EASA Easy Rules AMC20

Easy Access Rules for Acceptable Means of
Compliance for Airworthiness of Products,

Parts and Appliances (AMC-20)
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DISCLAIMER
This version is issued by the European Union Aviation Safety Agency (referred to as both ‘EASA’ and ‘the
Agency’) to provide its stakeholders with an updated, consolidated, and easy-to-read publication. It has
been prepared by putting together the related acceptable means of compliance and guidance material
adopted so far, including the amendments. However, this is not an official publication and EASA accepts
no liability for damage of any kind resulting from the risks inherent in the use of this document.

Easy Access Rules for Acceptable Means of Note from the editor
NOTE FROM THE EDITOR
The content of this document is arranged as follows: the acceptable means of compliance (AMC) are
followed by the related guidance material (GM) paragraph(s).
All elements (i.e. AMC and GM) are colour-coded and can be identified according to the illustration below.
The EASA Executive Director (ED) decision through which the point was introduced or last amended is
indicated below the point title in italics.
Acceptable means of compliance

ED decision
Guidance material
ED decision
The format of this document has been adjusted to make it user-friendly and for reference purposes. Any
comments should be sent to [email protected].

Easy Access Rules for Acceptable Means of Incorporated amendments
INCORPORATED AMENDMENTS
AMC/GM (ED DECISIONS)
Incorporated ED Decision AMC/GM Issue No, Amendment No Applicability date
ED Decision 2003/12/RM AMC-20/ Initial issue 5/11/2003
ED Decision 2006/012/R AMC-20/ Amendment 1 29/12/2006
Note: To access the official versions, please click on the hyperlinks provided above.
3 This is the main applicability date defined in the ED Decision. However, the ED Decision allowed that this AMC was not applied to applications
received until 30 June 2014, if so requested by the applicant and providing that in such a case the applicant could demonstrate that the
process of development of the relevant part or appliance started before the entry into force of the ED Decision (1 January 2014), in
accordance with the specifications applicable at that time.

Easy Access Rules for Acceptable Means of Table of contents
TABLE OF CONTENTS
Disclaimer ..........................................................................................3
Note from the editor ..........................................................................4
Incorporated amendments .................................................................5
Table of contents ...............................................................................6
Preamble ......................................................................................... 10
SUBPART A — GENERAL ................................................................... 14
AMC 20-1A ............................................................................................................................. 14
AMC 20-1A Certification of Aircraft Propulsion Systems Equipped with Electronic Control
Systems................................................................................................................................... 14
AMC 20-2B ............................................................................................................................. 19
AMC 20-2B Certification of Essential Auxiliary Power Units (APUs) Equipped with Electronic
Controls .................................................................................................................................. 19
Appendix to AMC 20-2B .............................................................................................................24
AMC 20-3B ............................................................................................................................. 25
AMC 20-3B Certification of Engines Equipped with Electronic Engine Control Systems ....... 25
AMC 20-6 ............................................................................................................................... 56
AMC 20-6 Extended Range Operation with Two-Engine Aeroplanes ETOPS Certification and
Operation ............................................................................................................................... 56
Appendix 1 to AMC 20-6 – Propulsion System Reliability Assessment ......................................85
Appendix 2 to AMC 20-6 – Aircraft Systems Reliability Assessment .........................................96
Appendix 3 to AMC 20-6 – Operational Limitations ................................................................103
Appendix 4 to AMC 20-6 – Flight Preparation and In-flight Procedures..................................104
Appendix 5 to AMC 20-6 – ETOPS En-Route Alternate Aerodromes .......................................110
Appendix 6 to AMC 20-6 – ETOPS Training Programme ..........................................................112
Appendix 7 to AMC 20-6 – Typical ETOPS Operations Manual Supplement ...........................114
Appendix 8 to AMC 20-6 – Continuing Airworthiness Considerations ....................................116
AMC 20-8A ........................................................................................................................... 122
AMC 20-8A Occurrence reporting ........................................................................................ 122
AMC 20-9 ............................................................................................................................. 130
AMC 20-9 Acceptable Means of Compliance for the Approval of Departure Clearance via
Data Communications over ACARS ...................................................................................... 130
Appendix 1 to AMC 20-9 PDC versus DCL: A Comparison .......................................................137

Appendix 2 to AMC 20-9 Common Terms ...............................................................................138

AMC 20-10 ........................................................................................................................... 139
AMC 20-10 Acceptable Means of Compliance for the Approval of Digital ATIS via Data Link
over ACARS ........................................................................................................................... 139
Appendix 1 to AMC 20-10 Common Terms .............................................................................147
AMC 20-15 ........................................................................................................................... 148
AMC 20-15 Airworthiness Certification Considerations for the Airborne Collision Avoidance
System (ACAS II) with optional Hybrid Surveillance ............................................................. 148
Appendix 1 to AMC 20-15 – ACAS II/Mode S Transponder Ground Testing Precautions ........155
Appendix 2 to AMC 20-15 – List of Acronyms .........................................................................156
AMC 20-19 ........................................................................................................................... 157
AMC 20-19 Passenger Service and In-Flight Entertainment (IFE) Systems .......................... 157
AMC 20-20A ......................................................................................................................... 177
AMC 20-20A Continuing structural integrity programme .................................................... 177
Appendix 1 to AMC 20-20A Guidelines for the development of a supplementary structural
inspection programme.............................................................................................................195
Appendix 2 to AMC 20-20A Guidelines for the development of a programme to preclude the
occurrence of widespread fatigue damage .............................................................................203
Annex 1 to Appendix 2 to AMC 20-20A Full-scale fatigue test evidence .................................... 229
Annex 2 to Appendix 2 to AMC 20-20A Example of how to establish an LOV ............................ 236
Appendix 3 to AMC 20-20A Guidelines for establishing instructions for continued airworthiness
of structural repairs and modifications ...................................................................................239
Annex 1 to Appendix 3 to AMC 20-20 Approval process for new repairs ................................... 257
Annex 2 to Appendix 3 to AMC 20-20A Assessment of existing repairs ..................................... 258
Annex 3 to Appendix 3 to AMC 20-20A Repairs and modifications to removable structural
components ................................................................................................................................ 264
Annex 4 to Appendix 3 to AMC 20-20A Service bulletin review process .................................... 267
Annex 5 to Appendix 3 to AMC 20-20A List of major changes and STCs that may adversely affect
fatigue-critical structure.............................................................................................................. 270
Annex 6 to Appendix 3 to AMC 20-20A Background to the need for damage-tolerance-based
inspection programmes for repairs ............................................................................................. 271
Appendix 4 to AMC 20-20A Guidelines for the development of a corrosion prevention control
programme ..............................................................................................................................273
Appendix 5 to AMC 20-20A Guidelines for ensuring the validity of continuing structural integrity
programmes .............................................................................................................................285
AMC 20-21 ........................................................................................................................... 294
AMC 20-21 Programme to enhance aeroplane Electrical Wiring Interconnection System
(EWIS) maintenance ............................................................................................................. 294
Appendix A to AMC 20-21 Enhanced Zonal Analysis Logic Diagram and Steps .......................310
Appendix B to AMC 20-21 Examples of Typical EZAP Worksheets ..........................................318
Appendix C to AMC 20-21 Determination if a major change to an aircraft should be specifically
subjected to an EZAP ...............................................................................................................325
Appendix D to AMC 20-21 .......................................................................................................328
Appendix E to AMC 20-21 Causes of Wire Degradation ..........................................................329
AMC 20-22 ........................................................................................................................... 331

AMC 20-22 Aeroplane Electrical Wiring Interconnection System Training Programme...... 331
Appendix A to AMC 20-22 – EWIS Minimum Initial Training Programme for Group 1 and 2 ..338
Appendix B to AMC 20-22 – EWIS Minimum Initial Training Programme for Group 3 through 8
.................................................................................................................................................340
Appendix C to AMC 20-22 – Curriculum and Lessons Plan ......................................................342
AMC 20-23 ........................................................................................................................... 356
AMC 20-23 Development of Electrical Standard Wiring Practices documentation ............. 356
Appendix A: Groups, Major Topics, Standardised Sequence and Description of Minimum
Content ....................................................................................................................................363
AMC 20-24 ........................................................................................................................... 365
AMC 20-24 Certification Considerations for the Enhanced ATS in Non-Radar Areas using
ADS-B Surveillance (ADS-B-NRA) Application via 1090 MHZ Extended Squitter.................. 365
Appendix 1 to AMC 20-24 ........................................................................................................379
Appendix 2 to AMC 20-24 ........................................................................................................380
Appendix 3 to AMC 20-24 ........................................................................................................381
Appendix 4 to AMC 20-24 ........................................................................................................383
AMC 20-25A ......................................................................................................................... 385
AMC 20-25A Airworthiness considerations for Electronic Flight Bags (EFBs) ..................... 385
AMC 20-29 ........................................................................................................................... 394
AMC 20-29 Composite Aircraft Structure............................................................................. 394
Appendix 1 to AMC 20-29 – Applicable CSs and Relevant Guidance .......................................421
Appendix 2 to AMC 20-29 – Definitions ...................................................................................424
Appendix 3 to AMC 20-29 – Change of Composite Material and/or Process ..........................427
AMC 20-42 ........................................................................................................................... 431
AMC 20-42 Airworthiness information security risk assessment ........................................ 431
AMC 20-115D ....................................................................................................................... 435
AMC 20-115D Airborne Software Development Assurance Using EUROCAE ED-12 and RTCA
DO-178.................................................................................................................................. 435
GM1 to AMC 20-115D — Software change impact analyses (CIAs) ........................................447
GM2 to AMC 20-115D — Clarification of data coupling and control coupling ........................448
GM3 to AMC 20-115D — Error-handling at design level .........................................................448
AMC 20-128A ....................................................................................................................... 450
AMC 20-128A Design Considerations for Minimizing Hazards Caused by Uncontained
Turbine Engine and Auxiliary Power Unit Rotor Failure ....................................................... 450
Appendix 1 to AMC 20-128A User’s Manual ...........................................................................468
AMC 20-136 ......................................................................................................................... 484
AMC 20-136 Aircraft Electrical and Electronic System Lightning Protection ....................... 484
Appendix 1 to AMC 20-136 Definitions and acronyms ............................................................503
AMC 20-152A ....................................................................................................................... 505
AMC 20-152A Development Assurance for Airborne Electronic Hardware (AEH)............... 505

AMC 20-158 ......................................................................................................................... 526

AMC 20-158 Aircraft Electrical and Electronic System High-Intensity Radiated Fields (HIRF)
Protection ............................................................................................................................. 526
Appendix 1 to AMC 20-158 Generic transfer functions and attenuation ................................551
AMC 20-170 ......................................................................................................................... 556
AMC 20-170 Integrated modular avionics (IMA) ................................................................. 556
AMC 20-189 ......................................................................................................................... 580
AMC 20-189 The Management of Open Problem Reports (OPRs) ...................................... 580
GM1 to AMC 20-189 — PR management ................................................................................586
GM2 to AMC 20-189 — OPR classification ..............................................................................586
GM3 to AMC 20-189 — Additional GM related to the ‘Significant’ classification ...................588
SUBPART B — LIST OF AMC-20 ITEMS ............................................. 589

Easy Access Rules for Acceptable Means of Preamble
PREAMBLE
ED Decision 2020/023/R
Amendment 20
The following is a list of paragraphs affected by this amendment:
AMC 20-20A Amended (NPA 2013-07)
Appendix 1 to AMC 20-20A Amended (NPA 2013-07)
Annex 1 to Appendix 2 to AMC 20-20A Created (NPA 2013-07)
Annex 1 to Appendix 3 to AMC 20-20A Amended (NPA 2013-07)
Amendment 19
SUBPART A — GENERAL Created
AMC 20-1 Amended (NPA 2017-09)
AMC 20-19 Created (NPA 2017-09)
AMC 20-152A Created (NPA 2018-19)
SUBPART B — LIST OF AMC-20 ITEMS Created
Amendment 18

Amendment 17
AMC 20-4A Cancelled (NPA 2018-02)
AMC 20-5 Cancelled (NPA 2018-02)
AMC 20-27A Cancelled (NPA 2018-02)
Amendment 16
Amendment 15
Amendment 14
Amendment 13
Amendment 12

Amendment 11
Amendment 10
Amendment 9
Amendment 8
Amendment 7
AMC 20-6 rev. 2 Created (NPA 2008-01)
AMC 20-6 adopted on the 05/11/2003 by means of ED Decision 2003/12/RM is replaced by AMC 20-6 rev. 2.
Amendment 6

Amendment 5
Amendment 4
Amendment 3
AMC 20-24 Created (NPA 2007/05)
Amendment 2
AMC 20-1 Amended (NPA 04/2005)
Amendment 1
AMC 20-9 Created
AMC 20-10 Created
AMC 20-12 Created
AMC 20-13 Created

Easy Access Rules for Acceptable Means of SUBPART A — GENERAL
AMC 20-1A
SUBPART A — GENERAL
AMC 20-1A
AMC 20-1A Certification of Aircraft Propulsion Systems Equipped with

Electronic Control Systems
1 GENERAL
The existing certification specifications (CSs) for Engine, Propeller and aircraft certification may
require special interpretation for Engines and Propellers equipped with electronic control systems.
Because of the nature of this technology and because of the greater interdependence of Engine,
Propeller and aircraft systems, it has been found necessary to prepare acceptable means of
compliance (AMC) specifically addressing the certification of these electronic control systems.
AMC 20-1() addresses the compliance tasks relating to the certification of the installation of
propulsion systems equipped with electronic control systems. AMC 20-3 is dedicated to the
certification of Engine control systems but identifies some Engine-installation-related issues that
should be read in conjunction with AMC 20-1().
Like any AMC, it is issued to outline issues to be considered during demonstration of compliance
with the CSs.
2 RELEVANT SPECIFICATIONS
For aircraft certification, some of the related CSs are:
— for aeroplanes in CS-25 (and, where applicable, CS-23):
— paragraphs 33, 581, 631, 899, 901, 903, 905, 933, 937, 939, 961, 994, 995, 1103(d),
1143 (except (d)), 1149, 1153, 1155, 1163, 1181, 1183, 1189, 1301, 1305, 1307(c),
1309, 1337, 1351(b) and (d), 1353(a) and (b), 1355(c), 1357, 1431, 1461, 1521(a), 1527;
— for rotorcraft: equivalent specifications in CS-27 and CS-29.
3 SCOPE
This AMC is relevant to the CSs for aircraft installation of Engines or Propellers with electronic
control systems, whether using electrical or electronic (analogue or digital) technology.
It gives guidance on the precautions to be taken for the use of electrical and electronic technology
for Engine and Propeller control, protection and monitoring, and, where applicable, for integration
of functions specific to the aircraft.
Precautions have to be adapted to the criticality of the functions. These precautions may be
affected by the degree of authority of the system, the phase of flight, and the availability of a backup
system.

AMC 20-1A
This document also discusses the division of compliance tasks between the applicants for Engine,
Propeller (when applicable), and aircraft type certificates. This guidance relates to issues to be
considered during aircraft certification.
It does not cover APU control systems; APUs, which are not used as ‘propulsion systems’, are
addressed in the dedicated AMC 20-2().
4 PRECAUTIONS
(a) General
The introduction of electrical and electronic technology can entail the following:
— greater dependence of the Engine or Propeller and the aircraft owing to the exchange
of electrical power and/or data between them;
— increased integration of the control and related indication functions;
— a risk of significant Failures that are common to more than one Engine or Propeller of
the aircraft which might, for example, occur as a result of:
— — insufficient protection from electromagnetic disturbance (e.g. lightning,
internal or external radiation effects);
— — insufficient integrity of the aircraft electrical power supply;
— — insufficient integrity of data supplied from the aircraft;
— — hidden design faults or discrepancies contained within the design of the
propulsion system control software or airborne electronic hardware (AEH); or
— — omissions or errors in the system/software/AEH specification.
Appropriate design and integration precautions should therefore be taken to minimise these
risks.
(b) Objective
The introduction of electronic control systems should provide for the aircraft at least the
equivalent level of safety, and the related reliability level, as achieved in aircraft equipped
with Engine and Propellers using hydromechanical control and protection systems.
When possible, early coordination between the Engine, Propeller and aircraft applicants is
recommended in association with EASA as discussed in Section 5 of this AMC.
(c) Precautions relating to electrical power supply and data from the aircraft
When considering the objectives of Section 4(a) or (b), due consideration should be given to
the reliability of electrical power and data supplied to the electronic control systems and
peripheral components. The potential adverse effects on Engine and Propeller operation of
any loss of electrical power supply from the aircraft or failure of data coming from the aircraft
are assessed during the Engine and Propeller certification.
During aircraft certification, the assumptions made as part of the Engine and Propeller
certification on reliability of aircraft power and data should be checked for consistency with
the actual aircraft design.

AMC 20-1A
Aircraft should be protected from unacceptable effects of faults due to a single cause,
simultaneously affecting more than one Engine or Propeller. In particular, the following cases
should be considered:
— erroneous data received from the aircraft by the Engine/Propeller control system if the
data source is common to more than one Engine/Propeller (e.g. air data sources,
autothrottle synchronising); and
— control system operating faults propagating via data links between Engine/Propellers
(e.g. maintenance recording, common bus, cross-talk, autofeathering, automatic
reserve power system).
Any precautions needed may be taken either through the aircraft system architecture or by
logic internal to the electronic control system.
(d) Local events
For Engine and Propeller certification, effects of local events should be assessed.
Whatever the local event, the behaviour of the electronic control system should not cause a
hazard to the aircraft. This will require consideration of effects such as the control of the
thrust reverser deployment, the overspeed of the Engine, transient effects or inadvertent
Propeller pitch change under any flight condition.
When the demonstration that there is no hazard to the aircraft is based on the assumption
that there exists another function to afford the necessary protection, it should be shown that
this function is not rendered inoperative by the same local event (including destruction of
wires, ducts, power supplies).
Such assessment should be reviewed during aircraft certification.
(e) Software and airborne electronic hardware (AEH)
The acceptability of the criticality levels and methods used for the development and
verification of software and AEH which are part of the Engine and Propeller type designs
should have been agreed between the aircraft, Engine and Propeller designers prior to the
certification activity.
Note: In this AMC, the ‘criticality level’ is used to reflect either the software level of a software
item or the AEH design assurance level (or DAL) of an AEH item.
(f) Environmental effects
The validated protection levels for the Engine and Propeller electronic control systems as well
as their emissions of radio frequency energy are established during the Engine and Propeller
certification and are contained in the instructions for installation. For the aircraft
certification, it should be substantiated that these levels are appropriate.
5 INTERRELATION BETWEEN ENGINE, PROPELLER AND AIRCRAFT CERTIFICATION
(a) Objective
To satisfy the aircraft certification specifications, such as CS 25.901, CS 25.903 and
CS 25.1309, an analysis of the consequences of failures of the system on the aircraft has to
be made. It should be ensured that the software/AEH criticality levels and the safety and

AMC 20-1A
reliability objectives for the electronic control system are consistent with these
requirements.
(b) Interface Definition
The interface has to be identified for the AEH and software aspects between the Engine,
Propeller and the aircraft systems in the appropriate documents.
The Engine/Propeller/aircraft documents should cover in particular:
— the software/AEH criticality level (per function if necessary);
— the reliability objectives for a loss of Engine/Propeller control or significant change in
thrust (including an IFSD due to a control system malfunction), or for the transmission
of faulty parameters;
— the degree of protection against lightning or other electromagnetic effects (e.g. the
level of induced voltages that can be supported at the interfaces);
— Engine, Propeller and aircraft interface data and characteristics; and
— the aircraft power supply and its characteristics (if relevant).
(c) Distribution of Compliance Demonstration
The certification tasks of the aircraft propulsion system equipped with electronic control
systems may be shared between the Engine, Propeller and aircraft certification. The
distribution between the different certification activities should be identified and agreed
with EASA and/or the appropriate Engine and aircraft authorities (an example is given in
Section 6 ‘TABLE’).
Appropriate evidence provided for Engine and Propeller certification should be used for
aircraft certification. For example, the quality of any aircraft function software/AEH and
aircraft/Engine/Propeller interface logic already demonstrated for Engine or Propeller
certification should need no additional substantiation for aircraft certification.
Aircraft certification should deal with the specific precautions taken in respect of the physical
and functional interfaces with the Engine/Propeller.
6. TABLE
The following is an example of the distribution of the tasks between the Engine certification and
the aircraft certification. (When necessary, a similar approach should be taken for Propeller
applications.)
SUBSTANTIATION SUBSTANTIATION UNDER CS-25
TASK
UNDER CS-E with Engine data with aircraft data
ENGINE CONTROL — Safety objective — Consideration of
AND PROTECTION common mode
— Software/AEH
effects (including
criticality level
software and AEH)
— Reliability
— Software/AEH
criticality level

