and past service experience; and
(6) Providing necessary maintenance programs and replacement times to the operators. The
maintenance program should be included in the ICA in accordance with 14 CFR 25.1529.
b. Scatter Factor for Safe-life Determination. In the interpretation of fatigue analyses and test
data under § 25.571(c), the effect of variability should be accounted for by an appropriate scatter
factor. The applicant should justify the scatter factor chosen for any safe-life part. The following
guidance is provided (See Figure 1):
(1) The base scatter factors applicable to test results are BSF1= 3.0 and BSF2 ≥ 3.0 (see
section 8b(5) of this AC). If the applicant can meet the criteria of
section 8b(3) of this AC, they may use BSF1. As an option, the applicant may
elect to use BSF2. If the applicant cannot meet the criteria of section 8b(3) of this AC, they
must use BSF2.
(2) Base scatter factor BSF1 development. The base scatter factor BSF1 is developed using test
results of one representative test specimen.
(3) Justification for use of BSF1. BSF1 may be used only if the following criteria are met:
94
Page 95 of 123
(a) Understanding of load paths and failure modes. Service and test experience of similar
in-service components that were designed using similar design criteria and methods
should demonstrate that the load paths and potential failure modes of the components
are well understood.
(b) Control of design, material, and manufacturing process quality. The applicant should
demonstrate that his quality system (e.g., design, process control, and material
standards) ensures that the scatter in fatigue properties is controlled and that the design
of the fatigue-critical areas of the part account for the material scatter.
95
Page 96 of 123
Figure 1 – Safe-Life Determination
HAVE THE CRITERIA OF § 8b(3) BEEN MET:
-- Service and Text Experience of Similar Components § 8b(3)(a)

8b(3)(i)
-- QA System Ensuring Fatigure Scatter Lies within Certain Limits

§ 8b(3)(b)
8b(3)(ii)
--Representativeness of Test Specimen § 8b(3)(c)

8b(3)(iii)
ALL CRITERIA SOME CRITERIA

MET MISSED
USE BSF1 = 3.0 USE BSF2 ≥ 3.0

§ 8b(3)
HAVE THE ELEMENTS OF § 8b(4) BEEN BSF2 DETERMINED FROM ANALYSIS

ACCOUNTED FOR IN DESIGN: AND TEST § 8b(5)(a)
8b(5)(i)
-- Fatigue Scatter to Account for P=99% and -- Required Level of Safety
C=95% § 8b(4)(a)
8b(4)(i) -- Number of Specimens Tested
-- Spectrum Severity § 8b(4)(b)
8b(4)(ii) -- Representativeness of Test
-- Fatigue Scatter to Account for
P-99% and C=95%
-- Type of Repeated Loads Test
-- Accuracy of the Test Load Spectrum
-- Spectrum Severity
ALL ELEMENTS SOME ELEMENTS
-- Service Environmental Conditions
MET MISSED
Minimum Value ≥ 3.0 § 8b(5)(b)
8b(5)(ii)
Adjust BSF2 for Resolution of Test
Loads to Actual Loads § 8b(6)
ADJUST BSF1 for: ADJUST BSF1 for:

-- Number of Specimen -- Fatigue Scatter § 8b(4)(a)
8b(4)(i)
Tested § 8b(4)(c)
8b(4)(iii) -- Spectrum Severity § 8b(4)(b)
8b(4)(ii)
-- Resolution of Test Loads -- Number of Specimen Tested
to Actual Loads § 8b(6) § 8b(4)(c)
8b(4)(iii) SAFE LIFE =
-- Resolution of Test Loads to TEST CYCLES/SCATTER FACTOR*
Actual Loads § 8b(6)
*Scatter Factor = BSFx X Adjustment

SAFE LIFE =
TEST CYCLES/SCATTER FACTOR*
96
Page 97 of 123
(c) Representativeness of the test specimen.
1 The test article should be full-scale (component or sub-component) and represent

that portion of the production aircraft requiring test. All differences between the test
article and production article should be accounted for either by analysis supported by
test evidence or by testing itself.
2 Construction details, such as bracket attachments and clips, should be accounted for,
even though the items themselves may be non-load bearing.
3 Points of load application and reaction should accurately reflect those of the aircraft,
ensure correct behavior of the test article, and guard against uncharacteristic failures.
4 Systems used to protect the structure against environmental degradation can have a
negative effect on fatigue life and, therefore, should be included as part of the test
article.
(4) Adjustments to base scatter factor BSF1. If the criteria in section 8b(3) justifying the use of
BSF1 have been met, the base value of 3.0 should be adjusted to account for the following
factors, where these factors are not wholly taken into account by design analysis. As a result
of the adjustments, the final scatter factor may be less than, equal to, or greater than 3.0.
(a) Material fatigue scatter. Material properties should be investigated up to a 99%

probability of survival and a 95% level of confidence.
(b) Spectrum severity. The test-loads spectrum should be derived, based on a spectrum-
sensitive analysis accounting for variations in utilization (e.g., aircraft weight and center
of gravity), as well as for the occurrence and size of loads. The test-loads spectrum
applied to the structure should be demonstrated to be conservative when compared to the
usage expected in service.
(c) Number of representative test specimens. Well established statistical methods should be
used that associate the number of items tested with the distribution chosen to obtain an
adjustment to the base scatter factor.
(5) Adjustments to base scatter factor BSF2. If section 8b(3) of this AC cannot be satisfied in its
entirety, the applicant should use BSF2.
(a) The applicant should propose scatter factor BSF2 based on careful consideration of the
following issues:
● required level of safety,
● number of representative test specimens,
● how representative the test is,
● expected fatigue scatter,
97
Page 98 of 123
● type of repeated load test,
● accuracy of the test-loads spectrum,
● spectrum severity, and
● expected service environmental conditions.
(b) In no case should the value of BSF2 be less than 3.0.
(6) Resolution of test loadings to actual loadings. The applicant may use a number of different
approaches to reduce both the number of load cycles and number of test set-ups required.
These include the following:
● spectrum blocking (i.e., a change in the spectrum load sequence to reduce the total number
of test setups);
● high-load clipping (i.e., reduction of the highest spectrum loads to a level at which the
beneficial effects of compression yield are reduced or eliminated); and
● low-load truncation (i.e., the removal of non-damaging load cycles to simplify the
spectrum).
(7) Due to the modifications to the flight-by-flight loading sequence caused by these changes, the
applicant should propose either analytical or empirical approaches to quantify an adjustment
to the number of test cycles which represents the difference between the test spectrum and the
assumed flight-by-flight spectrum. In addition, an adjustment to the number of test cycles
may be justified by raising or lowering the test-load levels, as long as data support such
adjustment. Other effects to consider are different failure locations, different response to
fretting conditions, and temperature effects. The analytical approach should either use well-
established methods or be supported by test evidence.
c. Replacement times. Under § 25.571(a)(3), replacement times should be established for parts
with established safe-lives and should be included in the ALS of the ICA. These replacement
times can be extended if additional data indicate an extension is warranted. Factors that should
be considered for such extensions include the following:
(1) Comparison of original evaluation with service experience.
(2) Recorded load and stress data. Recorded load and stress data entails the installation of
instrumentation on airplanes in service to obtain a representative sampling of actual loads and
stresses experienced. The data to be measured include airspeed, altitude, and load-factor-
versus-time data; or airspeed, altitude, and strain-ranges-versus-time data; or similar data.
The data obtained from airplanes in service provide a basis for correlating the estimated
loading spectrum with the actual service experience.
(3) Additional analyses and tests. If test data and analyses are obtained based on repeated load
tests of additional specimens, a re-evaluation of the established safe-life can be made.
98
Page 99 of 123
(4) Tests of parts removed from service. Repeated load tests of replaced parts can be used to re-
evaluate the established safe-life. The tests should closely simulate service loading
conditions. Repeated load testing of parts removed from service is especially useful where
recorded load data obtained in service are available, since the actual loading experienced by
the part prior to replacement is known.
(5) Repair or rework of the structure. In some cases, repair or rework of the structure can gain
further life.
d. Type-design developments and changes. For design developments or design changes