AMC 20-1A
SUBSTANTIATION SUBSTANTIATION UNDER CS-25

TASK
UNDER CS-E with Engine data with aircraft data
MONITORING — Independence of — Monitoring — Indication system
control and parameter reliability reliability
monitoring
— Independence
parameters
Engine/Engine
AIRCRAFT DATA — Protection of Engine — Aircraft data reliability

from aircraft data
— Independence
failures
Engine/Engine
— Software/AEH
criticality level
THRUST REVERSER — Software/AEH — System reliability — Safety objectives

CONTROL/ criticality level
— Architecture
MONITORING
— Consideration of
common mode
effects (including
software and AEH)
CONTROL SYSTEM — Reliability or quality — Reliability of quality of

ELECTRICAL SUPPLY Requirement of aircraft supply, if used
aircraft supply, if
— Independence
used
Engine/Engine
ENVIRONMENTAL — Equipment — Declared capability — Aircraft design

CONDITIONS protection
LIGHTNING AND — Equipment — Declared capability — Aircraft wiring

OTHER protection protection and
— Declared emissions
ELECTROMAGNETIC Electromagnetic electromagnetic
EFFECTS emissions compatibility
FIRE PROTECTION — Equipment — Declared capability — Aircraft design

protection
[Amdt 20/2]
[Amdt 20/19]

AMC 20-2B
AMC 20-2B
AMC 20-2B Certification of Essential Auxiliary Power Units (APUs)

Equipped with Electronic Controls
1. GENERAL
The existing certification specifications (CSs) for APU and aircraft certification may require special
interpretation for essential APU equipped with electronic control systems. Because of the nature
of this technology, it has been found necessary to prepare acceptable means of compliance (AMC)
specifically addressing the certification of these electronic control systems.
Like any AMC, the content of this document is not mandatory. It is issued for guidance purposes,
and to outline a method of compliance with the CSs. In lieu of following this method, an alternative
method may be followed, provided that this is agreed by EASA as an acceptable method of
compliance with the CSs.
This document discusses the compliance tasks relating to both the APU and the aircraft certification.
2 RELEVANT SPECIFICATIONS
2.1 APU certification
CS-APU
— Book 1, paragraph 2(c);
— Book 1, Section A, paragraphs 10(b), 20, 80, 90, 210, 220, 280 and 530;
— Book 2, Section A, AMC CS-APU 20.
2.2 Aircraft certification
Aeroplanes: CS-25
— paragraphs 581, 899, 901, 903, 939, 1141, 1163, 1181, 1183, 1189, 1301, 1305,
1307(c), 1309, 1337, 1351(b) and (d), 1353(a) and (b), 1355(c), 1357, 1431, 1461, 1521,
1524, 1527
3 SCOPE
This AMC provides guidance on electronic (analogue and digital) essential APU control systems, on
the interpretation and means of compliance with the relevant APU and aircraft certification
requirements.
It gives guidance on the precautions to be taken for the use of electronic technology for APU
control, protection and monitoring and, where applicable, for integration of functions specific to
the aircraft.
Precautions have to be adapted to the criticality of the functions. These precautions may be
affected by:
— degree of authority of the system;

AMC 20-2B
— phase of flight;
— availability of backup system.
This document also discusses the division of compliance tasks between the APU and the aircraft
certification.
4 PRECAUTIONS
4.1 General
The introduction of electronic technology can entail the following:
(a) greater interdependence of the APU and the aircraft owing to the exchange of
electrical power and/or data between them;
(b) a risk of significant failures which might, for example, occur as a result of:
(i) insufficient protection from electromagnetic disturbance (e.g. lightning, internal
or external radiation effects);
(ii) insufficient integrity of the aircraft electrical power supply;
(iii) insufficient integrity of data supplied from the aircraft;
(iv) hidden design faults or discrepancies contained within the design of the APU
control software/airborne electronic hardware (AEH); or
(v) omissions or errors in the system specification.
Appropriate design and integration precautions must therefore be taken to minimise
these risks.
4.2 Objective
The introduction of electronic control systems should provide for the aircraft at least the
equivalent level of safety, and the related reliability level, as achieved by an essential APU
equipped with hydromechanical control and protection systems.
This objective, when defined during the aircraft/APU certification for a specific application,
will be agreed with EASA.
4.3 Precautions related to APU control, protection and monitoring
The software and AEH associated with the APU control, protection and monitoring functions
must have a criticality level and architecture appropriate to the criticality of the functions
performed.
For digital systems, any residual errors not detected during the software/AEH development
and certification process could cause an unacceptable failure. The latest edition of AMC 20-
115/AMC 20-152 constitutes an acceptable means of compliance for software/AEH
development, verification and software/AEH aspects of certification. The APU software/AEH
criticality level should be determined by the APU and aircraft/system safety assessment
process; ED-79A/ARP4754A and ARP4761 provide guidelines on how to conduct an
aircraft/APU/system safety assessment process.

AMC 20-2B
It should be noted that the software/AEH development assurance methods and disciplines
described in the latest edition of AMC 20-115/AMC 20-152 may not, in themselves, be
sufficient to ensure that the overall system safety and reliability targets have been achieved.
This is particularly true for certain critical systems, such as full authority digital engine control
(FADEC) systems. In such cases, it is accepted that other measures, usually within the system,
in addition to a high level of software/AEH development assurance, may be necessary to
achieve these safety objectives and demonstrate that they have been met.
It is outside the scope of the latest edition of AMC 20-115/AMC 20-152 to suggest or specify
these measures, but in accepting that they may be necessary, it is also the intention to
encourage the development of software/AEH techniques which could support meeting the
overall system safety objectives.
item and the AEH design assurance level (or DAL) of an AEH item.
4.4 Precautions related to APU independence from the aircraft
4.4.1 Precautions related to electrical power supply and data from the aircraft
When considering the objectives of Section 4.2, due consideration must be given to
the reliability of electrical power and data supplied to the electronic controls and
peripheral components. Therefore, the potential adverse effects on APU operation of
any loss of electrical power supply from the aircraft or failure of data coming from the
aircraft must be assessed during the APU certification.
(a) Electrical power
The use of either the aircraft electrical power network or electrical power
sources specific to the APU, or the combination of both, may meet the
objectives.
If the aircraft electrical system supplies power to the APU control system at any
time, the power supply quality, including transients or failures, must not lead to
a situation identified during the APU certification which is considered during the
aircraft certification to be a hazard to the aircraft.
(b) Data
The following cases should be considered:
(i) erroneous data received from the aircraft by the APU control system; and
(ii) control system operating faults propagating via data links.
In certain cases, defects of aircraft input data may be overcome by other data
references specific to the APU in order to meet the objectives.
4.4.2 Local events
(a) In designing an electronic control system to meet the objectives of Section 4.2,
special consideration needs to be given to local events.
Examples of local events include fluid leaks, mechanical disruptions, electrical
problems, fires or overheat conditions. An overheat condition results when the

AMC 20-2B
temperature of the electronic control unit is greater than the maximum safe
design operating temperature declared during the APU certification. This
situation can increase the failure rate of the electronic control system.
(b) Whatever the local event, the behaviour of the electronic control system must
not cause a hazard to the aircraft. This will require consideration of effects such
as the overspeed of the APU.
When the demonstration that there is no hazard to the aircraft is based on the
assumption that there exists another function to afford the necessary
protection, it must be shown that this function is not rendered inoperative by
the same local event (including destruction of wires, ducts, power supplies).
(c) Specific design features or analysis methods may be used to show compliance
with respect to hazardous effects. Where this is not possible, for example due
to the variability or the complexity of the failure sequence, then testing may be
required. These tests must be agreed with EASA.
4.4.3 Lightning and other electromagnetic effects

Electronic control systems are sensitive to lightning and other electromagnetic
interference. The system design must incorporate sufficient protection in order to
ensure the functional integrity of the control system when subjected to designated
levels of electric or electromagnetic inductions, including external radiation effects.
The validated protection levels for the APU electronic control system must be detailed
during the APU certification in an approved document. For aircraft certification, it must
be substantiated that these levels are adequate.
4.5 Other functions integrated into the electronic control system
If functions other than those directly associated with the control of the APU are integrated
into the electronic control system, the APU certification should take into account the
applicable aircraft requirements.
5 INTERRELATION BETWEEN APU CERTIFICATION AND AIRCRAFT CERTIFICATION
5.1 Objective
To satisfy the certification requirements, such as CS 25.901, CS 25.903 and CS 25.1309, an
analysis of the consequences of failures of the system on the aircraft has to be made. It
should be ensured that the software/AEH criticality levels and the safety and reliability
objectives for the electronic control system are consistent with these requirements.
5.2 Interface definition
The interface has to be identified for the AEH and software aspects between the APU and the
aircraft systems in the appropriate documents.
The APU documents should cover in particular:
(a) the software/AEH criticality level (per function if necessary);
(b) the reliability objectives for:

AMC 20-2B
— an APU shutdown in flight;

— a loss of APU control or a significant change in performance; and
— the transmission of faulty parameters;
(c) the degree of protection against lightning or other electromagnetic effects (e.g. the
level of induced voltages that can be supported at the interfaces);
(d) the APU and aircraft interface data and its characteristics; and
(e) the aircraft power supply and its characteristics (if relevant).
5.3 Distribution of compliance demonstrations
The certification of the APU equipped with electronic controls and of the aircraft may be
shared between the APU certification and the aircraft certification. The distribution between
the APU certification and the aircraft certification must be identified and agreed with EASA
and/or the appropriate APU and aircraft authorities (an example is given in the appendix).
Appropriate evidence provided for the APU certification should be used for the aircraft
certification. For example, the quality of any aircraft function software/AEH and aircraft/APU
interface logic already demonstrated for the APU certification should need no additional
substantiation for the aircraft certification.
Aircraft certification must deal with the specific precautions taken in respect of the physical
and functional interfaces with the APU.
[Amdt 20/10]
[Amdt 20/19]

AMC 20-2B
Appendix to AMC 20-2B

The following is an example of the distribution of the tasks between the APU certification and the aircraft
certification.
FUNCTIONS OR
SUBSTANTIATION UNDER
INSTALLATION SUBSTANTIATION UNDER CS-25
CS-APU
CONDITIONS
— Safety objective — Reliability
APU CONTROL AND
— Software/AEH — Software/AEH
PROTECTION
criticality level criticality level
— Independence of — Monitoring — Indication system

MONITORING control and monitoring parameter reliability reliability
parameters
— Protection of APU — Aircraft data

from aircraft data reliability
failures
AIRCRAFT DATA
— Software/AEH
criticality level
— Reliability and
CONTROL SYSTEM quality of aircraft
ELECTRICAL SUPPLY supply if used
ENVIRONMENTAL — Equipment protection — Declared capability — Aircraft design

CONDITIONS, LIGHTNING
— Aircraft wiring
AND OTHER
protection
ELECTROMAGNETIC
EFFECTS
[Amdt 20/19]

AMC 20-3B
AMC 20-3B
AMC 20-3B Certification of Engines Equipped with Electronic Engine

Control Systems
(1) PURPOSE
The existing certification specifications of CS-E for Engine certification may require specific
interpretation for Engines equipped with Electronic Engine Control Systems (EECS), with special
regard to interface with the certification of the aircraft and/or Propeller when applicable. Because
of the nature of this technology, it has been considered useful to prepare acceptable means of
compliance (AMC) specifically addressing the certification of these control systems.
Like any AMC, it is issued to outline issues to be considered during the demonstration of compliance
with CS-E.
(2) SCOPE
This AMC is relevant to Engine certification specifications for EECS, whether they use electrical or
electronic (analogue or digital) technology. This is in addition to other AMC such as AMC E 50 or
AMC E 80.
It gives guidance on the precautions to be taken for the use of electrical and electronic technology
for Engine control, protection, limiting and monitoring functions, and, where applicable, for the
integration of aircraft or Propeller functions. In the latter case, this document is applicable to such
functions integrated into the EECS, but only to the extent that these functions affect compliance
with CS-E specifications.
The text deals mainly with the thrust and power functions of an EECS, since this is the prime function
of the Engine. However, there are many other functions, such as bleed valve control, that may be
integrated into the system for operability reasons. The principles outlined in this AMC apply to the
whole EECS.
This document also discusses the division of compliance tasks for certification between the
applicants for Engine, Propeller (when applicable), and aircraft type certificates. This guidance
relates to issues to be considered during Engine certification. AMC 20-1() addresses issues
associated with the Engine installation in the aircraft.
The introduction of electrical and electronic technology can entail the following:
— greater dependence of the Engine on the aircraft owing to the increased use of electrical
power or data supplied from the aircraft;
— increased integration of control and related indication functions;
— increased risk of significant Failures that are common to more than one Engine of the aircraft
which might, for example, occur as a result of:
— insufficient protection from electromagnetic disturbance (e.g. lightning, internal or
external radiation effects) (see CS-E 50(a)(1), CS E-80 and CS-E 170);
— insufficient integrity of the aircraft electrical power supply (see CS-E 50(h));

AMC 20-3B
— insufficient integrity of data supplied from the aircraft (see CS-E 50(g));
— hidden design Faults or discrepancies contained within the design of the propulsion
system control software or airborne electronic hardware (AEH) (see CS-E 50(f)); or
— omissions or errors in the system/software/AEH specification (see CS-E 50(f)).
Appropriate design and integration precautions should therefore be taken to minimise any adverse
effects from the above.
(3) RELEVANT SPECIFICATIONS AND REFERENCE DOCUMENTS
Although compliance with many CS-E specifications might be affected by the Engine Control
System, the main paragraphs relevant to the certification of the Engine Control System itself are
the following:
CS-E Specification Turbine Engines Piston Engines
CS-E 20 (Engine configuration and interfaces) ✓ ✓
CS-E 25 (Instructions for Continued Airworthiness) ✓ ✓
CS-E 30 (Assumptions) ✓ ✓
CS-E 50 (Engine Control System) ✓ ✓
CS-E 60 (Provision for instruments) ✓ ✓
CS-E 80 (Equipment) ✓ ✓
CS-E 110 (Drawing and marking of parts — Assembly of parts) ✓ ✓
CS-E 130 (Fire prevention) ✓ ✓
CS-E 140 (Tests-Engine configuration) ✓ ✓
CS-E 170 (Engine systems and component verification) ✓ ✓
CS-E 210 (Failure analysis) ✓
CS-E 250 (Fuel System) ✓
CS-E 390 (Acceleration tests) ✓
CS-E 500 (Functioning) ✓
CS-E-510 (Safety analysis) ✓
CS-E 560 (Fuel system) ✓
CS-E 745 (Engine Acceleration) ✓
CS-E 1030 (Time-limited dispatch) ✓ ✓
The following documents are referenced in AMC 20-3B:

— International Electrotechnical Commission (IEC), Central Office, 3, rue de Varembé, P.O. Box
131, CH - 1211 GENEVA 20, Switzerland
— IEC/PAS 62239, Electronic Component Management Plans, edition 1.0, dated April
2001
— IEC/PAS 62240, Use of Semiconductor Devices Outside Manufacturers’ Specified
Temperature Ranges, edition 1.0, dated April 2001
— RTCA, Inc. 1828 L Street, NW, Suite 805, Washington, DC 20036 or EUROCAE, 17, rue Hamelin,
75116 Paris, France

AMC 20-3B
— RTCA DO-254/ EUROCAE ED-80, Design Assurance Guidance for Airborne Electronic
Hardware, dated April 19, 2000
— RTCA DO-160/EUROCAE ED 14, Environmental Conditions and Test Procedures for
Airborne Equipment
— AMC 20-115 on software considerations for certification of airborne systems and equipment
— Aeronautical Systems Center, ASC/ENOI, Bldg 560, 2530 Loop Road West, Wright-Patterson
AFB, OH, USA, 45433-7101
— MIL-STD-461E, Requirements for the Control of Electromagnetic Interference
Characteristics, dated August 20, 1999
— MIL-STD-810 E or F, Test Method Standard for Environmental Engineering, E dated July
14, 1989, F dated January 1, 2000
— U.S. Department of Transportation, Subsequent Distribution, Office Ardmore East Business
Center, 3341 Q 75th Ave, Landover, MD, USA, 20785
— AC 20-136, Protection of Aircraft Electrical/Electronic Systems Against the Indirect
Effects of Lightning, dated March 5, 1990
— Society of Automotive Engineers (SAE), 400 Commonwealth Drive, Warrendale, PA 15096-
0001 USA or EUROCAE, 17, rue Hamelin, 75116 Paris, France
— SAE ARP 5412 / EUROCAE ED-84, with Amendment 1 & 2, Aircraft Lightning
Environment and Related Test Waveforms, February 2005/May 2001 respectively
— SAE ARP 5413 / EUROCAE ED-81, with Amendment 1, Certification of Aircraft
Electrical/Electronic Systems for the Indirect Effects of Lightning, November
1999/August 1999 respectively
— SAE ARP 5414 / EUROCAE ED-91, with Amendment 1, Aircraft Lightning Zoning,
February 2005/June 1999 respectively
— SAE ARP 5416 / EUROCAE ED-105, Aircraft Lightning Test Methods, March 2005/April
2005 respectively
(4) DEFINITIONS
The words defined in CS-Definitions and in CS-E 15 are identified by capital letters.
The following figure and associated definitions are provided to facilitate a clear understanding of
the terms used in this AMC.

AMC 20-3B
DEFINITIONS VISUALISED
SYSTEMS MODES
ENGINE CONTROL SYSTEM
PRIMARY MODE /
Primary system
NORMAL MODE
May be one or more ALTERNATE MODES

lanes (channels)
ALTERNATE MODE 1
Lanes typically have

equal functionality ALTERNATE MODE 2
Backup system
BACKUP MODE 1
May be hydromechanical
control or less capable lane
BACKUP MODE 2
(5) GENERAL
It is recognised that the determination of compliance of the Engine Control System with the
applicable aircraft certification specifications will only be made during the aircraft certification.
In the case where the installation is unknown at the time of Engine certification, the applicant for
Engine certification should make reasonable installation and operational assumptions for the target
installation. Any installation limitations or operational issues will be noted in the instructions for
installation or operation, and/or the Type Certificate Data Sheet (TCDS) (see CS-E 30 Assumptions).
When possible, early coordination between the Engine and the aircraft applicants is recommended
in association with the relevant authorities as discussed under Section 15 of this AMC.
(6) SYSTEM DESIGN AND VALIDATION
(a) Control Modes — General
Under CS-E 50(a), the applicant should perform all necessary testing and analysis to ensure
that all Control Modes, including those which occur as a result of control Fault
Accommodation strategies, are implemented as required.
The need to provide protective functions, such as overspeed protection, for all Control
Modes, including any Alternate Modes, should be reviewed under the specifications of CS-E
50(c), (d) and (e), and CS-E 210 or CS-E 510.