involving structural configurations similar to those of a design already shown to comply with the
applicable provisions of § 25.571(c), it may be possible to evaluate the variations in critical
portions of the structure on a comparative basis. Examples would be (1) redesign of the wing
structure for increased loads or (2) the introduction, in pressurized cabins, of cutouts having
different locations or different shapes, or both. This evaluation should involve analysis of the
predicted stresses of the redesigned primary structure, and correlation of the analysis with the
analytical and test results used in showing compliance with § 25.571(c) of the original design.
e. Environmental effects such as temperature and humidity should be considered in the damage-
tolerance and fatigue analysis, and should be demonstrated through suitable testing.
9. Discrete Source Damage.
a. General. The purpose of this section is to establish FAA guidelines for consistent selection of
load conditions for residual-strength substantiation in showing compliance with § 25.571(e),
Damage-tolerance (discrete source) evaluation. The intent of these guidelines is to define, with
a satisfactory level of confidence, load conditions that will not be exceeded on the flight during
which the specified incident of § 25.571(e) occurs. In defining these load conditions,
consideration has been given to the expected damage to the airplane, the anticipated response of
the pilot at the time of the incident, and the actions of the pilot to avoid severe load environments
for the remainder of the flight consistent with pilot knowledge that the airplane may be in a
damaged state. With these considerations in mind, use the following ultimate loading conditions
to establish residual strength of the damaged structure.
b. The maximum extent of immediately obvious damage from discrete sources (§ 25.571(e))
should be determined, and the remaining structure shown with an acceptable level of confidence,
to have static strength for the maximum load (considered as ultimate load) expected during
completion of the flight.
c. The ultimate loading conditions should not be less than those developed from the following
conditions:
(1) At the time of the incident:
(a) The maximum, normal, operating differential pressure, multiplied by a 1.1 factor, plus
the expected external aerodynamic pressures during 1g level flight combined with 1g
flight loads.
99
Page 100 of 123
(b) The airplane, assumed to be in 1g level flight, should be shown to be able to survive any
maneuver or any other flight-path deviation caused by the specified incident of
§ 25.57l(e), taking into account any likely damage to the flight controls and pilot normal
corrective action.
(2) Following the incident:
(a) Seventy percent (70%) limit flight-maneuver loads and, separately, 40% of the limit gust
velocity (vertical and lateral) at the specified speeds, each combined with the maximum
appropriate cabin differential pressure (including the expected external aerodynamic
pressure).
(b) The airplane must be shown by analysis to be free from flutter up to VD/MD with any
change in structural stiffness resulting from the incident.
100
Page 0 of 123
1/13/11 AC 25.571-1D
Appendix 1
Appendix 1
References and Definitions
1. References.
a. AC 20-107B, “Composite Aircraft Structure”
b. AC 25.1529-1A, “Instructions for Continued Airworthiness of Structural Repairs on

Transport Airplanes”
c. AC 91-56B, “Continuing Structural Integrity Program for Airplanes”
d. AC 120-93, “Damage Tolerance Inspections for Repairs and Alterations”
e. AC 120-104, “Widespread Fatigue Damage and Establishing LOV”
2. Definitions of Terms Used in this AC.
a. Airworthiness Limitation item (ALI) — A mandatory-maintenance action identified

in the Airworthiness Limitations section of a design-approval holder’s Instructions for
Continued Airworthiness. These items may contain mandatory modification or
replacement times, mandatory inspection thresholds, intervals, and inspection
procedures.
b. Airworthiness Limitations section (ALS) — Relative to the Instructions for Continued

Airworthiness, the ALS is a collection of mandatory-maintenance actions required for
airplane structure and fuel-tank systems. For structural-maintenance actions, the ALS
includes structural-modification times, structural-replacement times, structural-
inspection thresholds and intervals, and structural-inspection procedures.
c. Alteration or modification — A design change that is made to an airplane. Within the

context of this AC, the two terms are synonymous.
d. Damage tolerance — The attribute of the structure that permits it to retain its required
residual strength for a period of use after the structure has sustained a given level of
fatigue, corrosion, or accidental or discrete source damage.
e. Design service goal — The period of time (in flight cycles or flight hours, or both)
established at design and/or certification during which the airplane structure is
reasonably free from significant damage.
f. Environmental Damage – Environmental damage includes many things beyond

temperature and moisture effects, it includes degradation caused by erosion,
A1-0
Page 1 of 123
1/13/11 AC 25.571-1D
Appendix 1
aggressive fluids, ultraviolet radiation and lightning for examples. You must also
consider cycling of temperature and moisture, which can cause various forms of matrix
degradation that cause other problems , including permeability and associated
challenges with certain design details (e.g., fluid ingression into sandwich panels,
internal systems exposed to fluids, and fuel tank leakage).
f. Fail-safe — The attribute of the structure that permits it to retain its required residual
strength for a period of unrepaired use after the failure or partial failure of a principal
structural element.
g. Instructions for Continued Airworthiness (ICA) — Documentation that sets forth

instructions and requirements for the maintenance that is essential to the continued
airworthiness of an aircraft, engine, or propeller.
h. Multiple load path — Applies to structure, the applied loads of which are distributed
through redundant structural members, so that the failure of a single structural member
does not result in the loss of structural capability to carry the applied loads.
i. Limit of validity (of the engineering data that supports the structural maintenance
program) — The period of time (in flight cycles, flight hours, or both), up to which it
has been demonstrated by test evidence, analysis and, if available, service experience
and teardown inspection results of high-time airplanes, that widespread fatigue damage
will not occur in the airplane structure.
j. Principal structural element (PSE) — An element that contributes significantly to the

carrying of flight, ground, or pressurization loads, and whose integrity is essential in
maintaining the overall structural integrity of the airplane. Principal structural elements
include all structure susceptible to fatigue damage, which could contribute to a
catastrophic failure. Refer to appendix 5 of this AC for clarification on how this term
relates to the terms, fatigue critical structure (FCS) and WFD – susceptible structure.
k. Safe-life — The number of events, such as flight cycles, landings, or flight hours, within
which the structure strength has a low probability of degrading below its design ultimate
value due to fatigue cracking.
l. Scatter factor — A life-reduction factor used in interpreting fatigue analysis and test
results.
m. Single load path — Describes structure, the applied loads of which are eventually
distributed through a single structural member, the failure of which would result in the
loss of the structural capability to carry the applied loads.
A1-1
Page 2 of 123
1/13/11 AC 25.571-1D
Appendix 1
n. Teardown inspection — The term used for the process of disassembling structure and
using destructive inspection techniques or visual (e.g., magnifying glass and dye
penetrant) or other non-destructive (e.g., eddy current, ultrasound) inspection techniques
to identify the extent of damage, within a structure, caused by fatigue,
environmental, and accidental damage.
o. Widespread fatigue damage (WFD) — The simultaneous presence of damage at

multiple structural locations that are of sufficient size and density such that the structure
will no longer meet the residual-strength requirements of § 25.571(b). Note that WFD
may further be affected by environmental degradation in metal-bonded structural details
subjected to other aging phenomena (e.g., hydration).
(1) Multiple site damage (MSD) — A source of widespread fatigue damage

characterized by the simultaneous presence of fatigue damage in the same
structural element.
(2) Multiple element damage (MED) — A source of widespread fatigue damage

characterized by the simultaneous presence of fatigue damage in adjacent
structural elements.
(3) Structural modification point (SMP) — The point in time when a structural area
must be modified to preclude WFD.
(4) Inspection start point — The point in time when special inspections of the fleet are
initiated due to a specific probability of having a MSD/MED condition.
p. WFD(average behavior) — The point in time, without intervention, when 50% of the fleet is
expected to develop WFD for a particular structure.
A1-2
Page 0 of 123
1/13/11 AC 25.571-1D
Appendix 2
Appendix 2
Full-Scale Fatigue Testing
1. Overview. Section 25.571(b) requires that special consideration for WFD be included
where the design is such that this type of damage could occur. Many such areas typically
are found in metallic transport airplane structure. Refer to AC 120-104 for examples of
WFD-susceptible structure. These areas have in common the same or similar structural
details over large areas that are subject to similar repeated tension-stress levels.
a. Without intervention, simultaneous fatigue damage would eventually occur at

multiple locations that would be very difficult to detect before the structure strength
degrades below required levels. A strategy must be in place to prevent such fatigue
damage from occurring, as mere inspection of these areas is not reliable to maintain
continued airworthiness of the airplane. Section 25.571(b) requires the applicant to
demonstrate with sufficient full-scale fatigue-test evidence that WFD will not occur in
any susceptible area within the LOV of the airplane.
b. As discussed in section 2 of this appendix, full-scale fatigue-test evidence may be

obtained from in-service experience. Testing should involve subjecting a full-scale
fatigue-test article to repeated loads followed by an evaluation to determine residual-
strength capability. For new type certificates and derivative models, the applicant
should use the results of the evaluation to help establish the LOV for the airplane as
discussed in section 7 of this AC.
c. Section 3 of this appendix discusses the key elements of a full-scale fatigue-test

program. The scope of the full-scale fatigue-test article required will depend on the type
of the certification project as discussed in section 4 of this appendix. For the purposes
of this AC, certification projects include: (1) new type certificates, (2) derivative
models, (3) type design changes – service bulletins, (4) type design changes –
supplemental type certificates, and (5) major repairs. In some cases, data from previous
full-scale fatigue testing may exist and may be relevant to the certification project.
d. Applicants must consider the issues identified in section 5 of this appendix when using
existing test data as evidence to support compliance.
e. Applicants must consider the issues identified in section 6 of this appendix when using
in-service data as evidence to support compliance.
2. Full-Scale Fatigue-Test Evidence. Full-scale fatigue-test evidence in the context of

§ 25.571 makes up the body of evidence (which may also include service experience) that
supports the WFD evaluation for a certification project. It includes data used in
determining or bounding the time to develop MSD/MED damage of a certain size,
A2-0
Page 1 of 123
1/13/11 AC 25.571-1D
Appendix 2
MSD/MED damage-growth scenarios, and residual-strength capability with MSD/MED

damage present. Types of data include strain-survey results, non-destructive and
destructive inspection results, and residual-strength test results. The primary source of full-
scale fatigue-test evidence is full-scale fatigue testing. The guidelines contained herein
should ensure that sufficient test evidence is produced to provide a high degree of
confidence that WFD will not occur within the LOV. This involves a laboratory test in
which structure that is representative of the type design being considered is subjected to
loading that simulates typical service operation. The test article may be the entire airframe
or a portion of it. A source of data that may supplement full-scale fatigue-test evidence is
data from operational airplanes. This “in-service” data includes maintenance findings and
results of teardown inspections.
3. Elements of a Full-Scale Fatigue-Test Program. The following guidance addresses

elements of a test program used in generating the data necessary to support compliance. It
is generally applicable to all certification projects.
a. Article. The test article should be representative of the structure of the airplane to be
certificated (i.e., a production article). The test article should be conformed in
accordance with 14 CFR 21.23. Attributes of the type design that could affect
MSD/MED initiation, growth, and subsequent residual-strength capability should be
replicated as closely as possible on the test article. Critical attributes include, but are
not limited to, the following:
● material types and forms,
● dimensions,
● joining methods and details,
● coating and plating,
● use of faying surface sealant,
● assembly processes and sequences and,
● influence of secondary structure (e.g., loads induced due to proximity to the structure
under evaluation).
b. Test setup and loading. The test setup and loading should result in a realistic
simulation of expected operational loads.
A2-1
Page 2 of 123
1/13/11 AC 25.571-1D
Appendix 2
(1) Test setup. The test setup dictates how the loads are introduced into the structure
and reacted. Every effort should be made to introduce and react loads as realistically
as possible. When compromises are made (e.g., wing-air loading), the resulting
internal loads should be evaluated (e.g., using finite-element methods) to ensure that
the structure is not being unrealistically underloaded or overloaded, locally or
globally.
(2) Test loading. Test loading includes the sequence of statically balanced end
conditions that are applied to represent some amount of operational usage.
Typically, a test sequence representing 1/10 of an anticipated service life is repeated
over and over again until the desired test duration is achieved. The sequence used
should include loads from all sources (e.g., cabin pressurization, maneuvers, gusts,
engine thrust, control-surface deflection, and landing impact) that are significant for
the structure being evaluated. The applicant should provide supporting rationale
when a load source is not included in the sequence. Differences between the test
sequence and expected operational sequence should be justified. For example,
standard practice eliminates low loads considered to be non-damaging, and clip
high, infrequent loads that may bias the outcome, but care should be taken in both
cases so that the test results are representative. Section 8b(6) of this AC provides
guidance on resolving test loading to actual loading.
c. WFD(average behavior). Fatigue damage is the gradual deterioration of a material subjected