AMC 20-3B
Any limitations on operations in Alternate Modes should be clearly stated in the Engine
instructions for installation and operation.
Descriptions of the functioning of the Engine Control System operating in its Primary and any
Alternate Modes should be provided in the Engine instructions for installation and operation.
Analyses and/or testing are necessary to substantiate that operating in the Alternate Modes
has no unacceptable effect on Engine durability or endurance. Demonstration of the
durability and reliability of the control system in all modes is primarily addressed by the
component testing of CS-E 170. Performing some portion of the Engine certification testing
in the Alternate Mode(s) and during transition between modes can be used as part of the
system validation required under CS-E 50(a).
(i) Engine Test Considerations
If the Engine certification tests defined in CS-E are performed using only the Engine
Control System’s Primary Mode in the Full-up Configuration and if approval for
dispatch in the Alternate Mode is requested by the applicant under CS-E 1030, it should
be demonstrated, by analysis and/or test, that the Engine can meet the defined test-
success criteria when operating in any Alternate Mode that is proposed as a
dispatchable configuration as required by CS-E 1030.
Some capabilities, such as operability, blade-off, rain, hail, bird ingestion, etc., may be
lost in some control modes that are not dispatchable. These modes do not require
engine test demonstration as long as the installation and operating instructions reflect
this loss of capability.
(ii) Availability
Availability of any Back-up Mode should be established by routine testing or
monitoring to ensure that the Back-up Mode will be available when needed. The
frequency of establishing its availability should be documented in the Instructions for
Continued Airworthiness (ICA).
(b) Crew Training Modes
This AMC is not specifically intended to apply to any crew training modes. These modes are
usually installation-, and possibly operator-, specific and need to be negotiated on a case-by-
case basis. As an example, one common application of crew training modes is for simulation
of the ‘failed-fixed’ mode on a twin-engine rotorcraft. Training modes should be described in
the Engine instructions for installation and operation as appropriate. Also, precautions
should be taken in the design of the Engine Control System and its crew interfaces to prevent
inadvertent entry into any training modes. Crew training modes, including lock-out systems,
should be assessed as part of the System Safety Analysis (SSA) of CS-E 50(d).
(c) Non-Dispatchable Configurations and Modes
For control configurations which are not dispatchable, but for which the applicant seeks to
take credit in the system Loss of Thrust (or Power) Control (LOTC/LOPC) analysis, it may be
acceptable to have specific operating limitations. In addition, compliance with CS-E 50(a)
does not imply strict compliance with the operability specifications of CS-E 390, CS-E 500 and
CS-E 745 in these non-dispatchable configurations, if it can be demonstrated that, in the
intended installation, no likely pilot control system inputs will result in Engine surge, stall,

AMC 20-3B
flame-out or unmanageable delay in power recovery. For example, in a twin-engine

rotorcraft, a rudimentary Backup System may be adequate since frequent and rapid changes
in power setting with the Backup System may not be necessary.
In addition to these operability considerations, other factors which should be considered in
assessing the acceptability of such reduced-capability Backup Modes include:
— the installed operating characteristics of the Back-up Mode and the differences from
the Primary Mode;
— the likely impact of the Back-up Mode operations on pilot workload, if the aircraft
installation is known;
— — the frequency of transfer from the Primary Mode to the Back-up Mode (i.e. the
reliability of the Primary Mode); frequencies of transfer of less than 1 per 20 000
engine flight hours have been considered acceptable.
(d) Control Transitions
The intent of CS-E 50(b) is to ensure that any control transitions, which occur as a result of
Fault Accommodation, occur in an acceptable manner.
In general, transition to Alternate Modes should be accomplished automatically by the
Engine Control System. However, systems for which pilot action is required to engage the
Backup Mode may also be acceptable. For instance, a Fault in the Primary System may result
in a ‘failed-fixed’ fuel flow and some action is required by the pilot to engage the Backup
System in order to modulate Engine power. Care should be taken to ensure that any reliance
on manual transition is not expected to pose an unacceptable operating characteristic,
unacceptable crew workload or require exceptional skill.
The transient change in power or thrust associated with transfer to Alternate Modes should
be reviewed for compliance with CS-E 50(b). If available, input from the installer should be
considered. Although this is not to be considered a complete list, some of the items that
should be considered when reviewing the acceptability of Control Mode transitions are:
— The frequency of occurrence of transfers to any Alternate Mode and the capability of
the Alternate Mode. Computed frequency-of-transfer rates should be supported with
data from endurance or reliability testing, in-service experience on similar equipment,
or other appropriate data.
— The magnitude of the power, thrust, rotor or Propeller speed transients.
— Successful demonstration, by simulation or other means, of the ability of the Engine
Control System to control the Engine safely during the transition. In some cases,
particularly those involving rotorcraft, it may not be possible to make a determination
that the mode transition provides a safe system based solely on analytical or simulation
data. Therefore, a flight test programme to support this data will normally be expected.
— An analysis should be provided to identify those Faults that cause Control Mode
transitions either automatically or through pilot action.
— For turboprop or turboshaft engines, the transition should not result in excessive
overspeed or underspeed of the rotor or Propeller which could cause emergency
shutdown, loss of electrical generator power or the setting-off of warning devices.

AMC 20-3B
The thrust or power change associated with the transition should be declared in the
instructions for installing the Engine.
(i) Time Delays
Any observable time delays associated with Control Mode, channel or system
transitions or in re-establishing the pilot’s ability to modulate Engine thrust or power
should be identified in the Engine instructions for installation and operation (see CS-E
50(b)). These delays should be assessed during aircraft certification.
(ii) Annunciation to the Flight Crew
If annunciation is necessary to comply with CS-E 50(b)(3), the type of annunciation to
the flight crew should be commensurate with the nature of the transition. For instance,
reversion to an Alternate Mode of control where the transition is automatic and the
only observable changes in operation of the Engine are different thrust control
schedules, would require a very different form of annunciation to that required if
timely action by the pilot is required in order to maintain control of the aircraft.
The intent and purpose of the cockpit annunciation should be clearly stated in the
Engine instructions for installation and operation, as appropriate.
(e) Environmental conditions
Environmental conditions include electromagnetic interference (EMI), high-intensity
radiated fields (HIRF) and lightning. The environmental conditions are addressed under CS-
E 80 and CS-E 170. The following provides additional guidance for EMI, HIRF and lightning.
(i) Declared levels
When the installation is known during the Engine type-certification programme, the
Engine Control System should be tested at levels that have been determined and
agreed by the Engine and aircraft applicants. It is assumed that, by this agreement, the
installation can meet the aircraft certification specifications. Successful completion of
the testing to the agreed levels would be accepted for Engine type certification. This,
however, may make the possibility of installing the Engine dependent on a specific
aircraft.
If the aircraft installation is not known or defined at the time of the Engine certification,
in order to determine the levels to be declared for the Engine certification, the Engine
applicant may use the external threat level defined at the aircraft level and use
assumptions on installation attenuation effects.
If none of the options defined above are available, it is recommended that the
procedures and minimum default levels for HIRF testing should be agreed with EASA.
(ii) Test procedures
(A) General
The installed Engine Control System, including representative
Engine–aircraft interface cables, should be the basis for certification testing.
EMI test procedures and test levels conducted in accordance with MIL-STD-461
or EUROCAE ED 14/DO-160 have been considered acceptable.

AMC 20-3B
The applicant should use the HIRF test guidelines provided in EUROCAE ED
14/RTCA DO-160 or equivalent. However, it should be recognised that the tests
defined in EUROCAE ED 14/RTCA DO-160 are applicable at a component test
level, requiring the applicant to adapt these test procedures to a system level
HIRF test to demonstrate compliance with CS-E 80 and CS-E 170.
For lightning tests, the guidelines of SAE ARP 5412, 5413, 5414 and 5416, and
EUROCAE ED 14/RTCA DO-160 would be applicable.
Pin Injection Tests (PIT) are normally conducted as component tests on the EECS
unit and other system components as required. PIT levels are selected as
appropriate from the tables of EUROCAE ED 14/DO-160.
Environmental tests, such as MIL-STD-810, may be accepted in lieu of EUROCAE
ED-14/DO-160 tests where these tests are equal to or more rigorous than those
defined in EUROCAE ED 14/DO-160.
(B) Open-loop and Closed-loop Testing
HIRF and lightning tests should be conducted as system tests on closed-loop or
open-loop laboratory set-ups.
The closed-loop set-up is usually provided with hydraulic pressure to move
actuators to close the inner actuating loops. A simplified Engine simulation may
be used to close the outer Engine loop.
Testing should be conducted with the Engine Control System controlling at the
most sensitive operating point, as selected and detailed in the test plans by the
applicant. The system should be exposed to the HIRF and lightning
environmental threats while operating at the selected condition. There may be
a different operating point for HIRF and lightning environmental threats.
For tests in open- and closed-loop set-ups, the following factors should also be
considered:
— If a special EECS test software is used, that software should be developed
at the criticality level determined by the Engine safety assessment
process.
— The Engine Control System should be tested at the criticality levels that
have been determined and agreed by the Engine and aircraft applicants.
It is assumed that by this agreement, the installation meets the aircraft
certification specifications. In some cases, the application code is modified
to include the required test code features.
— The system test set-up should be capable of monitoring both the output
signals and the input signals.
— Anomalies observed during open-loop testing on inputs or outputs should
be duplicated on the Engine simulation to determine whether the
resulting power or thrust perturbations comply with the pass–fail criteria.
(iii) Pass–Fail Criteria

AMC 20-3B
The pass–fail criteria of CS-E 170 for HIRF and lightning should be interpreted as ‘no
adverse effect’ on the functionality of the system.
The following are considered adverse effects:
— a greater than 3 % change of Take-off Power or Thrust for a period of more than
2 seconds;
— transfers to Alternate Channels, Backup Systems, or Alternate Modes;
— component damage;
— false annunciation to the flight crew, which could cause unnecessary or
inappropriate flight crew action;
— erroneous operation of protection systems, such as overspeed or thrust reverser
circuits.
AEH or software design changes implemented after the initial environmental testing
should be evaluated for their effects with respect to the EMI, HIRF and lightning
environment.
(iv) Maintenance Actions
CS-E 25 requires that the applicant prepare Instructions for Continued Airworthiness
(ICA). These include a maintenance plan. Therefore, for any protection system that is
part of the type design of the Engine Control System and is required by the system to
meet the qualified levels of EMI, HIRF and lightning, a maintenance plan should be
provided to ensure the continued airworthiness for the parts of the installed system
which are supplied by the Engine type-certificate holder.
The maintenance actions to be considered include periodic inspections or tests for
required structural shielding, wire shields, connectors, and equipment protection
components. Inspections or tests when the part is exposed may also be considered.
The applicant should provide the engineering validation and substantiation of these
maintenance actions.
(v) Time-Limited Dispatch (TLD) Environmental Tests
Although TLD is only an optional requirement for certification (see CS-E 1000 and CS-E
1030), EMI, HIRF and lightning tests for TLD are usually conducted together with tests
conducted for certification. Acceptable means of compliance are provided in AMC E
1030.
(7) INTEGRITY OF THE ENGINE CONTROL SYSTEM
(a) Objective
The intent of CS-E 50(c) is to establish Engine Control System integrity requirements
consistent with operational requirements of the various installations. (See also paragraph (4)
of AMC E 50).
(b) Definition of an LOTC/LOPC event
(i) For turbine Engines intended for CS-25 installations

AMC 20-3B
An LOTC/LOPC event is defined as an event where the Engine Control System:

— has lost the capability of modulating thrust or power between idle and 90% of
maximum rated power or thrust, or
— suffers a Fault which results in a thrust or power oscillation greater than the
levels given in paragraph (7)(c) of this AMC, or
— has lost the capability to govern the Engine in a manner which allows compliance
with the operability specifications given in CS-E 500(a) and CS-E 745.
(ii) For turbine Engines intended for rotorcraft
An LOPC event is defined as an event where the Engine Control System:
— has lost the capability of modulating power between idle and 90% of maximum
rated power at the flight condition, except OEI power ratings, or
— suffers a Fault which results in a power oscillation greater than the levels given
in paragraph (7)(c) of this AMC, or
with the operability specifications given in CS-E 500(a) and CS-E 745, with the
exception that the inability to meet the operability specifications in the Alternate
Modes may not be included as LOPC events.
— Single Engine rotorcraft will be required to meet the operability specifications in
the Alternate Mode(s), unless the lack of this capability is demonstrated to be
acceptable at the aircraft level. Engine operability in the Alternate Mode(s) is
considered a necessity if:
— the control transitions to the Alternate Mode more frequently than the
acceptable LOPC rate, or
— normal flight crew activity requires rapid changes in power to safely fly the
aircraft.
— For multi-Engine rotorcraft, the LOPC definition may not need to include the
inability to meet the operability specifications in the Alternate Mode(s). This may
be considered acceptable because when one Engine control transitions to an
Alternate Mode, which may not have robust operability, that Engine can be left
at reasonably fixed power conditions. The Engine(s) with the normally operating
control(s) can change power – as necessary – to complete aircraft manoeuvres
and safely land the aircraft. Demonstration of the acceptability of this type of
operation may be required at aircraft certification.
(iii) For turbine Engines intended for other installations
A LOTC/LOPC event is defined as an event where the Engine Control System:
— has lost the capability of modulating thrust or power between idle and 90% of
maximum rated power or thrust, or
— suffers a Fault which results in a thrust or power oscillation that would impact
controllability in the intended installation, or

AMC 20-3B
with the operability specifications given in CS-E 500(a) and CS-E 745, as
appropriate.
(iv) For piston Engines
An LOPC event is defined as an event where the Engine Control System:
— has lost the capability of modulating power between idle and 85% of maximum
rated power at all operating conditions, or
— suffers a Fault which results in a power oscillation greater than the levels given
in paragraph (7)(c) of this AMC, or
— — has lost the capability to govern the Engine in a manner which allows
compliance with the operability specifications given in CS-E 390.
(v) For engines incorporating functions for Propeller control integrated in the EECS
The following Faults or Failures should be considered as additional LOPC events:
— inability to command a change in pitch,
— uncommanded change in pitch,
— — uncontrollable Propeller torque or speed fluctuation.
(c) Uncommanded thrust or power oscillations
Any uncommanded thrust or power oscillations should be of such a magnitude as not to
impact aircraft controllability in the intended installation. Thrust or power oscillations less
than 10% peak to peak of Take-off Power and/or Thrust have been considered acceptable in
some installations, where the failure affects one engine only. Regardless of the levels
discussed herein, if the flight crew has to shut down an Engine because of unacceptable
thrust or power oscillations caused by the control system, such an event would be deemed
an in-service LOTC/LOPC event.
(d) Acceptable LOTC/LOPC rate
The applicant may propose an LOTC/LOPC rate other than those below. Such a proposal
should be substantiated in relation to the criticality of the Engine and control system relative
to the intended installation. The intent is to show equivalence of the LOTC/LOPC rate to
existing systems in comparable installations.
(i) For turbine Engines
The EECS should not cause more than one LOTC/LOPC event per 100 000 engine flight
hours.
(ii) For piston Engines
An LOPC rate of 45 per million engine flight hours (or 1 per 22,222 engine flight hours)
has been shown to represent an acceptable level for the most complex EECS. As a
result of the architectures used in many of the EECS for these engines, the functions
are implemented in independent system elements. These system elements or sub-
systems can be fuel control, or ignition control, or others. If a system were to contain

AMC 20-3B
only one element such as fuel control, then the appropriate total system level would
be 15 LOPC events per million engine flight hours. So the system elements are then
additive up to a max of 45 LOPC events per million hours. For example, an EEC system
comprised of fuel, ignition, and wastegate control functions should meet a total system
reliability of 15+15+15 = 45 LOPC events per million engine flight hours. This criterion
is then applied to the entire system and not allocated to each of the subsystems. Note
that a maximum of 45 LOPC events per million engine flight hours are allowed,
regardless of the number of subsystems. For example, if the EEC system includes more
than three subsystems, the sum of the LOPC rates for the total system should not
exceed 45 LOPC events per million engine flight hours for all of the electrical and
electronic elements.
(e) LOTC/LOPC Analysis
A system reliability analysis should be submitted to substantiate the agreed LOTC/LOPC rate
for the Engine Control System. A numerical analysis such as a Markov model analysis, fault
tree analysis or equivalent analytical approach is expected.
The analysis should address all components in the system that can contribute to LOTC/LOPC
events. This includes all electrical, mechanical, hydromechanical, and pneumatic elements of
the Engine Control System. This LOTC/LOPC analysis should be done in conjunction with the
System Safety Assessment required under CS-E 50(d). Paragraph (8) of this AMC provides
additional guidance material.
The engine fuel pump is generally not included in the definition of the Engine Control System.
It is usually considered part of the fuel delivery system.
The LOTC/LOPC analysis should include those sensors or elements which may not be part of
the Engine type design, but which may contribute to LOTC/LOPC events. An example of this
is the throttle or power lever transducer, which is usually supplied by the installer. The effects
of loss, corruption or Failure of Aircraft-Supplied Data should be included in the Engine
Control System’s LOTC/LOPC analysis. The reliability and interface requirements for these
non-Engine type design elements should be contained in the Engine instructions for
installation. It needs to be ensured that there is no double counting of the rate of Failure of
non-engine parts within the aircraft system safety analyses.
The LOTC/LOPC analysis should consider all Faults, both detected and undetected. Any
periodic maintenance actions needed to find and repair both Covered and Uncovered Faults,
in order to meet the LOTC/LOPC rate, should be contained in the Engine instructions for
continued airworthiness.
(f) Commercial or Industrial Grade Electronic Parts
When the Engine type design specifies commercial or industrial grade electronic
components, which are parts not manufactured to military standards, the applicant should
have the following data available for review, as applicable:
— Reliability data that substantiates the Failure rate for each component used in the
LOTC/LOPC analysis and the SSA for each commercial and industrial grade electrical
component specified in the design.

AMC 20-3B
— The applicant’s procurement, quality assurance, and process control plans for the
vendor-supplied commercial and industrial grade parts. These plans should ensure that
the parts will be able to maintain the reliability level specified in the approved Engine
type design.
— Unique databases for similar components obtained from different vendors, because
commercial and industrial grade parts may not all be manufactured to the same
accepted industry standard, such as military component standards.
— Commercial and industrial grade parts have typical operating ranges of 0 degrees to
+70 degrees Celsius and -40 degrees to +85 degrees Celsius, respectively. Military
grade parts are typically rated at -54 degrees to 125 degrees Celsius. Commercial and
industrial grade parts are typically defined in these temperature ranges in vendor parts
catalogues. If the declared temperature environment for the Engine Control System
exceeds the stated capability of the commercial or industrial grade electronic
components, the applicant should substantiate that the proposed extended range of
the specified components is suitable for the installation and that the Failure rates used
for those components in the SSA and LOTC/LOPC analyses is appropriately adjusted for
the extended temperature environment. Additionally, if commercial or industrial parts
are used in an environment beyond their specified rating and cooling provisions are
required in the design of the EECS, the applicant should specify these provisions in the
instructions for installation to ensure that the provisions for cooling are not
compromised. Failure modes of the cooling provisions included in the EECS design that
cause these limits to be exceeded should be considered in determining the probability
of Failure.
— Two examples of industry published documents which provide guidance on the
application of commercial or industrial grade components are:
— IEC/PAS 62239, Electronic Component Management Plans
— IEC/PAS 62240, Use of Semiconductor Devices Outside Manufacturers’ Specified
Temperature Ranges
When any electrical or electronic components are changed, the SSA and LOTC/LOPC analyses
should be reviewed with regard to the impact of any changes in component reliability.
Component, subassembly or assembly level testing may be required by the Agency to
substantiate a change that introduces a commercial or industrial part(s). However, such a
change would not be classified as ‘significant’ with respect to Part 21.A.101(b)1.
(g) Single Fault Accommodation
Compliance with the single Fault specifications of CS-E 50(c)(2) and (3) may be substantiated
by a combination of tests and analyses. The intent is that single Failures or malfunctions in
the Engine Control System’s components, in its fully operational condition, do not result in a
Hazardous Engine Effect. In addition, in its full-up configuration the control system should be
essentially single Fault tolerant of electrical/electronic component Failures with respect to
LOTC/LOPC events. For dispatchable configurations refer to CS-E 1030 and AMC E 1030.
It is recognised that to achieve true single Fault tolerance for LOTC/LOPC events could require
a triplicated design approach or a design approach with 100% Fault detection. Currently,

AMC 20-3B
systems have been designed with dual, redundant channels or with Back-up Systems that
provide what has been called an "essentially single Fault tolerant" system. Although these
systems may have some Faults that are not Covered Faults, they have demonstrated
excellent in-service safety and reliability, and have proven to be acceptable.
The objective, of course, is to have all the Faults addressed as Covered Faults. Indeed, the
dual channel or Back-up system configurations do cover the vast majority of potential
electrical and electronic Faults. However, on a case-by-case basis, it may be appropriate for
the applicant to omit some coverage because detection or accommodation of some
electrical/electronic Faults may not be practical. In these cases, it is recognised that single,
simple electrical or electronic components or circuits can be employed in a reliable manner,
and that requiring redundancy in some situations may not be appropriate. In these
circumstances, Failures in some single electrical or electronic components, elements or
circuits may result in an LOTC/LOPC event. This is what is meant by the use of the term
“essentially”, and such a system may be acceptable.
(h) Local Events
Examples of local events to be considered under CS-E 50(c)(4) include:
— Overheat conditions, for example, those resulting from hot air duct bursts,
— Fires, and
— Fluid leaks or mechanical disruptions which could lead to damage to control system
electrical harnesses, connectors, or the control unit(s).
These local events would normally be limited to one Engine. Therefore, a local event is not
usually considered to be a common mode event, and common mode threats, such as HIRF,
lightning and rain, are not considered local events.
When demonstration that there is no Hazardous Engine Effect is based on the assumption
that another function exists to afford the necessary protection, it should be shown that this
function is not rendered inoperative by the same local event on the Engine (including
destruction of wires, ducts, power supplies).
It is considered that an overheat condition exists when the temperature of the system
components is greater than the maximum safe design operating temperature for the
components, as declared by the Engine applicant in the Engine instructions for installation.
The Engine Control System should not cause a Hazardous Engine Effect when the
components or units of the system are exposed to an overheat or over-temperature
condition. Specific design features or analysis methods may be used to show compliance with
respect to the prevention of Hazardous Engine Effects. Where this is not possible, for
example, due to the variability or the complexity of the Failure sequence, then testing may
be required.
The Engine Control System, including the electrical, electronic and mechanical parts of the
system, should comply with the fire specifications of CS-E 130 and the interpretative material
of AMC E 130 is relevant. This rule applies to the elements of the Engine Control System which
are installed in designated fire zones.
There is no probability associated with CS-E 50(c)(4). Hence, all foreseeable local events
should be considered. It is recognised, however, that it is difficult to address all possible local