to repeated loads. This gradual deterioration is a function of use and can be statistically
quantified. Widespread fatigue damage therefore can be statistically quantified.
Widespread fatigue damage cannot be absolutely precluded because there is always
some probability of occurrence. The average time in flight cycles and/or flight hours to
develop WFD is referred to as the WFD(average behavior) for WFD-susceptible structure.
AC 120-104 provides guidance how to determine when structure should be modified or
replaced to minimize the probability of having WFD in the fleet. The point at which a
modification or replacement is undertaken is referred to as the “structural modification
point” (SMP). The SMP is generally a fraction of the number representing the point in
time when WFD(average behavior) will occur. As an example, the SMP may be determined
by dividing the number representing the timing of when WFD(average behavior) will occur by
a factor of 2 if inspections are deemed effective, or by a factor of 3 if inspections are not
effective. If an inspection is determined to be effective, the “inspection start point”
(ISP) may be determined by dividing the number representing the timing of when
WFD(average behavior) will occur by a factor of 3.
d. Test duration. The duration of the full-scale fatigue test varies depending on the test
objective, and whether the test is to be used for a new type certificate, design change, or
repair. It is standard practice to interpret the unfactored fatigue life of one specimen as
the average life. It follows, then, that if one full-scale fatigue-test article maintains the
A2-2
Page 3 of 123
1/13/11 AC 25.571-1D
Appendix 2
minimum residual-strength requirements of § 25.571(b) for test duration X, one can

conservatively assume that the WFD(average behavior) of all WFD-susceptible structure is
equal to X. Assuming inspection for MSD/MED is impractical, replacement or
modification would be required at X divided by 3 per the guidance in AC 120-104. For
areas where inspections for MSD/MED are practical, the applicant may defer
replacement or modification until X divided by 2, provided inspections for MSD/MED
start at X divided by 3. The applicant should consider these factors when deciding on
the duration of a full-scale fatigue test.
(1) New type certificates and derivatives. The applicant must establish an LOV for new
type certificates and derivative models. There are no requirements regarding the
value of LOV. The full-scale fatigue-test duration should not be less than 2 times
the LOV. Although not required, a longer test may identify unanticipated fatigue-
sensitive areas as well as help validate damage sites, damage scenarios,
damage-growth lives, and residual-strength capabilities. The applicant may also use
a longer test to reduce or eliminate the need for WFD-related mandatory-
maintenance actions. Consistent with the guidance in section (3)(d) of this
appendix, and AC 120-104, a test duration of 3 times the LOV, without an
occurrence of WFD, would eliminate the need for WFD-related mandatory-
maintenance requirements. On the other hand, a test duration of 2 times the LOV
may result in required inspections and/or replacements/modifications prior to the
LOV.
(2) Repairs and type design changes. The test duration should support the installation of
repairs and type design changes up to the LOV of the affected airplane model. If it
is conservatively assumed that the repair or type-design change is implemented
before an airplane has accumulated any time in service, the rationale discussed in
section 3d(1), above, applies. A test duration of 3 times the LOV would be
recommended. However, consideration of the age of the airplane being repaired or
modified could reduce the test duration. For example, an applicant for a repair or
type design change to an airplane that has reached an age equivalent to 75 percent of
its LOV must demonstrate that the repaired or modified airplane will be free from
WFD for at least the remaining 25 percent of the LOV. In this example, a test
duration of 75% of the LOV would be recommended (i.e., 3 times the time
remaining until the LOV is reached).
e. Post-test evaluation. One of the primary objectives of the full-scale fatigue test is to
generate data needed to determine the WFD(average behavior) for each susceptible area or
establish a lower bound. The definition of WFD(average behavior) is the average time
required for MSD/MED to initiate and grow to the point that the static-strength
capability of the structure is reduced below the residual-strength requirements of
A2-3
Page 4 of 123
1/13/11 AC 25.571-1D
Appendix 2
§ 25.571(b). A residual-strength assessment is required at the end of the full-scale

fatigue test to demonstrate that the structure meets this requirement.
(1) Residual-strength tests. The direct way to demonstrate freedom from WFD at the
end of a full-scale fatigue test is to subject the article to the required residual-
strength loads specified in § 25.571(b). If the test article sustains these loads, the
applicant has demonstrated that the structure has a minimum WFD(average behavior)
equal to the number of flight cycles and/or flight hours tested. However, because
fatigue damage that might exist at the end of the test are not quantified, it is not
possible to determine how far beyond the test duration WFD would occur in any of
the susceptible areas without additional work (e.g., teardown inspection). Residual-
strength testing could preclude the possibility of using an article for additional
fatigue testing. For example, the application of loads in excess of representative
operational loads on a metallic test article may result in local material yielding at
existing crack tips that may slow or temporarily stop crack growth.
(2) Teardown inspections. The residual-strength capability may be evaluated indirectly

by performing teardown inspections to quantify the size of any MSD/MED
damage that might be present, or to establish a lower bound on damage size
based on inspection-method capability. After this is done, the residual-strength
capability can be estimated analytically. Depending on the results, damage-
growth analyses may also be required to project backward or forward in time to
estimate the WFD(average behavior) for an area. As a minimum, teardown-inspection
methods should be capable of detecting the minimum size of MSD or MED
damage that would result in a WFD condition (i.e., residual strength degraded to
below the level specified in § 25.571(b)). Effective teardown inspections required to
demonstrate freedom from WFD typically require significant resources. They
usually require disassembly (e.g., fastener removal) and destruction of the test
article. All areas that are susceptible to WFD should be identified and examined.
4. Scope of the Full-Scale Fatigue-Test Article. The scope of the full-scale fatigue-test
article is generally dependent on the type of certification project. Guidance on the expected
scope for various certification projects is as follows:
a. New type certificates. As previously discussed, for any metallic airplane design, it is
likely that multiple areas are susceptible to WFD based on the examples given in AC
120-104. Likewise, testing a complete airframe is probably the most practical approach.
Regardless, the applicant is expected to subject all susceptible areas to full-scale fatigue
testing. The only exception involves existing full-scale fatigue-test evidence that could
be used to support compliance.
A2-4
Page 5 of 123
1/13/11 AC 25.571-1D
Appendix 2
b. Derivative models – amended type certificates. The default for a derivative model
would be to test the entire airframe. However, it is considered likely that existing data
was developed and is available to support compliance of the original model. If this is
the case, the article may be limited to only a portion or portions of the complete
airframe.
c. Type-design changes – service bulletins. The default for a type-certificate holder’s

type design change is to test an article consisting of the design change and any original
structure that is susceptible to WFD, and which the design change could negatively
affect in terms of fatigue. See appendix 4 for examples of types of alterations for which
the type-certificate holder should perform full-scale fatigue tests, unless the type-
certificate holder can show that fatigue testing is not required (e.g., an alteration is not
susceptible to WFD, or sufficient test data already exists). It is expected that the type-
certificate holder has existing relevant data. If this is the case, this type of certification
project would not require a test, provided that the type-certificate holder demonstrates,
with the existing data, that the design change and any of the original structure that it
affects will be free from WFD up to the LOV of the airplane to which the design change
applies.
d. Type-design changes – supplemental type certificates. Because supplemental type

certificate applicants often do not have access to the type-certificate holder’s full-scale
fatigue-test data, a full-scale fatigue-test article is expected. The article should consist
of the design change and any original structure that is susceptible to WFD, and any
structure that the design change could negatively affect in terms of fatigue. See
appendix 4 for examples of types of alterations for which the applicant for an
supplemental type certificate should perform full-scale fatigue tests, unless the applicant
can show that fatigue testing is not required (e.g., an alteration is not susceptible to
WFD, or sufficient test data already exists).
e. Major repairs. In general, major repairs do not require testing of a full-scale test
article. For those repairs where testing is required, the test article should consist of the
repair and any original structure that is susceptible to WFD, and which the repair could
negatively affect in terms of fatigue.
(1) Published repair instructions (Amendment 25-96 or later). The applicant for a type
certificate usually develops published repair instructions, such as a structural repair
manual, for an airplane model. The applicant should perform analyses, such as
fatigue and damage-tolerance analyses, that correlate to results of relevant full-scale
fatigue tests to show the repairs in that manual are free from WFD up to the LOV.
Alternatively, the applicant could perform component fatigue testing to show the
published repairs are free from WFD up to the LOV.
A2-5
Page 6 of 123
1/13/11 AC 25.571-1D
Appendix 2
(2) Non-published repair instructions (Amendment 25-96 or later). The applicant

should correlate analysis methods to results of relevant full-scale fatigue tests, or
perform component fatigue testing to evaluate the repair. Repairs for which
correlated analysis is acceptable are those that are the same as, or comparable to,
those found in FAA-approved published data, such as the type-certificate holder’s
structural repair manual. For the purpose of this AC, a repair is comparable when
the operating stress levels and fatigue characteristics are approximately the same as
those of the FAA-approved published data. To achieve this, the repair needs to have
design aspects, such as design details, airframe materials, and production processes
that are similar to the FAA-approved published data. For other repairs and
depending on the type of repair, the applicant may need to perform full-scale fatigue
testing. Alternatively, the applicant may propose analysis methods, such as fatigue
and damage-tolerance analyses, that compare the fatigue characteristics of the
original type design to the repaired structure and affected areas.
5. Use of Existing Full-Scale Fatigue-Test Data. In some cases, especially for derivative
models and type-design changes the type-certificate holder accomplished, existing full-scale
fatigue-test data may be used in supporting compliance and mitigating the need to perform
additional testing. This is most probable when the data are from testing performed to
support compliance with § 25.571 at Amendment 25-96 or later. This is less likely with
other data.
a. Amendment 25-96 or later. Because the primary objective for developing the original
full-scale fatigue-test data is to establish an absolute or lower-bound WFD(average behavior),
for WFD-susceptible areas to support compliance, the original test article should be
conformed and a rigorous post-test evaluation should be completed to demonstrate the
remaining residual-strength capability. In addition to demonstrating residual-strength
capability, the applicant must identify and reconcile any physical differences between
the structure originally tested and the structure being considered that could affect its
fatigue behavior. Differences that should be addressed include, but are not limited to,
differences in any of the physical attributes listed in section 3a of this appendix.
Additionally, the applicant should identify and reconcile differences in operational
loading. As a minimum, the applicant should address the following:
● Gross weight (e.g., increases)
● Cabin pressurization (e.g., change in maximum cabin or operating altitude)
● Flight-segment parameters
b. Other data. Performing full-scale fatigue testing to support compliance with

§ 25.571(b) was not required prior to Amendment 25-96. It was accepted that fatigue
A2-6
Page 7 of 123
1/13/11 AC 25.571-1D
Appendix 2
would be managed solely by inspection, and that inspection requirements adequately

could be determined based on analysis supported by limited testing at the coupon and
component level. Nevertheless, many OEMs performed their own full-scale fatigue
tests with the primary objective to evaluate the economic life of the structure. However,
most test articles were not conformed in accordance with 14 CFR 21.33. Since no
regulation required such tests, applicants did not submit test plans or reports to the FAA.
Testing philosophies and protocols were not standardized, and the rigor of methods used
for load-sequence development varied significantly over the years and from one OEM to
another. Post-test evaluations (if performed) varied significantly and, in some cases,
consisted of nothing more than limited visual inspections. An applicant may propose to
use full-scale fatigue-test data from airplanes certificated to 14 CFR 25.571 (pre-
Amendment 25-96) to support compliance with Amendment 25-96 or later
requirements. In such cases, the applicant must consider the issues identified in section
5a of this appendix.
6. Use of In-Service Data. In-service data may be available to be used in supporting WFD
evaluations. Examples of such data are as follows:
● Documented positive findings of MSD/MED damage that include location, size, and
the time in service of the affected airplane, along with a credible record of how the
airplane had been operated since original delivery.
● Documented negative findings from in-service inspections for MSD/MED damage on

a statistically significant number of airplanes, with the time in service of each aircraft
and a credible record of how each aircraft had been operated since original delivery.
For this data to be useful, the inspection methods used should be capable of detecting
MSD/MED damage sizes equal to or smaller than those sizes that could reduce the
strength of the structure below the residual-strength levels specified in § 25.571(b).
● Documented findings from the destructive teardown inspection of structure from in-
service airplanes. This might be structure (e.g., fuselage splices) removed from
airplanes that were subsequently returned to service or from retired airplanes. It would
also be necessary to have a credible record of the operational loading the subject
structure experienced up to the time it was taken out of service.
a. Prior to using in-service data, any physical and loading differences that exist between
the structure of the in-service or retired airplanes, and the structure being certified,
should be identified and reconciled as discussed in section 5a of this appendix.
A2-7
Page 0 of 123
1/13/11 AC 25.571-1D
Appendix 3
Appendix 3
Process for Compliance with 14 CFR 25.571(a), (b) and (c) for Fatigue Damage
This chart applies only to § 25.571(a), (b), and (c) for fatigue damage (FD), relative to LOV.
For the purposes of this flowchart “All Structure” refers to all structure within the scope of
§ 25.571. This includes fatigue critical structure, as defined in 14 CFR 26.41.
A3-0
Page 1 of 123
1/13/11 AC 25.571-1D
Appendix 3
Step 1: Is the integrity of the structure essential in maintaining the overall structural integrity of
the airplane, and does it contribute significantly to the carrying of flight, ground, or
pressurization loads?
If Yes, go to Step 2. Structure meeting these criteria are within the scope of § 25.571.
See section 6c of this AC for examples.
If No, then the structure under consideration is not within the scope of § 25.571.
Terminate the process.
Step 2: Evaluate each structure in accordance with § 25.571(a) and (b) or (c), as applicable.
Structure identified to be within the scope of the § 25.571 requires a showing of