AMC 20-3B
events in the intended aircraft installation at the time of Engine certification. Therefore,
sound Engineering judgement should be applied in order to identify the reasonably
foreseeable local events. Compliance with this specification may be shown by considering
the end result of the local event on the Engine Control System. The local events analysed
should be well documented to aid in certification of the Engine installation.
The following guidance applies to Engine Control System wiring:
— Each wire or combination of wires interfacing with the EECS that could be affected by
a local event should be tested or analysed with respect to local events. The assessment
should include opens, shorts to ground and shorts to power (when appropriate) and
the results should show that Faults result in identified responses and do not result in
Hazardous Engine Effects.
— Engine control unit aircraft interface wiring should be tested or analysed for shorts to
aircraft power, and these “hot” shorts should result in an identified and non-Hazardous
Engine Effect. Where aircraft interface wiring is involved, the installer should be
informed of the potential effects of interface wiring Faults by means of information
provided in the Engine instructions for installation. It is the installer’s responsibility to
ensure that there are no wiring Faults which could affect more than one Engine. Where
practical, wiring Faults should not affect more than one channel. Any assumptions
made by the Engine applicant regarding channel separation should be included in the
LOTC/LOPC analysis.
— Where physical separation of conductors is not practical, co-ordination between the
Engine applicant and the installer should ensure that the potential for common mode
Faults between Engine Control Systems is eliminated, and between channels on one
Engine is minimised.
The applicant should assess by analysis or test the effects of fluid leaks impinging on
components of the Electronic Engine Control System. Such conditions should not result in a
Hazardous Engine Effect, nor should the fluids be allowed to impinge on circuitry or printed
circuit boards and result in a potential latent Failure condition.
(8) SYSTEM SAFETY ASSESSMENT
(a) Scope of the assessment
The system safety assessment (SSA) required under CS-E 50(d) should address all operating
modes, and the data used in the SSA should be substantiated.
The LOTC/LOPC analysis described in Section 7 is a subset of the SSA. The LOTC/LOPC analysis
and SSA may be separate or combined as a single analysis.
The SSA should consider all Faults, both detected and undetected, and their effects on the
Engine Control System and the Engine itself. The intent is primarily to address the Faults or
malfunctions which only affect one Engine Control System, and therefore only one Engine.
However, Faults or malfunctions in aircraft signals, including those in a multi-engine
installation that could affect more than one Engine, should also be included in the SSA; these
types of Faults are addressed under CS-E 50(g).
The Engine Control System SSA and LOTC/LOPC analysis, or combined analyses, should
identify the applicable assumptions and installation requirements and establish any

AMC 20-3B
limitations relating to Engine Control System operation. These assumptions, requirements,

and limitations should be stated in the Engine instructions for installation and operation as
appropriate. If necessary, the limitations should be contained in the airworthiness limitations
section of the instructions for continued airworthiness in accordance with CS-E 25(b)(1).
The SSA should address all Failure effects identified under CS-E 510 or CS-E 210, as
appropriate. A summary should be provided, listing the malfunctions or Failures and their
effects caused by the Engine Control System, such as:
— Failures affecting power or thrust resulting in LOTC/LOPC events.
— Failures which result in the Engine’s inability to meet the operability specifications. If
these Failure cases are not considered as LOPC events according to paragraph (7)(b)(ii)
of this AMC, the expected frequency of occurrence for these events should be
documented.
— Transmission of erroneous parameters which could lead to thrust or power changes
greater than 3% of Take-off Power or Thrust (10% for piston engines installations) (e.g.,
false high indication of the thrust or power setting parameter) or to Engine shutdown
(e.g., high EGT or turbine temperatures or low oil pressure).
— Failures affecting functions included in the Engine Control System, which may be
considered aircraft functions (e.g. Propeller control, thrust reverser control, control of
cooling air, control of fuel recirculation)
— Failures resulting in Major Engine Effects and Hazardous Engine Effects.
The SSA should also consider all signals used by the Engine Control System, in particular any
cross-Engine control signals and air signals as described in CS-E 50(i).
The criticality of functions included in the Engine Control System for aircraft level functions
needs to be defined by the aircraft applicant.
(b) Criteria
The SSA should demonstrate or provide the following:
(i) Compliance with CS-E 510 or CS-E 210, as appropriate.
(ii) For Failures leading to LOTC/LOPC events, compliance with the agreed LOTC/LOPC rate
for the intended installation (see paragraph (7)(d) of this AMC).
(iii) For Failures affecting Engine operability but not leading to LOPC events, compliance
with the expected total frequency of occurrence of Failures that result in Engine
response that is non-compliant with CS-E 390, CS-E 500(a) and CS-E 745 specifications
(as appropriate). The acceptability of the frequency of occurrence for these events -
along with any aircraft flight deck indications deemed necessary to inform the flight
crew of such a condition - will be determined at aircraft certification.
(iv) The consequence of the transmission of a faulty parameter
The consequence of the transmission of a faulty parameter by the Engine Control
System should be identified and included, as appropriate, in the LOTC/LOPC analysis.
Any information necessary to mitigate the consequence of a faulty parameter
transmission should be contained in the Engine operating instructions.

AMC 20-3B
For example, the Engine operating instructions may indicate that a display of zero oil
pressure be ignored in-flight if the oil quantity and temperature displays appear
normal. In this situation, Failure to transmit oil pressure or transmitting a zero oil
pressure signal should not lead to an Engine shutdown or LOTC/LOPC event.
Admittedly, flight crew initiated shutdowns have occurred in-service during such
conditions. In this regard, if the Engine operating instructions provide information to
mitigate the condition, then control system Faults or malfunctions leading to the
condition do not have to be included in the LOTC/LOPC analysis. In such a situation,
the loss of multiple functions should be included in the LOTC/LOPC analysis. If the
display of zero oil pressure and zero oil quantity (or high oil temperature) would result
in a crew initiated shutdown, then those conditions should be included in the systems
LOTC/LOPC analysis.
(c) Malfunctions or Faults affecting thrust or power
In multi-engine aeroplanes, Faults that result in thrust or power changes of less than
approximately 10% of Take-off Power or Thrust may be undetectable by the flight crew. This
level is based on pilot assessment and has been in use for a number of years. The pilots
indicated that flight crews will note the Engine operating differences when the difference is
greater than 10% in asymmetric thrust or power.
The detectable difference level for Engines for other installations should be agreed with the
installer.
When operating in the take-off envelope, Uncovered Faults in the Engine Control System
which result in a thrust or power change of less than 3% (10% for piston engines installations),
are generally considered acceptable. However, this does not detract from the applicant’s
obligation to ensure that the full-up system is capable of providing the declared minimum
rated thrust or power. In this regard, Faults which could result in small thrust changes should
be random in nature and detectable and correctable during routine inspections, overhauls or
power-checks.
The frequency of occurrence of Uncovered Faults that result in a thrust or power change
greater than 3% of Take-off Power or Thrust, but less than the change defined as an
LOTC/LOPC event, should be contained in the SSA documentation. There are no firm
specifications relating to this class of Faults for Engine certification; however the rate of
occurrence of these types of Faults should be reasonably low, in the order of 10-4 events per
Engine flight hour or less. These Faults may be required to be included in aircraft certification
analysis.
Signals sent from one Engine Control System to another in an aeroplane installation, such as
signals used for an Automatic Take-off Thrust Control System (ATTCS), synchrophasing, etc.,
are addressed under CS-E 50(g). They should be limited in authority by the receiving Engine
Control System, so that undetected Faults do not result in an unacceptable change in thrust
or power on the Engine using those signals. The maximum thrust or power loss on the Engine
using a cross-Engine signal should generally be limited to 3% absolute difference of the
current operating condition.
Note: It is recognised that ATTCS, when activated, may command a thrust or power increase
of 10% or more on the remaining Engine(s). It is also recognised that signals sent from one

AMC 20-3B
Engine control to another in a rotorcraft installation, such as load sharing and One Engine
Inoperative (OEI), can have a much greater impact on Engine power when those signals fail.
Data of these Failure modes should be contained in the SSA.
When operating in the take-off envelope, detected Faults in the Engine Control System,
which result in a thrust or power change of up to 10% (15% for piston engines) may be
acceptable if the total frequency of occurrence for these types of Failures is relatively low.
The predicted frequency of occurrence for this category of Faults should be contained in SSA
documentation. It should be noted that requirements for the allowable frequency of
occurrence for this category of Faults and any need for a flight deck indication of these
conditions would be reviewed during aircraft certification. A total frequency of occurrence in
excess of 10–4 events per Engine flight hour would not normally be acceptable.
Detected Faults in signals exchanged between Engine Control Systems should be
accommodated so as not to result in greater than a 3% thrust or power change on the Engine
using the cross-Engine signals.
(9) PROTECTIVE FUNCTIONS
(a) Rotor Over-speed Protection.
Rotor over-speed protection is usually achieved by providing an independent over-speed
protection system, such that it requires two independent Faults or malfunctions (as
described below) to result in an uncontrolled over-speed.
The following guidance applies if the rotor over-speed protection is provided solely by an
Engine Control System protective function.
For dispatchable configurations, refer to CS-E 1030 and AMC E 1030.
The SSA should show that the probability per Engine flight hour of an uncontrolled over-
speed condition from any cause in combination with a Failure of the over-speed protection
system to function is less than one event per hundred million hours (a Failure rate of 10–8
events per Engine flight hour).
The over-speed protection system would be expected to have a Failure rate of less than 10–
4 Failures per engine flight hour to ensure the integrity of the protected function.
A self-test of the over-speed protection system to ensure its functionality prior to each flight
is normally necessary for achieving the objectives. Verifying the functionality of the over-
speed protection system at Engine shutdown and/or start-up is considered adequate for
compliance with this requirement. It is recognised that some Engines may routinely not be
shut down between flight cycles. In this case this should be accounted for in the analyses.
Because in some over-speed protection systems there are multiple protection paths, there
will always be uncertainty that all paths are functional at any given time. Where multiple
paths can invoke the over-speed protection system, a test of a different path may be
performed each Engine cycle. The objective is that a complete test of the over-speed system,
including electro-mechanical parts, is achieved in the minimum number of Engine cycles. This
is acceptable so long as the system meets a 10-4 Failure rate.
The applicant may provide data that demonstrates that the mechanical parts (this does not
include the electro-mechanical parts) of the over-speed protection system can operate

AMC 20-3B
without Failure between stated periods, and a periodic inspection may be established for
those parts. This data is acceptable in lieu of testing the mechanical parts of the sub-system
each Engine cycle.
(b) Other protective functions
The Engine Control System may perform other protective functions. Some of these may be
Engine functions, but others may be aircraft or Propeller functions. Engine functions should
be considered under the guidelines of this AMC. The integrity of other protective functions
provided by the Engine Control System should be consistent with a safety analysis associated
with those functions, but if those functions are not Engine functions, they may not be a part
of Engine certification.
As Engine Control Systems become increasingly integrated into the aircraft and Propeller
systems, they are incorporating protective functions that were previously provided by the
aircraft or Propeller systems. Examples are reducing the Engine to idle thrust if a thrust
reverser deploys and providing the auto-feather function for the Propeller when an Engine
fails.
The reliability and availability associated with these functions should be consistent with the
top level hazard assessment of conditions involving these functions. This will be completed
during aircraft certification.
For example, if an Engine Failure with loss of the auto-feather function is catastrophic at the
aircraft level - and the auto-feather function is incorporated into the Engine Control System
- the applicant will have to show for CS-25 installations (or CS-23 installations certified to CS-
25 specifications) that an Engine Failure with loss of the auto-feather function cannot result
from a single control system Failure, and that combinations of control system Failures, or
Engine and control system Failures, which lead to a significant Engine loss of thrust or power
with an associated loss of the autofeather function may be required to have an extremely
improbable event rate (i.e., 10-9 events per Engine flight hour).
Although these functions await evaluation at the aircraft level, it is strongly recommended
that, if practicable, the aircraft level hazard assessment involving these functions be available
at the time of the Engine Control System certification. This will facilitate discussions and co-
ordination between the Engine and aircraft certification teams under the conditions outlined
in paragraph (15) of this AMC. It is recognised that this co-ordination may not occur for
various reasons. Because of this, the applicant should recognise that although the Engine
may be certified, it may not be installable at the aircraft level.
The overall requirement is that the safety assessment of the Engine Control System should
include all Failure modes of all functions incorporated in the system. This includes those
functions which are added to support aircraft certification, so that the information of those
Failure modes will get properly addressed and passed on to the installer for inclusion in the
airframe SSA. Information concerning the frequencies of occurrence of those Failure modes
may be needed as well.

AMC 20-3B
(10) SOFTWARE AND AIRBORNE ELECTRONIC HARDWARE (AEH) DESIGN AND IMPLEMENTATION
(a) Objective
For Engine Control Systems that use software/AEH, the objective of CS-E 50(f) is to prevent
as far as possible software/AEH errors that would result in an unacceptable effect on power
or thrust, or any unsafe condition.
In multiple Engine installations, the possibility of software/AEH errors that are common to
more than one Engine Control System may determine the criticality level of the
software/AEH.
(b) Approved Methods
Methods for developing software/AEH that are compliant with the guidelines contained in
the latest edition of AMC 20-115/AMC 20-152 are acceptable methods. Alternative methods
for developing software/AEH may be proposed by the applicant and are subject to approval
by EASA.
Software/AEH which was not developed using the versions of ED-12/ED-80 referenced in the
latest edition of AMC 20-115/AMC 20-152 is referred to as legacy software/AEH. In general,
changes made to legacy software/AEH applicable to its original installation are assured in the
same manner as the original certification. When legacy software/AEH is used in a new aircraft
installation that requires the latest edition of AMC 20-115/AMC 20-152, the original approval
of the legacy software/AEH is still valid, assuming equivalence to the required software/AEH
criticality level can be ascertained. If the software/AEH development method equivalence is
acceptable to EASA, taking into account the conditions defined in the latest edition of
AMC 20-115/AMC 20-152, the legacy software/AEH can be used in the new installation. If
equivalence cannot be substantiated, all the software changes should be assured through
the use of the latest edition of AMC 20-115 for software or of AMC 20-152 for AEH.
item or the AEH design assurance level (or DAL) of an AEH item.
(c) Software/AEH criticality level
The software/AEH criticality level is determined by the Engine safety assessment process. ED-
79A/ARP4754A and ARP4761 provide guidelines on how to conduct an
aircraft/Engine/system safety assessment process. The Engine software/AEH should be
developed at the criticality levels that have been determined and agreed by the Engine and
aircraft applicants. It is assumed that by this agreement, the aircraft certification
specifications are met.
Determination of the appropriate software/AEH criticality level may depend on the Failure
modes and consequences of those Failures. For example, it is possible that Failures resulting
in significant thrust or power increases or oscillations may be more severe than an Engine
shutdown and, therefore, the possibility of these types of Failures should be considered when
selecting a given software/AEH criticality level.
(d) On-Board or Field Software Loading and Part Number Marking
The following guidelines should be followed when on-board or field loading of Electronic
Engine Control software and associated Electronic Part Marking (EPM) is implemented.

AMC 20-3B
For software changes, the software to be loaded should have been documented by an
approved design change and released with a service bulletin.
For an EECS unit having separate part numbers for hardware and software, the software part
number(s) need not be displayed on the unit as long as the software part number(s) is(are)
embedded in the loaded software and can be verified by electronic means. When new
software is loaded into the unit, the same verification requirement applies and the proper
software part number should be verified before the unit is returned to service.
For an EECS unit having only one part number, which represents a combination of a software
and hardware build, the unit part number on the nameplate should be changed or updated
when the new software is loaded. The software build or version number should be verified
before the unit is returned to service.
The configuration control system for an EECS that will be onboard/field loaded and using
electronic part marking should be approved. The drawing system should provide a
compatibility table that tabulates the combinations of hardware part numbers and software
versions that have been approved by the Agency. The top-level compatibility table should be
under configuration control, and it should be updated for each change that affects
hardware/software combinations. The applicable service bulletin should define the hardware
configurations with which the new software version is compatible.
The loading system should be in compliance with the guidelines of the latest edition of
AMC 20-115.
If the applicant proposes more than one source for loading, (e.g., diskette, mass storage,
Secure Disk card, USB stick flash, etc.), all sources should comply with these guidelines.
The service bulletin should require verification that the correct software version has been
loaded after installation on the aircraft.
(e) Software Change Category
The processes and methods used to change software should not affect the software level of
that software. For classification of software changes, refer to §4 in Appendix A of GM 21.A.91.
(f) Software Changes by Others than the TC Holder
There are two types of potential software changes that could be implemented by someone
other than the original TC holder:
— option-selectable software, or
— user-modifiable software (UMS).
Option-selectable changes would have to be pre-certified utilising a method of selection
which has been shown not to be capable of causing a control malfunction.
UMS is software intended for modification by the aircraft operator without review by the
certification authority, the aircraft applicant, or the equipment vendor. For Engine Control
Systems, UMS has generally not been applicable. However, approval of UMS, if required,
would be addressed on a case-by-case basis.
In principle, persons other than the TC holder may modify the software within the
modification constraints defined by the TC holder, if the system has been certified with the

AMC 20-3B
provision for software user modifications. To certify an Electronic Engine Control System with
the provision for software modification by others than the TC holder, the TC holder should
(1) provide the necessary information for approval of the design and implementation of a
software change, and (2) demonstrate that the necessary precautions have been taken to
prevent the user modification from affecting Engine airworthiness, especially if the user
modification is incorrectly implemented.
In the case where the software is changed in a manner not pre-allowed by the TC holder as
“user modifiable”, the “non-TC holder” applicant will have to comply with the requirements
given in Part 21, subpart E.
(11) RESERVED
(12) AIRCRAFT-SUPPLIED DATA
(a) Objective
As required by CS-E 50(g), in case of loss, interruption, or corruption of Aircraft-Supplied Data,
the Engine should continue to function in a safe and acceptable manner, without
unacceptable effects on thrust or power, Hazardous Engine Effects, or loss of ability to
comply with the operating specifications of CS-E 390, CS-E 500(a) and CS-E 745, as
appropriate.
(b) Background
Historically, regulatory practice was to preserve the Engine independence from the aircraft.
Hence even with very reliable architecture, such as triply redundant air data computer (ADC)
systems, it was required that the Engine Control System provided an independent control
means that could be used to safely fly the aircraft should all the ADC signals be lost.
However, with the increased Engine-aircraft integration that is currently occurring in the
aviation industry and with the improvement in reliability and implementation of Aircraft-
Supplied Data, the regulatory intent is being revised to require that Fault Accommodation be
provided against single Failures of Aircraft-Supplied Data. This may include Fault
Accommodation by transition into another Control Mode that is independent of Aircraft-
Supplied Data.
The Engine Control System’s LOTC/LOPC analysis should contain the effects of air data system
Failures in all allowable Engine Control System and air data system dispatch configurations.
When Aircraft-Supplied Data can affect Engine Control System operation, the applicant
should address the following items, as applicable, in the SSA or other appropriate documents:
— Software in the data path to the EECS should be at a level consistent with that defined
for the EECS. The data path may include other aircraft equipment, such as aircraft
thrust management computers, or other avionics equipment.
— The applicant should state in the instructions for installation that the aircraft applicant
is responsible for ensuring that changes to aircraft equipment, including software, in
the data path to the Engine do not affect the integrity of the data provided to the
Engine as defined by the Engine instructions for installation.
— The applicant should supply the effects of faulty and corrupted Aircraft-Supplied Data
on the EECS in the Engine instructions for installation.