compliance with § 25.571 (a) and (b) or (c), as applicable, relative to fatigue damage.
Environmental damage and accidental damage, including manufacturing defects, are
not addressed in this flowchart.
Corrosion typically has been addressed by maintaining corrosion to Level 1 or

better, and to corrosion control and accidental damage programs. These programs
are developed under the Air Transport Association of America, Inc. (ATA)
Maintenance Steering Group’s MSG-3 or other accepted version of the
“Operator/Manufacturer Scheduled Maintenance Development” procedures.
As airplanes are subjected to these programs, operators should evaluate the

programs and adjust them to fit their operations.
Note: Section 25.571 requires applicants to evaluate the strength, detail design, and
fabrication to show that catastrophic failure due to fatigue, environmental,
manufacturing defects, or accidental damage will be avoided throughout the
operational life of the airplane. It also requires that, based on the evaluations,
inspections, or other procedures be established, as necessary, to prevent
catastrophic failure, and be included in the ALS of the ICA, as required by
§ 25.1529.
As discussed in section 6i(3) of this AC, the applicant may use the Maintenance
Review Board process to develop maintenance tasks that require inspections or other
procedures for addressing accidental and environmental (corrosion) damage. If this
process is used as a means of compliance, the applicant should reference, in the ALS,
the maintenance documents that contain those tasks.
Step 3: Is the structure susceptible to fatigue damage?
If Yes, go to Step 4.
A3-1
Page 2 of 123
1/13/11 AC 25.571-1D
Appendix 3
If No, no further showing of compliance is necessary. Terminate the process.
Structure that is susceptible to fatigue damage, which could, without intervention,

eventually lead to catastrophic failure of an airplane, typically includes structure critical
to carrying flight, ground, or pressurization loads that are subjected to tension-
dominated repeated loads during operation (as discussed previously in this document).
This structure also includes structure which, if repaired or altered, could be susceptible
to fatigue damage and contribute to a catastrophic failure.
Step 4: Is it reasonably foreseeable that fatigue damage will occur before the LOV? Fatigue
damage in this context includes all fatigue-cracking scenarios, including fatigue
cracking at unique design feature as well as MSD and MED. If the fatigue performance
of the structure relies on a bond, that bond must perform as intended throughout the
LOV. See AC20-107B, para. 6(d), for guidance on the means to address aging of
bonded structure and verify bondline integrity within the LOV.
If No, no further showing of compliance is necessary. Terminate the process. Note

that sufficient evidence must support a high degree of confidence that WFD will not
occur within the LOV.
To address this question, estimate the fatigue life for all susceptible structure. The
evaluation should be based on analysis, test, or service experience, or a combination of
these, as necessary. An applicant may screen out areas that exhibit long fatigue lives.
This means that the average fatigue life is a multiple of the LOV. Typically, the
predicted fatigue life should be at least 3 times the LOV to justify eliminating the
structure from further consideration. This may be the case for basic fuselage structure,
away from discontinuities such as splices, windows, or doors, where the working-stress
levels are relatively low. For structure that cannot be eliminated, additional evaluations
are required.
Step 5: Can the structure be inspected reliably?
If No, go to Step 8.
To address this question, crack-growth and residual-strength evaluations (damage-

tolerance evaluation) must be performed. These evaluations typically are based on
analyses supported by test evidence. Sections 6, 7, and 8 of this AC contain
discussions of damage-tolerance evaluations, and fatigue and widespread-fatigue
evaluations. Use the results to determine if inspections reliably can detect damage
A3-2
Page 3 of 123
1/13/11 AC 25.571-1D
Appendix 3
before it reduces the material strength below the required strength level. For the
purposes of this AC, an inspection is “effective” if, when performed by properly trained
maintenance personnel, the inspection readily detects the damage in question.2
Step 6: Are inspections looking at multiple details (e.g., rivet/fastener holes, adjacent
frames/stringers, etc.) over large areas for relatively small cracks (MSD/MED)?
If Yes, go to Step 7 to establish inspections, then to Step 8 to establish modifications

or replacements.
If No, go to Step 7, then to Step 9.
This step determines whether inspections by themselves are adequate for precluding a
catastrophic failure, or whether they are supplementary to modifying or replacing
structure.
When inspections are focused on details in small areas and have a high probability
of detection, they may be used by themselves to ensure continued airworthiness,
unless or until there are in-service findings. Based on findings, these inspections
may need to be modified, and it may be necessary to modify or replace structure.
When inspections examine multiple details over large areas for relatively small
cracks, they should not be used by themselves. Rather, they should be used to
supplement the modification or replacement of structure. This is because it would
be difficult to achieve the probability of detection required to allow inspection to be
used indefinitely as a means to ensure continued operational safety.
Step 7: Establish requirements for inspections, including thresholds and repetitive inspection
intervals.
Using the results of your damage-tolerance evaluation, select an inspection method (or
methods), and establish the inspection threshold and repetitive inspection interval.
Inspection thresholds must be based on damage-growth analyses and/or tests,

with the assumption that the structure contains an initial flaw of the maximum
2
The cracking identified in airworthiness directive 2002-07-09 is an example of the type of cracking that MSD
inspections effectively detect. These cracks grow from fastener holes in the lower row of the lower skin panel in
such a way that the cracking is readily detectable using non-destructive inspection methods. The cracking identified
in airworthiness directive 2002-07-08 is an example of where MSD inspections are not “effective.” These cracks
grow in the outer surface and between fastener holes in the lower row of the lower skin panel in such a way that the
cracking is not readily detectable using non-destructive inspection methods. Therefore, modification is the only
option to address this type of cracking.
A3-3
Page 4 of 123
1/13/11 AC 25.571-1D
Appendix 3
probable size that could exist as a result of manufacturing or service-induced

damage.
Thresholds established for damage at multiple details that are over large areas
(WFD-related damage) should be determined through a statistical analysis of
damage initiation based on fatigue testing, teardown, or in-service experience of
similar structure. If an inspection is determined to be effective, the “inspection start
point” (ISP) may be determined by dividing the number representing the timing of
when WFD(average behavior) will occur by a factor of 3.
If the answer to the question in Step 6 was Yes, go to Step 8 to establish modifications
or replacements.
If the answer to the question in Step 6 is No, go to Step 9 to determine if the inspection
requirements established in this step need to go into the ALS.
Step 8: Establish modifications or replacements, including time for modifying or replacing