AMC 20-3B
— The instructions for installation should state that the installer should ensure that those
sensors and equipment involved in delivering information to the EECS are capable of
operating in the EMI, HIRF and lightning environments, as defined in the certification
basis for the aircraft, without affecting their proper and continued operation.
— The applicant should state the reliability level for the Aircraft-Supplied Data that was
used as part of the SSA and LOTC/LOPC analysis as an “assumed value” in the
instructions for installation.
As stated in CS-E 50(g), thrust and power command signals sent from the aircraft are not
subject to the specifications of CS-E 50(g)(2). If the aircraft thrust or power command system
is configured to move the Engine thrust or power levers or transmit an electronic signal to
command a thrust or power change, the Engine Control System merely responds to the
command and changes Engine thrust or power as appropriate. The Engine Control System
may have no way of knowing that the sensed throttle or power lever movement was correct
or erroneous.
In both the moving throttle (or power lever) and non-moving throttle (or power lever)
configurations, it is the installer’s responsibility to show that a proper functional hazard
analysis is performed on the aircraft system involved in generating Engine thrust or power
commands, and that the system meets the appropriate aircraft’s functional hazard
assessment safety related specifications. This task is an aircraft certification issue, however
Failures of the system should be included in the Engine’s LOTC/LOPC analysis.
(c) Design assessment
The applicant should prepare a Fault Accommodation chart that defines the Fault
Accommodation architecture for the Aircraft-Supplied Data.
There may be elements of the Engine Control System that are mounted in the aircraft and
are not part of the Engine type design, but which are dedicated to the Engine Control System
and powered by it, such as a throttle position resolver. In these instances, such elements are
considered to be an integral component of the Electronic Engine Control System and are not
considered aircraft data.
In the case where the particular Failure modes of the aircraft air data may be unknown, the
typical Failure modes of loss of data and erroneous data should be assumed. The term
“erroneous data” is used herein to describe a condition where the data appears to be valid
but is incorrect.
Such assumptions and the results of the evaluation of erroneous aircraft data should be
provided to the installer.
The following are examples of possible means of accommodation:
— Provision of an Alternate Mode that is independent of Aircraft-Supplied Data.
— Dual sources of aircraft-supplied sensor data with local Engine sensors provided as
voters and alternate data sources.
— Use of synthesised Engine parameters to control or as voters. When synthesised
parameters are used for control or voting purposes, the analysis should consider the
impact of temperature and other environmental effects on those sensors whose data

AMC 20-3B
are used in the synthesis. The variability of any data or information necessary to relate
the data from the sensors used in the synthesis to the parameters being synthesised
should also be assessed.
— Triple redundant ADC systems that provide the required data.
If for aircraft certification it is intended to show that the complete loss of the aircraft air data
system itself is extremely improbable, then it should be shown that the aircraft air data
system is unaffected by a complete loss of aircraft generated power, for example, backed up
by battery power. (See AMC 20-1)
(d) Effects on the Engine
CS-E 510 defines the Hazardous Engine Effects for turbine Engines.
CS-E 50(g) is primarily intended to address the effects of aircraft signals, such as aircraft air
data information, or other signals which could be common to all Engine Control Systems in a
multi-Engine installation. The control system design should ensure that the full-up system is
capable of providing the declared minimum rated thrust or power throughout the Engine
operating envelope.
CS-E 50(g) requires the applicant to provide an analysis of the effect of loss or corruption of
aircraft data on Engine thrust or power. The effects of Failures in Aircraft-Supplied Data
should be documented in the SSA as described in Section (8) above. Where appropriate,
aircraft data Failures or malfunctions that contribute to LOTC/LOPC events should be
included in the LOTC/LOPC analysis.
(e) Validation
Functionality of the Fault Accommodation logic should be demonstrated by test, analysis, or
combination thereof. In the case where the aircraft air data system is not functional because
of the loss of all aircraft generated power, the Engine Control System should include validated
Fault Accommodation logic which allows the Engine to operate acceptably with the loss of all
aircraft-supplied air data. Engine operation in this system configuration should be
demonstrated by test.
For all dispatchable Control Modes, see CS-E 1030 and AMC E 1030.
If an Alternate Mode, independent of Aircraft-Supplied Data, has been provided to
accommodate the loss of all data, sufficient testing should be conducted to demonstrate that
the operability specifications have been met when operating in this mode. Characteristics of
operation in this mode should be included in the instructions for installation and operation
as appropriate. This Alternate Mode need not be dispatchable.
(13) AIRCRAFT SUPPLIED ELECTRICAL POWER
(a) Objective
The objective is to provide an electrical power source that is single Fault tolerant (including
common cause or mode) in order to allow the EECS to comply with CS-E 50(c)(2). The most
common practice for achieving this objective has been to provide a dedicated electrical
power source for the EECS. When aircraft electrical power is used, the assumed quality and
reliability levels of this aircraft power should be contained in the instructions for installation.

AMC 20-3B
(b) Electrical power sources

An Engine dedicated power source is defined herein as an electric power source providing
electrical power generated and supplied solely for use by a single Engine Control System.
Such a source is usually provided by an alternator(s), mechanically driven by the Engine or
the transmission system of rotorcraft. However, with the increased integration of the Engine-
aircraft systems and with the application of EECS to small Engines, both piston and turbine,
use of an Engine-mounted alternator may not necessarily be the only design approach for
meeting the objective.
Batteries are considered an Aircraft-Supplied Power source except in the case of piston
Engines. For piston Engines, a battery source dedicated solely to the Engine Control System
may be accepted as an Engine dedicated power source. In such applications, appropriate
information for the installer should be provided including, for example, health status and
maintenance requirements for the dedicated battery system.
(c) Analysis of the design architecture
An analysis and a review of the design architecture should identify the requirements for
Engine dedicated power sources and Aircraft-Supplied Power sources. The analysis should
include the effects of losing these sources. If the Engine is dependent on Aircraft-Supplied
Power for any operational functions, the analysis should result in a definition of the
requirements for Aircraft-Supplied Power.
The following configurations have been used:
— EECS dependent on Aircraft-Supplied Power
— EECS independent of Aircraft-Supplied Power (Engine dedicated power source)
— Aircraft-Supplied Power used for functions, switched by the EECS
— Aircraft-Supplied Power directly used for Engine functions, independently from the
EECS
— Aircraft-Supplied Power used to back up the Engine dedicated power source
The capacity of any Engine dedicated power source, required to comply with CS-E 50(h)(2),
should provide sufficient margin to maintain confidence that the Engine Control System will
continue to function in all anticipated Engine operating conditions where the control system
is designed and expected to recover Engine operation automatically in-flight. The autonomy
of the Engine Control System should be sufficient to ensure its functioning in the case of
immediate automatic relight after unintended shutdown. Conversely, the autonomy of the
Engine Control System in the whole envelope of restart in windmilling conditions is not
always required. This margin should account for any other anticipated variations in the
output of the dedicated power source such as those due to temperature variations,
manufacturing tolerances and idle speed variations. The design margin should be
substantiated by test and/or analysis and should also take into account any deterioration
over the life of the Engine.
(d) Aircraft-Supplied Power Reliability
Any Aircraft-Supplied Power reliability values used in system analyses, whether supplied by
the aircraft manufacturer or assumed, should be contained in the instructions for installation.

AMC 20-3B
When Aircraft-Supplied Power is used in any architecture, if aircraft power Faults or Failures
can contribute to LOTC/LOPC or Hazardous Engine Effects, these events should be included
in the Engine SSA and LOTC/LOPC analyses.
When compliance with CS-E 50(h)(1) imposes an Engine dedicated power source, Failure of
this source should be addressed in the LOTC/LOPC analysis required under CS-E 50 (c). While
no credit is normally necessary to be given in the LOTC/LOPC analysis for the use of Aircraft-
Supplied Power as a back-up power source, Aircraft-Supplied Power has typically been
provided for the purpose of accommodating the loss of the Engine dedicated power source.
However, LOTC/LOPC allowance and any impact on the SSA for the use of Aircraft-Supplied
Power as the sole power source for an Engine control Back-up System or as a back-up power
source would be reviewed on a case-by-case basis.
In some system architectures, an Engine dedicated power source may not be required and
Aircraft-Supplied Power may be acceptable as the sole source of power.
An example is a system that consists of a primary electronic single channel and a full
capability hydromechanical Back-up System that is independent of electrical power (a full
capability hydromechanical control system is one that meets all CS-E specifications and is not
dependent on aircraft power). In this type of architecture, loss or interruption of Aircraft-
Supplied Power is accommodated by transferring control to the hydromechanical system.
Transition from the electronic to the hydromechanical control system is addressed under CS-
E 50(b).
Another example is an EECS powered by an aircraft power system that could support a critical
fly-by-wire flight control system. Such a power system may be acceptable as the sole source
of power for an EECS. In this example, it should be stated in the instructions for installation
that a detailed design review and safety analysis is to be conducted to identify latent failures
and common cause failures that could result in the loss of all electrical power. The
instructions should also state that any emergency power sources must be known to be
operational at the beginning of the flight. Any emergency power sources must be isolated
from the normal electrical power system in such a way that the emergency power system
will be available no matter what happens to the normal generated power system. If batteries
are the source of emergency power, there must be a means of determining their condition
prior to flight, and their capacity must be shown to be sufficient to assure exhaustion will not
occur before getting the aircraft safely back on the ground.
This will satisfy that appropriate reliability assumptions are provided to the installer.
(e) Aircraft-Supplied Power Quality
When Aircraft-Supplied Power is necessary for operation of the Engine Control System, CS-E
50(h)(3) specifies that the Engine instructions for installation contain the Engine Control
System’s electrical power supply quality requirements. This applies to any of the
configurations listed in paragraph (13)(c) or any new configurations or novel approach not
listed that use Aircraft-Supplied Power. These quality requirements should include steady
state and transient under-voltage and over-voltage limits for the equipment. The power input
standards of RTCA DO-160/EUROCAE ED-14 are considered to provide an acceptable
definition of such requirements. If RTCA DO-160/EUROCAE ED-14 is used, any exceptions to

AMC 20-3B
the power quality standards cited for the particular category of equipment specified should
be stated.
It is recognised that the electrical or electronic components of the Engine Control System
when operated on Aircraft-Supplied Power may cease to operate during some low voltage
aircraft power supply conditions beyond those required to sustain normal operation, but in
no case should the operation of the Engine control result in a Hazardous Engine Effect. In
addition, low voltage transients outside the control system’s declared capability should not
cause permanent loss of function of the control system, or result in inappropriate control
system operation which could cause the Engine to exceed any operational limits, or cause
the transmission of unacceptable erroneous data.
When aircraft power recovers from a low-voltage condition to a condition within which the
control system is expected to operate normally, the Engine Control System should resume
normal operation. The time interval associated with this recovery should be contained in the
Engine instructions for installation. It is recognised that Aircraft-Supplied Power conditions
may lead to an Engine shutdown or Engine condition which is not recoverable automatically.
In these cases the Engine should be capable of being restarted, and any special flight crew
procedures for executing an Engine restart during such conditions should be contained in the
Engine instructions for operation. The acceptability of any non-recoverable Engine operating
conditions - as a result of these Aircraft-Supplied Power conditions - will be determined at
aircraft certification.
If Aircraft-Supplied Power supplied by a battery is required to meet an "all Engines out"
restart requirement, the analysis according to paragraph 13(c) should result in a definition of
the requirements for this Aircraft-Supplied Power. In any installation where aircraft electrical
power is used to operate the Engine Control System, such as low Engine speed in-flight re-
starting conditions, the effects of any aircraft electrical bus-switching transients or power
transients associated with application of electrical loads, which could cause an interruption
in voltage or a decay in voltage below that level required for proper control functioning,
should be considered.
(f) Effects on the Engine
Where loss of aircraft power results in a change in Engine Control Mode, the Control Mode
transition should meet the specifications of CS-E 50(b).
For some Engine control functions that rely exclusively upon Aircraft-Supplied Power, the loss
of electrical power may still be acceptable. Acceptability is based on evaluation of the change
in Engine operating characteristics, experience with similar designs, or the accommodation
designed into the control system.
Examples of such Engine control functions that have traditionally been reliant on aircraft
power include:
— Engine start and ignition
— Thrust Reverser deployment
— Anti-Icing (Engine probe heat)
— Fuel Shut-Off

AMC 20-3B
— Over-speed Protection Systems

— — Non-critical functions that are primarily performance enhancement functions
which, if inoperative, do not affect the safe operation of the Engine.
(g) Validation
The applicant should demonstrate the effects of loss of Aircraft-Supplied Power by Engine
test, system validation test or bench test or combination thereof.
(14) PISTON ENGINES
Piston Engines are addressed by the sections above; no additional specific guidance is necessary.
CS-E 50 specifications are applicable to these Engines but, when interpretation is necessary, the
conditions which would be acceptable for the aircraft installation should be considered.
(15) ENGINE, PROPELLER AND AIRCRAFT SYSTEMS INTEGRATION AND THE INTERRELATION BETWEEN
ENGINE, PROPELLER AND AIRCRAFT CERTIFICATION ACTIVITIES
(a) Aircraft or Propeller Functions Integrated into the Engine Control System
This involves the integration of aircraft or Propeller functions (i.e., those that have
traditionally not been considered Engine control functions), into the Electronic Engine
Control System’s hardware and software.
Examples of this include thrust reverser control systems, Propeller speed governors, which
govern speed by varying pitch, and ATTCS. When this type of integration activity is pursued,
the EECS becomes part of - and should be included in the aircraft’s SSA, and although the
aircraft functions incorporated into the EECS may receive review at Engine certification, the
acceptability of the safety analysis involving these functions should be determined at aircraft
certification.
The EECS may be configured to contain only part of the aircraft system’s functionality, or it
may contain virtually all of it. Thrust reverser control systems are an example where only part
of the functionality is included in the EECS. In such cases, the aircraft is configured to have
separate switches and logic (i.e., independent from the EECS) as part of the thrust reverser
control system. This separation of reverser control system elements and logic provides an
architectural means to limit the criticality of the functions provided by the EECS.
However, in some cases the EECS may be configured to incorporate virtually all of a critical
aircraft function. Examples of this “virtual completeness” in aircraft functionality are EECS
which contain full authority to govern Propeller speed in turboprop powered aircraft and
ATTCS in turbofan power aircraft.
The first of these examples is considered critical because, if an Engine fails, the logic in the
Engine Control System should be configured to feather the Propeller on that Engine. Failure
to rapidly feather the Propeller following an Engine Failure results in excessive drag on the
aircraft, and such a condition can be critical to the aircraft. When functions like these are
integrated into the Engine control such that they render an EECS critical, special attention
should be paid to assuring that no single (including common cause/mode) Failures could
cause the critical Failure condition, e.g. exposure of the EECS to overheat should not cause
both an Engine shutdown and Failure of the Propeller to feather.

AMC 20-3B
The second example, that of an ATTCS, is considered critical because the system is required
to increase the thrust of the remaining Engine(s) following an Engine Failure during takeoff,
and the increased thrust on the remaining Engines is necessary to achieve the required
aircraft performance.
All of the above examples of integration involve aircraft functionality that would receive
significant review during aircraft certification.
(b) Integration of Engine Control Functions into Aircraft Systems
The trend toward systems integration may lead to aircraft systems performing functions
traditionally considered part of the Engine Control System. Some designs may use aircraft
systems to implement a significant number of the Engine Control System functions. An
example would be the complex integrated flight and Engine Control Systems – integrated in
aircraft avionics units - which govern Engine speed, rotor speed, rotor pitch angle and rotor
tilt angle in tilt-rotor aircraft.
In these designs, aircraft systems may be required to be used during Engine certification. In
such cases, the Engine applicant is responsible for specifying the requirements for the EECS
in the instructions for installation and substantiating the adequacy of those requirements.
An example of limited integration would be an Engine control which receives a torque output
demand signal from the aircraft and responds by changing the Engine’s fuel flow and other
variables to meet that demand. However, the EECS itself, which is part of the type design,
provides all the functionality required to safely operate the Engine in accordance with CS-E
or other applicable specifications.
(c) Certification activities
(i) Objective
To satisfy the aircraft specifications, such as CS 25.901, CS 25.903 and CS 25.1309, an
analysis of the consequences of Failures of the Engine Control System on the aircraft
has to be made. The Engine applicant should, together with the aircraft applicant,
ensure that the software/AEH criticality levels and the safety and reliability objectives
for the Engine electronic control system are consistent with these specifications.
(ii) Interface Definition and System Responsibilities
System responsibilities as well as interface definitions should be identified for the
functional as well as hardware and software aspects between the Engine, Propeller
and the aircraft systems in the appropriate documents.
The Engine/Propeller/aircraft documents should cover in particular:
— Functional requirements and criticality (which may be based on Engine,
Propeller and aircraft considerations);
— Fault Accommodation strategies;
— Maintenance strategies;
— The software/AEH criticality level (per function if necessary);
— The reliability objectives for:

AMC 20-3B
— LOTC/LOPC events,
— Transmission of faulty parameters;
— The environmental requirements including the degree of protection against
lightning or other electromagnetic effects (e.g. level of induced voltages that can
be supported at the interfaces);
— Engine, Propeller and aircraft interface data and characteristics;
— Aircraft power supply requirements and characteristics (if relevant).
(iii) Distribution of Compliance Tasks
The tasks for the certification of the aircraft propulsion system equipped with
Electronic Engine Control Systems (EECSs) may be shared between the Engine,
Propeller and aircraft applicants. The distribution of these tasks between the
applicants should be identified and agreed with the appropriate Engine, Propeller and
aircraft authorities. For further information refer to AMC 20-1().
The aircraft certification should deal with the overall integration of the Engine and
Propeller in compliance with the applicable aircraft specifications.
The Engine certification will address the functional aspects of the Engine Control
System in compliance with the applicable Engine specifications.
Appropriate evidence provided for Engine certification should be used for aircraft
certification. For example, the quality of any aircraft function software/AEH and
aircraft–Engine interface logic already demonstrated for Engine certification should
need no additional substantiation for aircraft certification.
Two examples are given below to illustrate this principle.
(A) Case of an EECS performing the functions for the control of the Engine and the
functions for the control of the Propeller.
The Engine certification would address all general requirements such as
software/AEH development assurance procedures, EMI, HIRF and lightning
protection levels, effects of loss of aircraft-supplied power.
The Engine certification would address the functional aspects for the Engine
functions (safety analysis, rate of LOTC/LOPC events, effect of loss of aircraft-
supplied data, etc.). The Fault Accommodation logic affecting the control of the
Engine, for example, will be reviewed at that time.
The Propeller certification will similarly address the functional aspects for the
Propeller functions. The Fault Accommodation logic affecting the control of the
Propeller, for example, will be reviewed at that time.
In this example, the Propeller functions and characteristics defined by the
Propeller applicant, which are to be provided by the Engine Control System,
would normally need to be refined by flight test. The Propeller applicant is
responsible for ensuring that these functions and characteristics, which are
provided for use during the Engine certification programme, define an airworthy
Propeller configuration, even if they have not yet been refined by flight test.

AMC 20-3B
With regard to changes in design, agreement by all parties involved should be

reached so that changes to the Engine Control System that affect the Propeller
system, or vice versa, do not lead to any inadvertent effects on the other system.
(B) Case of an aircraft computer performing the functions for the control of the
Engine.
The aircraft certification will address all general requirements such as
software/AEH development assurance procedures, EMI, HIRF and lightning
protection levels.
The aircraft certification will address the functional aspects for the aircraft
functions.
The Engine certification will address the functional aspects for the Engine
functions (safety analysis, rate of LOTC/LOPC events, effect of loss of aircraft-
supplied data, etc.) The Fault Accommodation logic affecting the control of the
Engine, for example, will be reviewed at that time.
[Amdt 20/2]
[Amdt 20/10]
[Amdt 20/19]

AMC 20-6
AMC 20-6
AMC 20-6 Extended Range Operation with Two-Engine Aeroplanes

ETOPS Certification and Operation
Chapter I GENERAL CONSIDERATIONS

SECTION 1: PURPOSE
This AMC states an acceptable means but not the only means for obtaining approval for two-engine
aeroplanes intended to be used in extended range operations and for the performance of such operations.
An applicant may elect to use another means of compliance which should be acceptable to the Agency or
the competent authority. Compliance with this AMC is not mandatory. Use of the terms shall and must
apply only to an applicant who elects to comply with this AMC in order to obtain airworthiness approval
or to demonstrate compliance with the operational criteria.
This AMC is structured in 3 chapters which contain the following information:
1. Chapter I of this AMC provides general guidance and definitions related to extended range
operations.
2. Chapter II of this AMC provides guidance to (S)TC holders seeking ETOPS type design approval of an
engine or a particular airplane-engine combination. These airplanes may be used in extended range
operations.
3. Chapter III of this AMC provides guidance to operators seeking ETOPS operational approval to
conduct extended range operations under the requirements of the applicable operational
regulations4.
The purpose of this revision No. 2 of AMC 20-6 is to develop guidance for obtaining approval for diversion
times exceeding 180 minutes.
ETOPS type design approvals and operational approvals obtained before the issue of this revision remain
valid. Extension of existing ETOPS type design approvals or operational approvals beyond 180 min should
be issued in accordance with this revision.
New ETOPS type design approvals and operational approvals should be issued in accordance with this
revision.
SECTION 2: RELATED REFERENCES

CS-Definitions: ED Decision No. 2003/011/RM as last amended.
CS-E: ED Decision No. 2003/9/RM, as last amended (CS-E 1040).
CS-25: ED Decision No. 2003/2/RM, as last amended, (CS 25.901, 25.903, 25.1309, 25.1351(d), 25.1419,
25.1535, CS-25 Subpart J).
EU-OPS: Council Regulation (EEC) No 3922/91, as last amended.
1
EU-OPS until operational requirements Part-SPA Subpart-ETOPS are in force.

AMC 20-6
Part-21: Annex to Commission Regulation (EC) No 1702/2003, as last amended.

Part-M: Annex I to Commission Regulation (EC) No 2042/2003, as last amended.
Part-145: Annex II to Commission Regulation (EC) No 2042/2003, as last amended.
SECTION 3: ABBREVIATIONS
AFM: Airplane Flight Manual
ATS: Air Traffic Services
CAME: Continuing Airworthiness Management Exposition
CAMO: Continuing Airworthiness Management Organisation approved pursuant to Part-M Subpart-G
CG: Centre of Gravity
IFSD: In-flight shut-down
MCT: Maximum Continuous Thrust
MMEL: Master Minimum Equipment List
MEL: Minimum Equipment List
RFFS Rescue and Fire Fighting Services
(S)TC: (Supplemental) Type Certificate
SECTION 4: TERMINOLOGY
a. Approved One-Engine-Inoperative Cruise Speed
(1) The approved one-engine-inoperative cruise speed for the intended area of operation must
be a speed, within the certificated limits of the aeroplane, selected by the operator and
approved by the competent authority.
(2) The operator must use this speed in
(i) establishing the outer limit of the area of operation and any dispatch limitation,
(ii) calculation of single-engine fuel requirements under Appendix 4 section 4 of this AMC
and,
(iii) establishing the level off altitude (net performance) data. This level off altitude (net
performance) must clear any obstacle en route by margins as specified in the
operational requirements.
A speed other than the approved one-engine-inoperative-speed may be used as the
basis for compliance with en-route altitude requirements.
The fuel required with that speed or the critical fuel scenario associated with the
applicable ETOPS equal-time point, whichever is higher has to be uplifted..
(3) As permitted in Appendix 4 of this AMC, based on evaluation of the actual situation, the pilot-
in-command may deviate from the planned one-engine-inoperative cruise speed.

AMC 20-6
Note: The diversion distance based on the approved one-engine-inoperative cruise speed may take into
account the variation of the True Air Speed.
b. Dispatch
Dispatch is when the aircraft first moves under its own power for the purpose of taking-off.
c. ETOPS Configuration, Maintenance and Procedures (CMP)
The ETOPS CMP document contains the particular airframe-engine combination configuration
minimum requirements, including any special inspection, hardware life limits, Master Minimum
Equipment List (MMEL) constraints, operating and maintenance procedures found necessary by the
Agency to establish the suitability of an airframe/engine combination for extended range operation.
d. ETOPS significant system
ETOPS Significant System means the aeroplane propulsion system and any other aeroplane systems
whose failure could adversely affect the safety of an ETOPS flight, or whose functioning is important
to continued safe flight and landing during an aeroplane diversion.
Each ETOPS significant system is either a Group 1 or Group 2 system based on the following criteria:
(1) ETOPS Group 1 Systems:
Group 1 Systems are ETOPS significant systems that, related to the number of engines on the
aeroplane or the consequences of an engine failure, make the systems’ capability important
for an ETOPS flight. The following provides additional discriminating definitions of an ETOPS
Group 1 Significant System:
(i) A system for which the fail-safe redundancy characteristics are directly linked to the
number of engines (e.g., hydraulic system, pneumatic system, electrical system).
(ii) A system that may affect the proper functioning of the engines to the extent that it
could result in an in-flight shutdown or uncommanded loss of thrust (e.g., fuel system,
thrust reverser or engine control or indicating system, engine fire detection system).
(iii) A system which contributes significantly to the safety of an engine inoperative ETOPS
diversion and is intended to provide additional redundancy to accommodate the
system(s) lost by the inoperative engine. These include back-up systems such as an
emergency generator, APU, etc.
(iv) A system essential for prolonged operation at engine inoperative altitudes such as anti-
icing systems for a two-engine aeroplane if single engine performance results in the
aeroplane operating in the icing envelope.
(2) ETOPS Group 2 Systems:
Group 2 Systems are ETOPS significant systems that do not relate to the number of engines
on the aeroplane, but are important to the safe operation of the aeroplane on an ETOPS
flight. The following provides additional discriminating definitions of an ETOPS Group 2
Significant System:
(i) A system for which certain failure conditions would reduce the capability of the
aeroplane or the ability of the crew to cope with an ETOPS diversion (e.g., long range

AMC 20-6
navigation or communication, equipment cooling, or systems important to safe

operation on a ETOPS diversion after a decompression such as anti-icing systems).
(ii) Time-limited systems including cargo fire suppression and oxygen if the ETOPS
diversion is oxygen system duration dependent.
(iii) Systems whose failure would result in excessive crew workload or have operational
implications or significant detrimental impact on the flight crew’s or passengers’
physiological well-being for an ETOPS diversion (e.g., flight control forces that would
be exhausting for a maximum ETOPS diversion, or system failures that would require
continuous fuel balancing to ensure proper CG, or a cabin environmental control
failure that could cause extreme heat or cold to the extent it could incapacitate the
crew or cause physical harm to the passengers).
(iv) A system specifically installed to enhance the safety of ETOPS operations and an ETOPS
diversion regardless of the applicability of paragraphs (2)(i), (2)(ii) and (2)(iii) above
(e.g. communication means).
e. Extended Range Entry Point
The extended range entry point is the first point on the aeroplane’s route which is:
— For two-engine aeroplanes with a maximum approved passenger seating configuration of 20
or more, or with a maximum take-off mass of 45360 kg or more, at 60 minutes flying time at
the approved one-engine-inoperative cruise speed (under standard conditions in still air)
from an adequate aerodrome.
— For two-engine aeroplanes with a maximum approved passenger seating configuration of 19
or less and a maximum take-off mass of less than 45360 kg, at 180 minutes flying time at the
approved one-engine-inoperative speed (in still air) from an adequate aerodrome.
f. In-flight Shutdown (IFSD)
In-flight shutdown (IFSD) means when an engine ceases to function and is shutdown, whether self-
induced, flight crew initiated or caused by an external influence. For ETOPS, all IFSDs occurring from
take-off decision speed until touch-down shall be counted.
The Agency considers IFSD for all causes, for example: flameout, internal failure, flight crew initiated
shutdown, foreign object ingestion, icing, inability to obtain or control desired thrust or power, and
cycling of the start control, however briefly, even if the engine operates normally for the remainder
of the flight.
This definition excludes the cessation of the functioning of an engine when immediately followed
by an automatic engine relight and when an engine does not achieve desired thrust or power but
is not shutdown. These events as well as engine failures occurring before take-off decision speed
or after touch-down, although not counted as IFSD, shall be reported to the competent authority
in the frame of continued airworthiness for ETOPS.
g. Maximum Approved Diversion Time
A maximum approved diversion time(s) for the airframe/engine combination or the engine,
established in accordance with the type design criteria in this AMC and Appendices 1 and 2 of this
AMC. This Maximum Approved Diversion Time(s) is reflected in the aeroplane and engine Type
Certificate Data Sheets or (S)TC and in the AFM or AFM-supplement.

AMC 20-6
Any proposed increase in the Maximum Approved Diversion Time(s), or changes to the aircraft or
engine, should be re-assessed by the (S)TC holder in accordance with Part 21.A.101 to establish if
any of the Type Design criteria in this AMC should be applied.
h. Operator’s Approved Diversion Time
Operator’s Approved Diversion Time is the maximum time authorised by the Competent Authority
that the operator can operate a type of aeroplane at the approved one-engine-inoperative cruise
speed (under standard conditions in still air) from an adequate aerodrome for the area of operation.
i. System:
A system includes all elements of equipment necessary for the control and performance of a
particular function. It includes both the equipment specifically provided for the function in
question and other basic equipment such as that necessary to supply power for the
equipment operation.
(1) Airframe System. Any system on the aeroplane that is not part of the propulsion
system.
(2) Propulsion System. The aeroplane propulsion system includes the engine and each
component that is necessary for propulsion; components that affect the control of the
propulsion units; and components that affect the safe operation of the propulsion
units.
SECTION 5: CONCEPTS
Although it is self-evident that the overall safety of an extended range operation cannot be better than
that provided by the reliability of the propulsion systems, some of the factors related to extended range
operation are not necessarily obvious.
For example, cargo compartment fire suppression/containment capability could be a significant factor, or
operational/maintenance practices may invalidate certain determinations made during the aeroplane
type design certification or the probability of system failures could be a more significant problem than the
probability of propulsion system failures. Although propulsion system reliability is a critical factor, it is not
the only factor which should be seriously considered in evaluating extended range operation. Any decision
relating to extended range operation with two-engine aeroplanes should also consider the probability of
occurrence of any conditions which would reduce the capability of the aeroplane or the ability of the crew
to cope with adverse operating conditions.
The following is provided to define the concepts for evaluating extended range operation with two-engine
aeroplanes. This approach ensures that two-engine aeroplanes are consistent with the level of safety
required for current extended range operation with three and four-engine turbine powered aeroplanes
without unnecessarily restricting operation.
a. Airframe Systems
A number of airframe systems have an effect on the safety of extended range operation; therefore,
the type design certification of the aeroplane should be reviewed to ensure that the design of these
systems is acceptable for the safe conduct of the intended operation.
b. Propulsion Systems

AMC 20-6
In order to maintain a level of safety consistent with the overall safety level achieved by modern
aeroplanes, it is necessary for two-engine aeroplanes used in extended range operation to have an
acceptably low risk of significant loss of power/thrust for all design and operation related causes
(see Appendix 1).
c. Maintenance and Reliability Programme Definition
Since the quality of maintenance and reliability programmes can have an appreciable effect on the
reliability of the propulsion system and the airframe systems required for extended range
operation, an assessment should be made of the proposed maintenance and reliability
programme's ability to maintain a satisfactory level of propulsion and airframe system reliability for
the particular airframe/engine combination.
d. Maintenance and Reliability Programme Implementation
Following a determination that the airframe systems and propulsion systems are designed to be
suitable for extended range operation, an in-depth review of the applicant's training programmes,
operations and maintenance and reliability programmes should be accomplished to show ability to
achieve and maintain an acceptable level of systems reliability to safely conduct these operations.
e. Human Factors
System failures or malfunctions occurring during extended range operation could affect flight crew
workload and procedures. Since the demands on the flight crew may increase, an assessment
should be made to ensure that more than average piloting skills or crew co-ordination is not
required.
Chapter II TYPE DESIGN APPROVAL CONSIDERATIONS

SECTION 1: APPLICABILITY
This chapter is applicable to (S)TC applicants or holders seeking ETOPS type design approval for an engine
or a particular airplane-engine combination.
SECTION 2: COMPETENT AUTHORITY

The Competent Authority for the issue of an ETOPS type design approval is the Agency.
SECTION 3: GENERAL
When a two-engine aeroplane is intended to be used in extended range operations, a determination
should be made that the design features are suitable for the intended operation. The ETOPS significant
system for the particular airframe/engine combination should be shown to be designed to fail-safe criteria
and it should be determined that it can achieve a level of reliability suitable for the intended operation.
In some cases modifications to systems may be necessary to achieve the desired reliability.
SECTION 4: ELEGIBILITY
To be eligible for extended range operations (ETOPS), the specified airframe/engine combination, should
have been certificated according to the airworthiness standards of large aeroplanes and engines.

AMC 20-6
The process to obtain a type design ETOPS approval requires the applicant to show that in accordance
with the criteria established in this chapter II and Appendices 1 and 2:
4. the design features of the particular airframe/engine combination are suitable for the intended
operations; and,
5. the particular airframe/engine combination, having been recognised eligible for ETOPS, can achieve
a sufficiently high level of reliability.
The required level of reliability of the airframe/engine combination can be validated by the following
methods:
(1) METHOD 1: in-service experience for ETOPS Type Design Approval defined in section 6.1 and
Appendices 1 and 2 of this AMC, or
(2) METHOD 2: a programme of design, test and analysis agreed between the applicant and the Agency,
(i.e. Approval Plan) for Early ETOPS Type Design Approval defined in Appendices 1 and 2 of this
AMC.
SECTION 5: REQUEST FOR APPROVAL

An applicant for, and holders of a (S)TC requesting a determination that a particular airframe/engine
combination is a suitable type design for extended range operation, should apply to the Agency. The
Agency will then initiate an assessment of the engine and airframe/engine combination in accordance
with the criteria laid down in this chapter II and Appendix 1 & 2 of this AMC.
SECTION 6: VALIDATION METHODS OF THE LEVEL OF RELIABLITY

This chapter together with Appendix 1 and 2 to this AMC should be followed to assess the reliability level
of the propulsion system and airframe systems for which ETOPS type design approval is sought. Appendix
1 and 2 describe both the in-service experience method and the early ETOPS method.
6.1 METHOD 1: IN-SERVICE EXPERIENCE FOR ETOPS TYPE DESIGN APPROVAL
Prior to the ETOPS type design approval, it should be shown that the world fleet of the particular
airframe/engine combination for which approval is sought can achieve or has achieved, as
determined by the Agency (see Appendix 1 and 2), an acceptable and reasonably stable level of
propulsion system in-flight shutdown (IFSD) rate and airframe system reliability.
Engineering and operational judgement applied in accordance with the guidance outlined in
Appendix 1 will then be used to determine that the IFSD rate objective for all independent causes
can be or has been achieved. This assessment is an integral part of the determination in section 7
paragraph (2) for type design approval. This determination of propulsion system reliability is
derived from a world fleet data base containing, in accordance with requirements of Appendix 1,
all in-flight shutdown events, all significant engine reliability problems, design and test data and
available data on cases of significant loss of thrust, including those where the propulsion system
failed or the engine was throttled back or shut down by the pilot. This determination will take due
account of the approved maximum diversion time, proposed rectification of all identified
propulsion and ETOPS significant systems problems, as well as events where in-flight starting
capability may be degraded.

AMC 20-6
6.2 METHOD 2: EARLY ETOPS

ETOPS approval is considered feasible at the introduction to service of an airframe/engine
combination as long as the Agency is totally satisfied that all aspects of the approval plan have been
completed. The Agency must be satisfied that the approval plan achieves the level of safety
intended in this AMC and in the aeroplane and engine certification bases. Any non-compliance with
the approval plan can result in a lesser approval than sought for.
(S)TC holders will be required to respond to any incident or occurrence in the most expeditious
manner. A serious single event or series of related events could result in immediate revocation of
ETOPS type design approval. Any isolated problem not justifying immediate withdrawal of approval,
should be addressed within 30 days in a resolution plan approved by the Agency. (S)TC holders will
be reliant on operators to supply incident and occurrence data.
SECTION 7: EVALUATION CRITERIA of the ETOPS type design

The applicant should conduct an evaluation of failures and failure combinations based on engineering and
operational consideration as well as acceptable fail-safe methodology. The evaluation should consider
effects of operations with a single engine, including allowance for additional stress that could result from
failure of the first propulsion system. Unless it can be shown that equivalent safety levels are provided or
the effects of failure are minor, failure and reliability analysis should be used as guidance in verifying that
the proper level of fail-safe design has been provided. Excluding failures of the engine, any system or
equipment failure condition, or combination of failures that affects the aeroplane or engine and that
would result in a need for a diversion, should be considered a Major event (CS 25.1309) and therefore the
probability of such should be compatible with that safety objective. The following criteria are applicable
to the extended range operation of aeroplanes with two engines:
(1) Airframe systems should be shown to comply with CS 25.1309 in accordance with section 7 and 8
of chapter II and Appendix 2 to this AMC.
(2) The propulsion systems should be shown to comply with CS 25.901.
(i) Engineering and operational judgement applied in accordance with the guidance outlined in
section 6 and Appendix 1 should be used to show that the propulsion system can achieve the
desired level of reliability.
(ii) Contained engine failure, cascading failures, consequential damage or failure of remaining
systems or equipment should be assessed in accordance with CS 25.901.
(iii) It should be shown during the type design evaluation that the approved engine limits at all
approved power settings will not be exceeded when conducting an extended duration single-
engine operation during the diversion in all expected environmental conditions. The
assessment should account for the effects of additional engine loading demands (e.g., anti-
icing, electrical, etc.) which may be required during the single-engine flight phase associated
with the diversion
(3) The safety impact of an uncontained engine failure should be assessed in accordance with CS
25.903.
(4) The APU installation, if required for extended range operations, should meet the applicable CS-25
provisions (Subpart J, APU) and any additional requirements necessary to demonstrate its ability to
perform the intended function as specified by the Agency following a review of the applicant's data.

AMC 20-6
If certain extended range operation may necessitate in-flight start and run of the APU, it must be
substantiated that the APU has adequate capability and reliability for that operation.
The APU should demonstrate the required in-flight start reliability throughout the flight envelope
(compatible with overall safety objective but not less than 95%) taking account of all approved fuel
types and temperatures. An acceptable procedure for starting and running the APU (e.g. descent
to allow start) may be defined in order to demonstrate compliance to the required in-flight start
reliability. If this reliability cannot be demonstrated, it may be necessary to require continuous
operation of the APU.
(5) Extended duration, single-engine operations should not require exceptional piloting skills and/or
crew co-ordination. Considering the degradation of the performance of the aeroplane type with an
engine inoperative, the increased flight crew workload, and the malfunction of remaining systems
and equipment, the impact on flight crew procedures should be minimised.
Consideration should also be given to the effects on the crew's and passengers' physiological needs
(e.g., cabin temperature control), when continuing the flight with an inoperative engine or one or
more inoperative airframe system(s).
The provision of essential services to ensure the continued safety of the aeroplane and safety of
the passengers and crew, particularly during very long diversion times with depleted/degraded
systems, should be assessed. The applicant should provide a list of aircraft system functions
considered as necessary to perform a safe ETOPS flight. The applicants should consider the
following examples:
(i) Flight deck and cabin environmental systems integrity and reliability
(ii) The avionics/cooling and consequent integrity of the avionic systems
(iii) Cargo hold fire suppression capacity and integrity of any smoke/fire alerting system
(iv) Brake accumulator or emergency braking system capacity/integrity
(v) Adequate capacity of all time dependent functions
(vi) Pressurisation System integrity/reliability
(vii) Oxygen System integrity/reliability/capacity, if the Maximum Approved Diversion Time is
based on the oxygen system capability
(viii) Integrity/reliability/capacity of back-up systems (e.g. electrical, hydraulic)
(ix) Fuel system integrity and fuel accessibility. Fuel consumption with engine failure and/or
other system failures (see paragraph (11))
(x) Fuel quantity and fuel used, indications and alerts (see paragraph (10)).
(6) It should be demonstrated for extended duration single-engine operation, that the remaining
power (electrical, hydraulic, pneumatic) will continue to be available at levels necessary to permit
continued safe flight and landing, and to provide those services necessary for the overall safety of
the passengers and crew.
Unless it can be shown that cabin pressure can be maintained on single-engine operation at the
altitude necessary for continued flight to an ETOPS en-route alternate aerodrome, oxygen should
be available to sustain the passengers and crew for the maximum diversion time.

AMC 20-6
(7) In the event of any single failure, or any combination of failures not shown to be Extremely
Improbable, it should be shown that electrical power is provided for essential flight instruments,
warning systems, avionics, communications, navigation, required route or destination guidance
equipment, supportive systems and/or hardware and any other equipment deemed necessary for
extended range operation to continue safe flight and landing at an ETOPS en-route alternate
aerodrome. Information provided to the flight crew should be of sufficient accuracy for the
intended operation.
Functions to be provided may differ between aeroplanes and should be agreed with the Agency.
These should normally include:
(i) attitude information;
(ii) adequate radio communication (including the route specific long range communication
equipment as required by the applicable operational regulations) and intercommunication
capability;
(iii) adequate navigation capability (including route specific long range navigation equipment as
required by the applicable operational regulations and weather radar);
(iv) adequate cockpit and instrument lighting, emergency lighting and landing lights;
(v) sufficient captain and first officer instruments, provided cross-reading has been evaluated;
(vi) heading, airspeed and altitude including appropriate pitot/static heating;
(vii) adequate flight controls including auto-pilot;
(viii) adequate engine controls, and restart capability with critical type fuel (from the stand-point
of flame out and restart capability) and with the aeroplane initially at the maximum relight
altitude;
(ix) adequate fuel supply system capability including such fuel boost and fuel transfer functions
that may be necessary;
(x) adequate engine instrumentation;
(xi) such warning, cautions, and indications as are required for continued safe flight and landing;
(xii) fire protection (cargo, APU and engines);
(xiii) adequate ice protection including windshield de-icing;
(xiv) adequate control of cockpit and cabin environment including heating and pressurisation;
and,
(xv) ATC Transponder.
Note: For 90 minutes or less ETOPS operations, the functions to be provided must satisfy the
requirements of CS 25.1351(d)(2) as interpreted by AMC 25.1351(d)(4) and (5).
(8) Three or more reliable and independent electrical power sources should be available. As a
minimum, following failure of any two sources, the remaining source should be capable of powering
the items specified in paragraph (7). If one or more of the required electrical power sources are
provided by an APU, hydraulic system, or ram air turbine, the following criteria apply as
appropriate:

AMC 20-6
(i) The APU, when installed, should meet the criteria in paragraph (4).
(ii) The hydraulic power source should be reliable. To achieve this reliability, it may be necessary
to provide two or more independent energy sources (e.g., bleed air from two or more
pneumatic sources).
(iii) The Ram Air Turbine (RAT) should be demonstrated to be sufficiently reliable in deployment
and use. The RAT should not require engine dependent power for deployment.
If one of the required electrical power sources is provided by batteries, the following criteria apply:
(iv) When one of the 3 independent electrical power sources is time-limited (e.g. batteries), such
power source should have a capability to enable the items required in paragraph (7) to be
powered for continued flight and landing to an ETOPS en-route alternate aerodrome and it
will be considered as a time-limited system in accordance with paragraph (12).
(9) For ETOPS approvals above 180 minutes, in addition to the criteria for electrical power sources
specified in paragraph (8) above, the following criteria should also be applied:
(i) Unless it can be shown that the failure of all 3 independent power sources required by
paragraph (8) above is extremely improbable, following failure of these 3 independent power
sources, a fourth independent power source should be available that is capable of providing
power to the essential functions referred to in paragraph (7) for continued safe flight and
landing to an adequate ETOPS en-route alternate aerodrome
(ii) If the additional power source is provided by an APU, it should meet the criteria in paragraph
(4).
(iii) If the additional power source is provided by a hydraulic system or ram air turbine, the
provisions of paragraph (8) apply.
(10) It should be shown that adequate status monitoring information and procedures on all ETOPS
significant systems are available for the flight crew to make pre-flight, in-flight go/no-go and
diversion decisions.
Adequate fuel quantity information should be available to the flight crew, including alerts, and
advisories, that consider the fuel required to complete the flight, abnormal fuel management or
transfer between tanks, and possible fuel leaks in the tanks, the fuel lines and other fuel system
components and the engines.
(11) Fuel system
(i) The aeroplane fuel system should provide fuel pressure and flow to the engine(s) in
accordance with CS 25.951 and 25.955 for any fuel pump power supply failure condition not
shown to be extremely improbable.
(ii) The fuel necessary to complete the ETOPS mission or during a diversion should be available
to the operating engine(s) under any failure condition, other then fuel boost pump failures,
not shown to be extremely improbable5 (e.g. crossfeed valve failures, automatic fuel
management system failures).
(12) Time-limited system
5
Extremely improbable is defined in CS25.1309 and AMC to CS 25.1309.