structure.
Based on the results of the fatigue and damage-tolerance evaluations performed,

determine the replacement time or SMP (i.e., replacement time or modification time)
for affected structure.
● For structure that is not susceptible to damage at multiple sites and where the
applicant has shown that the damage-tolerance-based inspections are impractical, a
replacement time must be established per § 25.571(c). See section 8 of this AC for
further guidance.
● For structure that is susceptible to damage at multiple sites and where the applicant
has shown that damage-tolerance-based inspections are practical, a SMP must be
established per § 25.571(b). The Step 6 inspections supplement the required SMP.
An acceptable approach for determining the SMP is to divide the WFD(average behavior)
by a factor of 2. To determine ISP, divide the WFD(average behavior) by a factor of 3.
See AC 120-104 for further guidance on establishing SMP and ISP.
● For structure that is susceptible to damage at multiple sites and where the applicant
has shown that damage-tolerance-based inspections are not reliable in Step 5, an
SMP must be established per § 25.571(b). An acceptable approach would be to
divide the WFD(average behavior) by a factor of 3.
Go to Step 9 to determine if the modification or replacement requirements need to be

included in the ALS.
A3-4
Page 5 of 123
1/13/11 AC 25.571-1D
Appendix 3
Step 9: Are any inspections, modifications, or replacements required before the LOV?
If No, terminate the process.
Based on the results of Steps 7 and 8, determine if any maintenance actions need to be
included in the ALS of the ICA. Any inspection with thresholds less than the LOV, or
replacements or modifications that must occur prior to the LOV, must be included in
the ALS.
Step 10: Revise the FAA-approved ALS to include all inspections, modifications, and
replacements required before the LOV.
Based on the results of Step 9, include, in the ALS of the ICA (per § 25.1529), the
inspections or other procedures determined to be necessary to prevent catastrophic
failure up to the LOV. The LOV must also be included.
For each required inspection, the operator should include—
● The structure to be inspected.
● The method of inspection.
● The inspection threshold (the point in time at which to begin inspections).
● The inspection repetitive interval.
For required modifications or replacements, the operator should include—
● The structure to be modified or replaced.
● The method of modification or replacement.
● The replacement time or structural-modification point (the point in time to begin the
modification), as applicable.
A3-5
Page 0 of 123
1/13/11 AC 25.571-1D
Appendix 4
Appendix 4
Examples of Alterations that May Require Full-Scale Fatigue Testing
1. The following are examples of types of alterations that may require full-scale fatigue
testing:
a. passenger-to-freighter conversions (including addition of cargo doors);
b. gross-weight increases (e.g., increased operating weights, increased zero-fuel weights,

increased landing weights, and increased maximum-takeoff weights);
c. installation of fuselage cutouts (e.g., passenger-entry doors, emergency-exit doors or

crew-escape hatches, fuselage-access doors, and cabin-window relocations);
d. complete re-engine or pylon alteration;
e. engine-hush kits;
f. wing alterations (e.g., installation of winglets; changes in flight-control settings such as

flap droop; and alteration of wing trailing-edge structure);
g. modified or replaced skin splice;
h. any alteration that affects three or more stiffening members (e.g., wing stringers and
fuselage frames);
i. an alteration that results in operational-mission change, which significantly changes the

original equipment manufacturer’s load/stress spectrum (e.g., extending the flight
duration from 2 hours to 10 hours); and
j. an alteration that changes areas of the fuselage from being externally inspectable using
visual means to being uninspectable (e.g., installation of a large, external, fuselage
doubler that results in hiding details beneath it).
A4-0
Page 0 of 123
1/13/11 AC 25.571-1D
Appendix 5
Appendix 5
PSE, FCS and WFD-Susceptible Structure
1. Overview. Three key terms used when showing compliance to the damage-tolerance and
fatigue requirements of 14 CFR parts 25 and 26 are, “principle structural element” (PSE),
“fatigue critical structure” (FCS), and “widespread fatigue damage (WFD) susceptible
structure.” This appendix provides clarification on the intended meanings of these terms and
how they relate to one another. This appendix describes the items that should be included
in an airplane’s Airworthiness Limitations section based on the evaluation of each PSE,
FCS, and WFD-susceptible structure.
2. PSE – Principal Structural Element.
a. The term “principal structural element” (PSE) is defined in this AC as follows:
b. Principal structural element, PSE, is an element that contributes significantly to the

carrying of flight, ground, or pressurization loads, and whose integrity is essential in
maintaining the overall integrity of the airplane.
c. While this definition does not specifically address the fatigue susceptibility of structure,
or environmental or accidental damage, it is intended to address all structure that must
be evaluated under § 25.571. Section 25.571(a) states the following:
“This evaluation must be conducted … for each part of the structure

that could contribute to a catastrophic failure (such as wing,
empennage, control surfaces and their systems, the fuselage, engine
mounting, landing gear, and their related primary attachments).”
d. The above reinforces the notion that the identification of PSEs should be based solely on
the importance of the structure to assure the overall airplane integrity.
e. Section 6c of this AC provides guidance for identifying PSEs. Many manufacturers use
this list as a starting point for their list of fatigue critical structure (FCS), because AC
120-93 specifically refers to this AC for identifying FCS. Section 25.571 is intended to
address all structure that could contribute to a catastrophic failure resulting from fatigue,
environmental, and accidental damage, and therefore may include some structure that is
not considered FCS. Nevertheless, PSE should be considered when developing a list of
FCS.
f. The definitions used by applicants to identify PSEs have not been consistent between
applicants and, in some cases, between models produced by the same applicant. The
lack of standardization of the usage and understanding of the term “PSE,” and the
A5-0
Page 1 of 123
1/13/11 AC 25.571-1D
Appendix 5
resultant diversity that exists between type-design PSE lists, have required the FAA to
introduce a new term, “fatigue-critical structure,” in the Aging Airplane Safety—
Damage Tolerance Data for Repairs and Alterations found in 14 CFR part 26, subpart
E, and corresponding advisory material.
3. FCS – Fatigue Critical Structure.
a. Under 14 CFR 26.41, fatigue critical structure is defined as airplane structure that is
susceptible to fatigue damage, which could contribute to a catastrophic failure, as
determined in accordance with 14 CFR 25.571. Fatigue critical structure includes
structure susceptible to fatigue damage, which could contribute to a catastrophic
failure. Fatigue-critical structure also includes structure which, if repaired or altered,
could be susceptible to fatigue damage and contribute to a catastrophic failure.
Structure may be susceptible to fatigue cracking when subjected to tension-dominated
repeated loads during operation or bondlines susceptible to disbonds due to out-of-plane
peel and shear stresses. Such structure may be part of the baseline structure or part of an
alteration. “Baseline structure” means structure that is designed under the original type
certificate or amended type certificate for that airplane model (i.e., the as-delivered
airplane model configuration).
b. Fatigue critical structure is a subset of principal structural elements, specifically those