AMC 20-6
In addition to the Maximum Approved Diversion Time, diversion time may also be limited by the
capacity of the cargo hold fire suppression system or other ETOPS significant time-limited systems
determined by considering other relevant failures, such as an engine inoperative, and combinations
of failures not shown to be extremely improbable.
Time-limited system capability, if any, must be defined and stated in the Aeroplane Flight Manual
or AFM-supplement and CMP document.
(13) Operation in icing conditions
Airframe and propulsion ice protection should be shown to provide adequate capability (aeroplane
controllability, etc.) for the intended operation. This should account for prolonged exposure to
lower altitudes associated with the single engine diversion, cruise, holding, approach and landing.
(i) The aeroplane should be certified for operation in icing conditions in accordance with CS
25.1419.
(ii) The aeroplane should be capable of continued safe flight and landing in icing conditions at
depressurisation altitudes or engine inoperative altitudes.
The extent of ice accumulation on unprotected surfaces should consider the maximum super cooled
liquid water catch at one-engine inoperative and depressurisation cruise altitudes. Substantiated
icing scenario(s) should be assumed to occur during the period of time when icing conditions are
forecast. The icing episode(s) assumed should be agreed with the Agency. The probability of icing
longer than that assumed, and agreed for the icing episode(s), in combination with the probability
of the aeroplane having to operate in icing conditions (e.g. engine in-flight shut down or
decompression) should be shown to be extremely improbable.
(14) Solutions to achieve required reliability
The permanent solution to a problem should be, as far as possible, a hardware/design solution.
However, if scheduled maintenance, replacement, and/or inspection are utilised to obtain type
design approval for extended range operation, and therefore are required in the CMP standard
document, the specific maintenance information should be easily retrievable and clearly referenced
and identified in an appropriate maintenance document.
(15) Engine Condition Monitoring.
Procedures for an engine condition monitoring process should be defined and validated for ETOPS.
The engine condition monitoring process should be able to determine, if an engine is no longer
capable of providing, within certified engine operating limits, the maximum thrust required for a
single engine diversion. The effects of additional engine loading demands (e.g., anti-ice, electrical),
which may be required during an engine inoperative diversion, should be accounted for.
SECTION 8: ANALYSIS OF FAILURE EFFECTS AND RELIABILITY

8.1 General
The analysis and demonstrations of airframe and propulsion system level of reliability and failure
effects required by section 6 and section 7 should be based on the expected longest diversion time
for extended range routes likely to be flown with the aeroplane. However, in certain failure
scenarios, it may be necessary to consider a shorter diversion time due to the time-limited systems.

AMC 20-6
8.2 Propulsion systems

(i) An assessment of the propulsion system's reliability for particular airframe/engine
combinations should be made in accordance with section 6 and Appendix 1.
(ii) The analysis should consider:
(A) Effects of operation with a single-propulsion system (i.e., high-power demands
including extended use of MCT and bleed requirements, etc.) and include possible
damage that could result from failure of the first propulsion system.
(B) Effects of the availability and management of fuel for propulsion system operation
(i.e., cross-feed valve failures, fuel mismanagement, ability to detect and isolate leaks,
etc.).
(C) Effects of other failures, external conditions, maintenance and crew errors, that could
jeopardise the operation of the remaining propulsion system, should be examined.
(D) Effect of inadvertent thrust reverser deployment, if not shown to be extremely
improbable (includes design and maintenance).
8.3 Airframe systems
An assessment of the airframe system's reliability for particular airframe/engine combinations
should be made in accordance with section 7 and Appendix 2.
The analysis should consider:
(i) Hydraulic Power and Flight Control
An analysis should be carried out taking into account the criteria detailed in paragraph
section 7 paragraph (6).
Consideration of these systems may be combined, since many commercial aeroplanes have
full hydraulically powered controls. For aeroplanes with all flight controls being hydraulically
powered, evaluation of hydraulic system redundancy should show that single failures or
failure combinations, not shown to be extremely improbable, do not preclude continued safe
flight and landing at an ETOPS en-route alternate aerodrome. As part of this evaluation, the
loss of any parts of the hydraulic systems and any engine should be assumed to occur unless
it is established during failure evaluation that there are no sources of damage or the location
of the damage sources are such that this failure condition will not occur.
Note: For 75 minutes or less ETOPS approval, additional analysis to show compliance with
section 7 will not be required for airframe systems, where for basic (non-ETOPS) Type Design
Approval compliance with CS 25.1309, or its equivalent, has already been shown.
(ii) Services Provided by Electrical Power
An analysis should show that the criteria detailed in section 7 paragraphs (6), (7) and (8) are
satisfied taking into account the exposure times established in paragraph (1).
Note1: For 75 minutes or less ETOPS approval, additional analysis to show compliance with
Approval (TDA), compliance with CS 25.1309, or its equivalent, has already been shown.

AMC 20-6
Note 2: For ETOPS approval above 180 minutes, the analysis should also show that the criteria
detailed in section 7 paragraph (9) are satisfied.
(iii) Equipment Cooling
An analysis should establish that the equipment (including avionics) necessary for extended
range operation has the ability to operate acceptably following failure modes in the cooling
system not shown to be extremely improbable. Adequate indication of the proper
functioning of the cooling system should be demonstrated to ensure system operation prior
to dispatch and during flight.
paragraph section 7 will not be required for airframe systems, where for basic (non-ETOPS)
Type Design Approval (TDA), compliance with CS 25.1309, or its equivalent, has already been
shown.
(iv) Cargo Compartment
It should be shown that the cargo compartment design and fire protection system capability
(where applicable) is consistent with the following:
(A) Design
The cargo compartment fire protection system integrity and reliability should be
suitable for the intended operation considering fire detection sensors, liner materials,
etc.
(B) Fire Protection
The capacity/endurance of the cargo compartment fire suppression system should be
established.
(v) Cabin Pressurisation
Authority/Agency approved aeroplane performance data should be available to verify the
ability to continue safe flight and landing after loss of pressure and subsequent operation at
a lower altitude (see also section 7 paragraph (6)).
(vi) Cockpit and Cabin Environment
The analysis should show that an adequate cockpit and cabin environment is preserved
following all combinations of propulsion and electrical system failures which are not shown
to be extremely improbable, e.g. when the aeroplane is operating on standby electrical
power only.
Approval (TDA), compliance with CS 25.1309, or its equivalent, has already been shown.
SECTION 9: ASSESSMENT OF FAILURE CONDITIONS

In assessing the fail-safe features and effects of failure conditions, account should be taken of:
(1) The variations in the performance of the system, the probability of the failure(s), the complexity of
the crew action.

AMC 20-6
(2) Factors alleviating or aggravating the direct effects of the initial failure condition, including
consequential or related conditions existing within the aeroplane which may affect the ability of
the crew to deal with direct effects, such as the presence of smoke, aeroplane accelerations,
interruption of air-to-ground communication, cabin pressurisation problems, etc.
(3) A flight test should be conducted by the (S)TC holders and witnessed by the Agency to validate
expected aeroplane flying qualities and performance considering propulsion system failure,
electrical power losses, etc. The adequacy of remaining aeroplane systems and performance and
flight crew ability to deal with the emergency, considering remaining flight deck information, will
be assessed in all phases of flight and anticipated operating conditions. Depending on the scope,
content, and review by the Agency of the (S)TC holders data base, this flight test could also be used
as a means for approving the basic aerodynamic and engine performance data used to establish
the aeroplane performance identified in chapter III.
(4) Safety assessments should consider the flight consequences of single or multiple system failures
leading to a diversion, and the probability and consequences of subsequent failures or exhaustion
of the capacity of time-limited systems that might occur during the diversion.
Safety assessments should determine:
(i) The effect of the initial failure condition on the capability of the aeroplane to cope with
adverse conditions at the diversion airport, and
(ii) The means available to the crew to assess the extent and evolution of the situation during a
prolonged diversion.
The aeroplane flight manual and the flight crew warning and alerting and display systems should
provide clear information to enable the flight crew to determine when failure conditions are such
that a diversion is necessary.
The assessment of the reliability of propulsion and airframe systems for a particular
airframe/engine combination will be contained in the Agency approved Aeroplane Assessment
Report. In the case the Agency is validating the approval issued by a third country certification
authority, the report may incorporate the assessment report established by the latter.
Following approval of the report, the propulsion and airframe system recommendations will be
included in an Agency-approved CMP document that establishes the CMP standard requirements
for the candidate engine or airframe/engine combination. This document will then be referenced
in the Operation Specification and the Aircraft Flight Manual or AFM-Supplement.
SECTION 10: ISSUE OF THE ETOPS TYPE DESIGN APPROVAL

Upon satisfactory completion of the aeroplane evaluation through an engineering inspection and test
programme consistent with the type certification procedures of the Agency and sufficient in-service
experience data (see Appendix 1 & 2):
(1) The type design approval, the Maximum Approved Diversion Time and demonstrated capability of
any time-limited systems will be reflected in the approved AFM or AFM-Supplement, and the
aeroplane and engine Type Certification Data Sheet or Supplemental Type Certificate which contain
directly or by reference the following pertinent information, as applicable:

AMC 20-6
(i) special limitations (if necessary), including any limitations associated with a maximum
diversion time established in accordance with section 8 paragraph (1) and time-limited
systems (for example, the endurance of cargo hold fire suppression systems);
(ii) additional markings or placards (if required);
(iii) revision to the performance section of the AFM to include the data required by Appendix 4
paragraph 10;
(iv) the airborne equipment, installation, and flight crew procedures required for extended range
operations;
(v) description or reference to the CMP document containing the approved aeroplane standards
for extended range operations;
(vi) a statement to the effect that:
“The Type design, systems reliability and performance of the considered airplane/engine
models combinations have been evaluated by the Agency in accordance with CS-25, CS-E and
AMC 20-6 and found suitable for ETOPS operations when configured, maintained and
operated in accordance with this document. This finding does not constitute an approval to
conduct ETOPS operations.”
(2) The Engine ETOPS Type Design approval and Maximum Approved Diversion Time will be reflected
in the engine Type Certification Data Sheet or Supplemental Type Certificate which contain directly
or by referencing the following pertinent information, as applicable:
(i) special limitations (if necessary), including any limitations associated with the Maximum
Approved Diversion Time should be established;
(ii) additional markings or placards (if required);
(iii) description or reference to a document containing the approved engine configuration.
SECTION 11: CONTINUED AIRWORTHINESS OF THE ETOPS TYPE DESIGN APPROVAL

(1) The Agency will include the consideration of extended range operation in its normal surveillance
and design change approval functions.
(2) The (S)TC holders whose approval includes a type design ETOPS approval, as well as the Agency
should periodically and individually review the in-service reliability of the airframe/engine
combination and of the engine. Further to these reviews and each time that an urgent problem
makes it necessary, in order to achieve and maintain the desired level of reliability and therefore
the safety of ETOPS, the Agency may:
— require that the type design standard be revised, for example by the issuance of an
Airworthiness Directive, or,
— issue an Emergency Conformity Information6.
(3) The Reliability Tracking Board will periodically check that the airframe/propulsion system reliability
requirements for extended range operation are achieved or maintained. For mature ETOPS
6
See EASA Airworthiness Directive Policy reference C.Y001-01 (28.07.08).

AMC 20-6
products the RTB may be replaced by the process to monitor their reliability as defined in Appendix
1, section 6.b and Appendix 2, section 5.c.
Note: Periodically means in this context two years.
(4) Any significant problems which adversely affect extended range operation will be corrected.
Modifications or maintenance actions to achieve or maintain the reliability objective of extended
range operations for the airframe/engine combination will be incorporated into the CMP
document. The Agency will co-ordinate this action with the affected (S)TC holder.
(5) The CMP document which establishes the suitability of an engine or airframe/engine combination
for extended range operation defines the minimum standards for the operation.
Chapter III OPERATIONAL APPROVAL CONSIDERATIONS

SECTION 1: APPLICABILITY
This acceptable means of compliance is for operators seeking an ETOPS operational approval to operate:
(1) Two-engine aeroplanes with a maximum passenger seating configuration of 20 or more, or with a
maximum take-off mass of 45 360 kg or more, in excess of 60 minutes at the approved one-engine-
inoperative speed (under standard conditions in still air) from an adequate aerodrome;
(2) or Two-engine aeroplanes with a maximum passenger seating configuration of 19 or less and a
maximum take-off mass of less than 45 360 kg, in excess of 180 minutes at the approved one-
engine-inoperative speed (in still air) from an adequate aerodrome.
SECTION 2: COMPETENT AUTHORITY

The Competent Authority for the issue of an ETOPS operational approval to an operator is the authority
that has issued its Air Operator Certificate.
Nevertheless, as the operational approval requires the operator to comply with the continuing
airworthiness requirements of Annex 8 of this AMC, the operator has to ensure that the specific ETOPS
elements related to continuing airworthiness are approved by the Competent Authority designated in
Annex I (Part-M) to Regulation (EC) 2042/2003.
SECTION 3: APPLICABLE OPERATIONAL REQUIREMENTS

This chapter details the approval process required for ETOPS in accordance with the operational
requirements7.
SECTION 4: MEthods for obtaining ETOPS Operations APPROVAL

There are two methods for obtaining an ETOPS approval, depending on the availability and amount of
prior experience with the candidate airframe/engine combination:
6. “Accelerated ETOPS approval”, does not require prior in-service experience with the candidate
airframe/engine combination;
7
EU-OPS until operational requirements Part-SPA Subpart-ETOPS are in force.

AMC 20-6
7. “In-service ETOPS Approval”, based on a pre-requisite amount of prior in-service experience with
the candidate airframe/engine combination. Elements from the “accelerated ETOPS approval”
method may be used to reduce the amount of prior in-service experience.
SECTION 5: ACCELERATED ETOPS APPROVAL

The criteria defined in this section permit approval of ETOPS operations up to 180 minutes, when the
operator has established that those processes necessary for successful ETOPS are in place and are proven
to be reliable. The basis of the accelerated approval is that the operator will meet equivalent levels of
safety and satisfy the objectives of this AMC.
The Accelerated ETOPS approval process includes the following phases:
8. Application phase
9. Validation of the operator’s ETOPS processes
10. Validation of Operator ETOPS Continuing Airworthiness and Operations Capability
11. Issue of ETOPS Operations Approval by the competent authority
5.1 Application phase
The operator should submit an Accelerated ETOPS Operations Approval Plan to the Authority six (6)
months before the proposed start of ETOPS. This time will permit the competent authority to
review the documented plans and ensure adequate ETOPS processes are in place.
(A) Accelerated ETOPS Operations approval plan:
The Accelerated ETOPS Operations approval plan should define:
1. the proposed routes and the ETOPS diversion time necessary to support those routes;
2. The proposed one-engine-inoperative cruise speed, which may be area specific
depending upon anticipated aeroplane loading and likely fuel penalties associated with
the planned procedures;
3. How to comply with the ETOPS Processes listed in paragraph (B);
4. The resources allocated to each ETOPS process to initiate and sustain ETOPS
operations in a manner that demonstrates commitment by management and all
personnel involved in ETOPS continuing airworthiness and operational support;
5. How to establish compliance with the build standard required for Type Design
Approval, e.g. CMP document compliance;
6. Review Gates: A review gate is a milestone of the tracking plan to allow for the orderly
tracking and documentation of specific provisions of this section. Normally, the review
gate process will start six months before the proposed start of ETOPS and should
continue until at least six months after the start of ETOPS. The review gate process will
help ensure that the proven processes comply with the provisions of this AMC and are
capable of continued ETOPS operations.
(B) Operator ETOPS process elements

AMC 20-6
The operator seeking Accelerated ETOPS Operations Approval should also demonstrate to
the competent authority that it has established an ETOPS process that includes the following
ETOPS elements:
1. Airframe/engine combination and engine compliance to ETOPS Type Design Build
Standard (CMP);
2. Compliance with the continuing airworthiness requirements as defined in Appendix 8,
which should include:
a. A Maintenance Programme;
b. a proven ETOPS Reliability Programme;
c. A proven Oil Consumption Monitoring Programme;
d. A proven Engine Condition Monitoring and Reporting system;
e. A propulsion system monitoring programme;
f. An ETOPS parts control programme;
g. A proven plan for resolution of aeroplane discrepancies.
3. ETOPS operations manual supplement or its equivalent in the Operations Manual;
4. The operator should establish a programme that results in a high degree of confidence
that the propulsion system reliability appropriate to the ETOPS diversion time would
be maintained;
5. Initial and recurrent training and qualification programmes in place for ETOPS related
personnel, including flight crew and all other operations personnel;
6. Compliance with the Flight Operations Programme as defined in this AMC;
7. Proven flight planning and dispatch programmes appropriate to ETOPS;
8. Procedures to ensure the availability of meteorological information and MEL
appropriate to ETOPS; and
9. Flight crew and dispatch personnel familiar with the ETOPS routes to be flown; in
particular the requirements for, and selection of ETOPS en-route alternate
aerodromes.
(C) Process elements Documentation:
Documentation should be provided for the following elements:
1. Technology new to the operator and significant differences in ETOPS significant
systems (engines, electrical, hydraulic and pneumatic), compared to the aeroplanes
currently operated and the aeroplane for which the operator is seeking Accelerated
ETOPS Operations Approval;
2. The plan to train the flight and continuing airworthiness personnel to the different
ETOPS process elements;

AMC 20-6
3. The plan to use proven or manufacturer validated Training and Maintenance and
Operations Manual procedures relevant to ETOPS for the aeroplane for which the
operator is seeking Accelerated ETOPS Operations Approval;
4. Changes to any previously proven or manufacturer validated Training, Maintenance or
Operations Manual procedures described above. Depending on the nature of any
changes, the operator may be required to provide a plan for validating such changes;
5. The validation plan for any additional operator unique training and procedures
relevant to ETOPS, if any;
6. Details of any ETOPS support programme from the airframe/engine combination or
engine (S)TC holder, other operators or any third country authority or other competent
authority; and
7. The control procedures when a contracted maintenance organisation or flight dispatch
organisation is used.
5.2 Validation of the Operator’s ETOPS Processes
This section identifies process elements that need to be validated and approved prior to the start
of Accelerated ETOPS. For a process to be considered proven, the process should first be described,
including a flow chart of process elements. The roles and responsibilities of the personnel managing
the process should be defined including any training requirement. The operator should
demonstrate that the process is in place and functions as intended. This may be accomplished by
providing data, documentation and analysis results and/or by demonstrating in practise that the
process works and consistently provides the intended results. The operator should also
demonstrate that a feedback loop exists to facilitate the surveillance of the process, based on in-
service experience.
If any operator is currently approved for conducting ETOPS with a different engine and/or
airframe/engine combination, it may be able to document proven ETOPS processes. In this case
only minimal further validation may be necessary. It will be necessary to demonstrate that
processes are in place to assure equivalent results on the engine and/or airframe/engine
combination being proposed for Accelerated ETOPS Operations Approval.
(A) Reduction in the validation requirements:
The following elements will be useful or beneficial in justifying a reduction by the competent
authority in the validation requirements of ETOPS processes:
1. Experience with other airframes and/or engines;
2. Previous ETOPS experience;
3. Experience with long range, over-water operations with two, three or four engine
aeroplanes;
4. Any experience gained by flight crews, continuing airworthiness personnel and flight
dispatch personnel, while working with other ETOPS approved operators, particularly
when such experience is with the same airframe or airframe/engine combination.