elements that are susceptible to fatigue damage.
4. Widespread Fatigue Damage Susceptible Structure.
a. Widespread fatigue damage is the simultaneous presence of cracks at multiple structural

locations, which are of sufficient size and density such that the structure no longer meets
the residual-strength requirements of § 25.571(b).
b. Multiple site damage (MSD) and multiple-element damage (MED) are conditions that,
with no intervention, can lead to WFD. The term “WFD-susceptible structure” refers to
areas of structure that, under normal circumstances, could be expected to eventually
develop MSD and/or MED cracks, which could lead to WFD.
c. Although not explicitly stated, structure susceptible to WFD cannot be inspected

reliably to preclude WFD. Unless a flight cycles and/or flight hours limit is placed on
an airplane, modifications may be needed to preclude WFD. Structure susceptible to
WFD is a subset of FCS, which, in turn, is a subset of PSE.
A5-1
Page 2 of 123
Appendix 6
Acronyms and Abbreviations used in this AC
Term Definition
AC Advisory circular
ALI Airworthiness Limitation item
ALS Airworthiness Limitations section
FCS Fatigue critical structure
ICA Instructions for Continued Airworthiness
ISP Inspection start point
Limit of validity of the engineering data that supports the
LOV
structural maintenance program
MED Multiple element damage
MSD Multiple site damage
PSE Principal structural element
SMP Structural modification point
WFD Widespread fatigue damage
/s/
Jeffrey E. Duven
Acting Manager, Transport Airplane Directorate
Aircraft Certification Service
A5-2
Page 3 of 123
8.0 List of Acronyms
AC Advisory Circular
ACO Aircraft Certification Office
ADL Allowable Damage Limit
ARAC Aviation Rulemaking Advisory Committee
BRSL Bonded Repair Size Limit
BVID Barely Visible Impact Damage
CACRC Commercial Aircraft Composite Repair Committee
CMH Composite Materials Handbook
CFR Code of Federal Regulations
CM Certification Memo
CMT Composite Maintenance Technology
COS Continued Operational Safety
CPCP Corrosion Prevention and Control Program
CVID Clearly Visible Impact Damage
DSG Design Service Goal
DTDC Damage Tolerance Design Criteria
DTE Damage Tolerance Evaluation
DVI Detailed Visual Inspection
EASA European Union Aviation Safety Agency
FAA Federal Aviation Administration
GVI General Visual Inspection
HEWABI High Energy Wide Area Blunt Impact
IPT Integrated Product Team
IRCWG Industry/Regulatory Composite Working Group
LOV Limit of Validity
MLP Multiple Load Path
MRO Maintenance & Repair Organization
MSG Maintenance Steering Group
NAA National Aviation Authority
OEM Original Equipment Manufacturer
NDI Non-destructive Inspection
PAH Production Approval Holder
PMC Polymer Matrix Composite
PSE Principal Structural Element
RDL Repairable Damage Limit
SAE Society of Automotive Engineers
SDC Structural Damage Capability
SLP Single Load Path
SoBR Substantiation of Bonded Repair
SRM Structural Repair Manual
A5-3
Page 4 of 123
TAE Transport Airplane and Engine

TAMCSWG Transport Airplane Metallic and Composites Structures Working Group
TCCA Transport Canada Civil Aviation
TCH Type Certificate Holder
TG Task Group
TSO Technical Standard Order
VID Visual Impact Damage
WFD Widespread Fatigue Damage
WSU Wichita State University
A5-4

Bonded Structure Task Extension-Final Report

Uploaded by

Copyright:

Available Formats

Bonded Structure Task Extension-Final Report

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Bonded Structure Task Extension-Final Report

Uploaded by

Copyright:

Available Formats

Transport Airplane Metallic and Composite Structures Working Group Recommendation Report – Structural Bonding

Transport Airplane Metallic and Composite

RELEASE/REVISION RELEASE DATE

Transport Airplane Metallic and Composite Structures Working Group

AUTHOR/CONCURRENCE: Chantal Fualdes Airbus 7/27/2021

CONCURRENCE: Salamon Haravan Bombardier 7/26/2021

CONCURRENCE: Ryan Higgins British Airways 7/27/2021

CONCURRENCE: Douglas Jury Delta Air Lines 7/26/2021

CONCURRENCE: Antonio Fernando Barbosa Embraer 7/27/2021

CONCURRENCE: Mark Boudreau FedEx 7/27/2021

CONCURRENCE: Kevin Jones Gulfstream 7/27/2021

CONCURRENCE: Toshiyasu Fukuoka 福岡 俊康 Mitsubishi 7/27/2021

AUTHOR/CONCURRENCE: Eric Chesmar United Airlines 7/27/2021

CONCURRENCE: Linda Jahner FAA 7/26/2021

1.0 Executive Summary 5

1.0 Executive Summary

2.0 Bonded Structure Task Extension

 Review Existing References, Including Existing Guidance and Industry Standards

Deliverables: Produce report containing the following recommendations

 Recommendations on appropriate performance-based requirements

A survey contained in the report covered three main technical areas:

1. Materials and processes

2.3 Summary of the Bonding Task from 2018 Final Report

2.4 Detailed Work Plan

● Published reports of service difficulties, incidents or accidents involving bonding

3.0 Rules recommendations

CFR §25.601 – General

CFR §25.603 – Materials

CFR §25.605 - Fabrication methods

must be performed under an approved process specification.

CFR §25.609 - Protection of Structures

Each part of the structure must -

CFR §25.613 - Material strength properties and material design values

Damage-tolerance and fatigue evaluation of structure.

4.0 Guidance recommendations

b) metal to metal, and

- Materials and process controls qualifications procedures

4.2 Experiences of OEM and Best Practices Guidance

Reason for change: To be consistent with rule updates.

Reason for change: Cross reference to other guidance of relevance.

Reason for change:

Reason for change:

Reason for change:

o Needed an update for the old §23.573 reference.

Reason for change:

4.2.3 AC 21-26A Quality System for the Manufacture of

(1) Sandwich construction.

(3) Secondary Bonding.

Reason for change:

Therefore, the TAMCSWG recommendation is to update AC 21-26A to include a cross reference to AC

4.2.4 Bonded Structural Considerations

o Minimization of environmental and accidental damage (i.e. consider protection, different

Structural Damage Capability discussion

A specific fleet leader program is not recommended because:

4.2.4.2 Other Structural Considerations

(3) Achieve predominately cohesive or interlaminar failure modes demonstrating high

4.2.4.3 Adhesion Failure

4.2.5 Maintenance Repair and Inspection Considerations

Service Experiences, Including Benefits from Fleet Surveillance

Repair Size Limits

CONCURRENCE: Toshiyasu Fukuoka 福岡俊康 Mitsubishi 7/27/2021