AMC 20-6
Process validation may be done on the airframe/engine combination, which will be used in
Accelerated ETOPS operation or on a different aeroplane type than that for which approval
is being sought.
(B) Validation programme:
A process could be validated by demonstrating that it produces equivalent results on a
different aeroplane type or airframe/engine combination. In this case, the validation
programme should address the following:
1. The operator should show that the ETOPS validation programme can be executed in a
safe manner;
2. The operator should state in its application any policy guidance to personnel involved
in the ETOPS process validation programme. Such guidance should clearly state that
ETOPS process validation exercises should not be allowed to adversely impact the
safety of actual operations, especially during periods of abnormal, emergency, or high
cockpit workload operations. It should emphasise that during periods of abnormal or
emergency operation or high cockpit workload ETOPS process validation exercises may
be terminated;
3. The validation scenario should be of sufficient frequency and operational exposure to
validate maintenance and operational support systems not validated by other means;
4. A means should be established to monitor and report performance with respect to
accomplishment of tasks associated with ETOPS process elements. Any recommended
changes resulting from the validation programme to ETOPS continuing airworthiness
and/or operational process elements should be defined.
(C) Documentation requirements for the process validation
The operator should:
1. Document how each element of the ETOPS process was utilised during the validation;
2. Document any shortcomings with the process elements and measures in place to
correct such shortcomings;
3. Document any changes to ETOPS processes, which were required after an in-flight shut
down (IFSD), unscheduled engine removals, or any other significant operational
events;
4. Provide periodic Process Validation reports to the competent authority (this may be
addressed during Review Gates).
(D) Validation programme information
Prior to the start of the validation process, the following information should be submitted to
the competent authority:
1. Validation periods, including start dates and proposed completion dates;
2. Definition of aeroplane to be used in the validation (List should include registration
numbers, manufacturer and serial number and model of the airframe and engines);

AMC 20-6
3. Description of the areas of operation (if relevant to validation) proposed for validation
and actual operations;
4. Definition of designated ETOPS validation routes. The routes should be of duration
required to ensure necessary process validation occurs;
5. Process validation reporting. The operator should compile results of ETOPS process
validation.
5.3 Validation of Operator ETOPS Continuing Airworthiness and Operations Capability
The operator should demonstrate competence to safely conduct and adequately support the
intended operation. Prior to ETOPS approval, the operator should demonstrate that the ETOPS
continuing airworthiness processes are being properly conducted.
The operator should also demonstrate that ETOPS flight dispatch and release practices, policies,
and procedures are established for operations.
An operational validation flight may be required so that the operator can demonstrate dispatch and
normal in-flight procedures. The content of this validation flight will be determined by the
Competent Authority based on the previous experience of the operator.
Upon successful completion of the validation flight, when required, the operator should modify the
operational manuals to include approval for ETOPS as applicable
5.4 ETOPS Operations Approval issued by the Competent Authority
Operations approvals granted with reduced in-service experience may be limited to those areas
determined by the competent authority at time of issue. An application for a change is required for
new areas to be added.
The approval issued by the Competent Authority for ETOPS up to 180 minutes should be based on
the information required in Appendix 3 section 3.
SECTION 6: IN-SERVICE ETOPS APPROVAL

Approval based on in-service experience on the particular airframe/engine combination.
6.1 Application
Any operator applying for ETOPS approval should submit a request, with the required supporting
data, to the competent authority at least 3 months prior to the proposed start of ETOPS with the
specific airframe/engine combination.
6.2 Operator Experience
Each operator seeking approval via the in-service route should provide a report to the competent
authority, indicating the operator’s capability to maintain and operate the specific airframe/engine
combination for the intended extended range operation. This report should include experience with
the engine type or related engine types, experience with the aeroplane systems or related
aeroplane systems, or experience with the particular airframe/engine combination on non-
extended range routes. Approval would be based on a review of this information.
Each operator requesting Approval to conduct ETOPS beyond 180 minutes should already have
ETOPS experience and hold a 180 minute ETOPS approval.

AMC 20-6
Note 1: The operator’s authorised maximum diversion time may be progressively increased by the
competent authority as the operator gains experience on the particular airframe/engine
combination. Not less than 12 consecutive months experience will normally be required before
authorisation of ETOPS up to 180 minutes maximum diversion time, unless the operator can
demonstrate compensating factors. The factors to consider may include duration of experience,
total number of flights, operator’s diversion events, record of the airframe/engine combination
with other operators, quality of operator’s programmes and route structure. However, the operator
will still need, in the latter case, to demonstrate his capability to maintain and operate the new
airframe/engine combination at a similar level of reliability.
In considering an application from an operator to conduct extended range operations, an
assessment should be made of the operator’s overall safety record, past performance, flight crew
training and experience, and maintenance programme. The data provided with the request should
substantiate the operator’s ability and competence to safely conduct and support these operations
and should include the means used to satisfy the considerations outlined in this paragraph. (Any
reliability assessment obtained, either through analysis or service experience, should be used as
guidance in support of operational judgements regarding the suitability of the intended operation.)
6.3 Assessment of the Operator's Propulsion System Reliability
Following the accumulation of adequate operating experience by the world fleet of the specified
airframe/engine combination and the establishment of an IFSD rate objective in accordance with
Appendix 1 for use in ensuring the propulsion system reliability necessary for extended range
operations, an assessment should be made of the applicant’s ability to achieve and maintain this
level of propulsion system reliability.
This assessment should include trend comparisons of the operator’s data with other operators as
well as the world fleet average values, and the application of a qualitative judgement that considers
all of the relevant factors. The operator’s past record of propulsion system reliability with related
types of power units should also be reviewed, as well as its record of achieved systems reliability
with the airframe/engine combination for which authorisation is sought to conduct extended range
operations.
Note: Where statistical assessment alone may not be applicable, e.g., when the fleet size is small,
the applicant’s experience will be reviewed on a case-by-case basis.
6.4 Validation of Operator ETOPS Continuing Airworthiness and Operations Capability
The operator should demonstrate competence to safely conduct and adequately support the
intended operation. Prior to ETOPS approval, the operator should demonstrate that the ETOPS
continuing airworthiness processes are being properly conducted.
The operator should also demonstrate that ETOPS flight dispatch and release practices, policies,
and procedures are established for operations.
An operational validation flight may be required so that the operator can demonstrate dispatch and
normal in-flight procedures. The content of this validation flight will be determined by the Authority
based on the previous experience of the operator.
Upon successful completion of a validation flight, where required, the operational specifications
and manuals should be modified accordingly to include approval for ETOPS as applicable.

AMC 20-6
6.5 ETOPS Operations Approval issued by the Competent Authority

Operations approvals based on in-service experience are limited to those areas agreed by the
Competent Authority at time of issue. Additional approval is required for new areas to be added.
The approval issued by the Competent Authority for ETOPS should specifically include provisions as
described in Appendix 3 section 4.
SECTION 7: ETOPS APPROVAL CATEGORIES

There are 4 approval categories:
12. Approval for 90 minutes or less diversion time
13. Approval for diversion time above 90 minutes up to 180 minutes
14. Approval for diversion time above 180 minutes
15. Approval for diversion times above 180 minutes of operators of two-engine aeroplanes with a
maximum passenger seating configuration of 19 or less and a maximum take-off mass less than
45 360 kg
An operator seeking ETOPS approval in one of the above categories should comply with the requirements
common to all categories and the specific requirements of the particular category for which approval is
sought.
7.1 REQUIREMENTS COMMON TO ALL ETOPS APPROVAL CATEGORIES:
(i) Continuing Airworthiness
The operator should comply with the continuing airworthiness considerations of Appendix 8.
(ii) Release Considerations
(A) Minimum Equipment List (MEL)
Aeroplanes should only be operated in accordance with the provisions of the approved
Minimum Equipment List (MEL).
(B) Weather
To forecast terminal and en-route weather, an operator should only use weather
information systems that are sufficient reliable and accurate in the proposed area of
operation.
(C) Fuel
Fuel should be sufficient to comply with the critical fuel scenario as described in
Appendix 4 to this AMC.
(iii) Flight Planning
The effects of wind and temperature at the one-engine-inoperative cruise altitude should be
accounted for in the calculation of equal-time point. In addition to the nominated ETOPS en-
route alternates, the operator should provide flight crews with information on adequate
aerodromes on the route to be flown which are not forecast to meet the ETOPS en-route
alternate weather minima. Aerodrome facility information and other appropriate planning

AMC 20-6
data concerning these aerodromes should be provided before commencement of the flight
to flight crews for use when executing a diversion.
(iv) Flight Crew Training
The operator’s ETOPS training programme should provide initial and recurrent training for
flight crew in accordance with Appendix 6.
(v) En-route Alternate
Appendix 5 to this AMC should be implemented when establishing the company operational
procedures for ETOPS.
(vi) Communications Equipment (VHF/HF, Data Link, Satellite Communications)
For all routes where voice communication facilities are available, the communication
equipment required by operational requirements should include at least one voice-based
system.
7.2 SPECIFIC REQUIREMENTS:
7.2.1 APPROVAL FOR 90 MINUTES OR LESS DIVERSION TIME
The Operator’s Approved Diversion Time is an operational limit that should not exceed
either:
— the Maximum Approved Diversion Time or,
— the time-limited system capability minus 15 minutes.
If the airframe/engine combination does not yet have a Type Design approval for at least
90 minutes diversion time, the aircraft should satisfy the relevant ETOPS design
requirements.
Consideration may be given to the approval of ETOPS up to 90 minutes for operators with
minimal or no in-service experience with the airframe/engine combination. This
determination considers such factors as the proposed area of operations, the operator's
demonstrated ability to successfully introduce aeroplanes into operations and the quality of
the proposed continuing airworthiness and operations programmes.
Minimum Equipment List (MEL) restrictions for 120 minutes ETOPS should be used unless
there are specific restrictions for 90 minutes or less.
7.2.2 APPROVAL FOR DIVERSION TIME ABOVE 90 MINUTES UP TO 180 MINUTES
Prior to approval, the operator’s capability to conduct operations and implement effective
ETOPS programmes, in accordance with the criteria detailed in this AMC and the relevant
appendices, will be examined.
The Operator’s Approved Diversion Time is an operational limit that should not exceed
either:
— the Maximum Approved Diversion Time, or,

AMC 20-6
i) Additional Considerations for aircraft with 120 minutes Maximum Approved Diversion
Time
In the case of an aircraft approved for 120 minutes Maximum Approved
Diversion Time, an operator may request an increase in the operator’s approved
diversion time for specific routes provided:
1. The requested Operator’s Approved Diversion Time does not exceed
either:
— 115% of the Maximum Approved Diversion Time or,
2. The aeroplane fuel carriage supports the requested Operator’s Approved
Diversion Time.
3. It can be shown that the resulting routing will not reduce the overall
safety of the operation.
Such increases will require:
(A) the Agency to assess overall type design including time-limited
systems, demonstrated reliability; and
(B) the development of an appropriate MEL related to the diversion
time required.
ii) Additional Considerations for aircraft with 180 minutes Maximum Approved Diversion
Time
In the case of an aircraft certified for 180 minutes Maximum Approved Diversion Time,
an operator may request an increase in the operator’s approved diversion time for
specific routes provided:
1. The requested Operator’s Approved Diversion Time does not exceed either:
— 115% of the Maximum Approved Diversion Time or,
— the time-limited system capability minus 15 minutes
2. The aeroplane fuel carriage supports the requested Operator’s Approved
Diversion Time diversion time
3. It can be shown that the resulting routing will not reduce the overall safety of
the operation.
Such increases will require:
(A) the Agency to assess overall type design including time-limited systems,
demonstrated reliability; and
(B) the development of an appropriate MEL related to the diversion time
required.
7.2.3 APPROVAL FOR DIVERSION TIME ABOVE 180 MINUTES

AMC 20-6
Approval to conduct operations with diversion times exceeding 180 minutes may be granted
to operators with previous ETOPS experience on the particular engine/airframe combination
and an existing 180 minute ETOPS approval on the airframe/engine combination listed in
their application.
Operators should minimise diversion time along the preferred track. Increases in diversion
time by disregarding ETOPS adequate aerodromes along the route, should only be planned
in the interest of the overall safety of the operation.
The approval to operate more than 180 minutes from an adequate aerodrome shall be area
specific, based on the availability of adequate ETOPS en-route alternate aerodromes.
(i) Operating limitations
In view of the long diversion time involved (above 180 minutes), the operator is
responsible to ensure at flight planning stage, that on any given day in the forecast
conditions, such as prevailing winds, temperature and applicable diversion
procedures, a diversion to an ETOPS en-route alternate aerodrome will not exceed the:
(A) Engine-related time-limited systems capability minus 15 minutes at the
approved one-engine-inoperative cruise speed; and
(B) Non engine-related time-limited system capability minus 15 minutes, such as
cargo fire suppression, or other non engine-related system capability at the all
engine operative cruise speed.
(ii) Communications Equipment (VHF/HF, Data Link and Satellite based communications)
Operators should use any or all of these forms of communications to ensure
communications capability when operating ETOPS in excess of 180 minutes.
7.2.4 APPROVAL FOR DIVERSION TIMES ABOVE 180 MINUTES OF OPERATORS OF TWO-ENGINE
AEROPLANES WITH A MAXIMUM PASSENGER SEATING CONFIGURATION OF 19 OR LESS AND
A MAXIMUM TAKE-OFF MASS LESS THAN 45 360 KG
(i) Type Design
The airframe/engine combination should have the appropriate Type Design approval
for the requested maximum diversion times in accordance with the criteria in CS
25.1535 and chapter II ‘Type Design Approval Considerations’ of this AMC.
(ii) Operations Approval
Approval to conduct operations with diversion times exceeding 180 minutes may be
granted to operators with experience on the particular airframe/engine combination
or existing ETOPS approval on a different airframe/engine combination, or equivalent
experience. Operators should minimise diversion time along the preferred track to
180 minutes or less whenever possible. The approval to operate more than 180
minutes from an adequate aerodrome shall be area specific, based on the availability
of alternate aerodromes, the diversion to which would not compromise safety.
Note: Exceptionally for this type of aeroplanes, operators may use the accelerated
ETOPS approval method to gain ETOPS approval. This method is described in section
5.

AMC 20-6
SECTION 8: ETOPS OPERATIONS MANUAL SUPPLEMENT

The ETOPS operations manual supplement or its equivalent material in the operations manual, and any
subsequent amendments, are subject to approval by the Competent Authority.
The Authority will review the actual ETOPS in-service operation. Amendments to the Operations Manual
may be required as a result. Operators should provide information for and participate in such reviews,
with reference to the (S)TC holder where necessary. The information resulting from these reviews should
be used to modify or update flight crew training programmes, operations manuals and checklists, as
necessary.
An example outline of ETOPS Operations Manual Supplement content is provided in Appendix 7 to this
AMC.
SECTION 9: FLIGHT PREPARATION AND IN-FLIGHT PROCEDURES

The operator should establish pre-flight planning and dispatch procedures for ETOPS and they should be
listed in the Operations Manual. These procedures should include, but not be limited to, the gathering
and dissemination of forecast and actual weather information, both along the route and at the proposed
ETOPS alternate aerodromes. Procedures should also be established to ensure that the requirements of
the critical fuel scenario are included in the fuel planning for the flight.
The procedures and manual should require that sufficient information is available for the aeroplane pilot-
in-command, to satisfy him/her that the status of the aeroplane and relevant airborne systems is
appropriate for the intended operation. The manual should also include guidance on diversion decision-
making and en-route weather monitoring.
Additional guidance on the content of the “Flight Preparation and In-Flight Procedures” section of the
operations manual is provided in Appendix 4 to this AMC.
SECTION 10: OPERATIONAL LIMITATIONS

The operational limitations to the area of operations and the Operator’s Approved Diversion Time are
detailed in Appendix 3 to this AMC – “Operational Limitations”.
SECTION 11: ETOPS EN-ROUTE ALTERNATE AERODROMES

An operator should select ETOPS en-route alternate aerodromes in accordance with the applicable
operational requirements and Appendix 5 to this AMC - Route Alternate.
SECTION 12: INITIAL/RECURRENT TRAINING

An operator should ensure that prior to conducting ETOPS, each crew member has completed successfully
ETOPS training and checking in accordance with a syllabus compliant with Appendix 7 to this AMC,
approved by the Competent Authority and detailed in the Operations Manual.
This training should be type and area specific in accordance with the applicable operational requirements.
The operator should ensure that crew members are not assigned to operate ETOPS routes for which they
have not successfully passed the training.

AMC 20-6
SECTION 13: CONTINUING SURVEILLANCE

The fleet-average IFSD rate for the specified airframe/engine combination will continue to be monitored
in accordance with Appendices 1, 2 and 8. As with all other operations, the Competent Authority should
also monitor all aspects of the extended range operations that it has authorised to ensure that the levels
of reliability achieved in extended range operations remain at the necessary levels as provided in Appendix
1, and that the operation continues to be conducted safely. In the event that an acceptable level of
reliability is not maintained, if significant adverse trends exist, or if significant deficiencies are detected in
the type design or the conduct of the ETOPS operation, then the appropriate Competent Authority should
initiate a special evaluation, impose operational restrictions if necessary, and stipulate corrective action
for the operator to adopt in order to resolve the problems in a timely manner. The appropriate Authority
should alert the Certification Authority when a special evaluation is initiated and make provisions for their
participation.
[Amdt 20/7]

AMC 20-6
Appendix 1 to AMC 20-6 – Propulsion System Reliability Assessment

1. ASSESSMENT PROCESS
To establish by utilising service experience whether a particular airframe/engine combination has
satisfied the propulsion systems reliability requirements for ETOPS, an engineering assessment will
be made by the Agency, using all pertinent propulsion system data. To accomplish the assessment,
the Agency will need world fleet data (where available), and data from various sources (the
operator, the engine and aeroplane (S)TC holder) which should be extensive enough and of
sufficient maturity to enable the Agency to assess with a high level of confidence, using engineering
and operational judgement and standard statistical methods where appropriate, that the risk of
total power loss from independent causes is sufficiently low. The Agency will state whether or not
the current propulsion system reliability of a particular airframe/engine combination satisfies the
relevant criteria. Included in the statement, if the operation is approved, will be the engine build
standard, propulsion system configuration, operating condition and limitations required to qualify
the propulsion system as suitable for ETOPS.
Alternatively, where type design approval for Early ETOPS is sought at entry into service, the
engineering assessment can be based on substantiation by analysis, test, in-service experience or
other means, to show that the propulsion system will minimise failures and malfunctions and will
achieve an IFSD rate that is compatible with the specified safety target associated with total loss of
thrust.
If an approved engine CMP is maintained by the responsible engine Authority and is duly referenced
on the engine Type Certificate Data Sheet or STC, then this shall be made available to the Agency
conducting the aeroplane propulsion system reliability assessment. Such a CMP shall be produced
taking into account all the requirements of chapter II and should be incorporated or referenced in
the aeroplane CMP.
2. RELIABILITY VALIDATION METHODS
There are two extremes in the ETOPS process with respect to maturity; one is the demonstration
of stable reliability by the accumulation of in-service experience and the other is by a programme
of design, test and analysis, agreed between the (S)TC holders and the Agency. The extent to which
a propulsion system is a derivative of previous propulsion systems used on an ETOPS approved
airplane is also a factor of the level of maturity. When considering the acceptability of a propulsion
system, maturity should be assessed not only in terms of total fleet hours but also taking account
of fleet leader time over a calendar time and the extent to which test data and design experience
can be used as an alternative.
a. Service Experience
There is justification for the view that modern propulsion systems achieve a stable reliability
level by 100,000 engine hours for new types and 50,000 engine hours for derivatives. 3,000
to 4,000 engine hours is considered to be the necessary time in service for a specific unit to
indicate problem areas.
Normally, the in-service experience will be:

AMC 20-6
(1) For new propulsion systems: 100,000 engine hours and 12 months service. Where
experience on another aeroplane is applicable, a significant portion of the 100,000
engine hours should normally be obtained on the candidate aeroplane;
On a case-by-case basis, relevant test and design experience, and maximum diversion
time requested, could be taken into account when arriving at the in-service experience
required;
(2) For derivative propulsion systems: 50,000 engine hours and 12 months service. These
values may vary according to the degree of commonality. To this end in determining
the derivative status of a propulsion system, consideration should be given to technical
criteria referring to the commonality with previous propulsion system used on an
ETOPS approved aeroplane. Prime areas of concern include:
(i) Turbomachinery;
(ii) Controls and accessories and control logic;
(iii) Configuration hardware (piping, cables etc.);
(iv) Aeroplane to engine interfaces and interaction:
(A) Fire;
(B) Thrust reverser;
(C) Avionics;
(D) etc.
The extent to which the in-service experience might be reduced would depend upon
the degree of commonality with previous propulsion system used on an ETOPS
approved aeroplane using the above criteria and would be decided on a case-by-case
basis.
Also on a case-by-case basis, relevant test and design experience and maximum
diversion time requested could be taken into account when arriving at the in-service
experience required.
Thus, the required experience to demonstrate propulsion system reliability should be
determined by:
(i) The extent to which previous service experience with a common propulsion
system used on an ETOPS approved aeroplane systems can be considered;
(ii) To what extent compensating factors, such as design similarity and test
evidence, can be used;
(iii) The two preceding considerations would then determine the amount of service
experience needed for a particular propulsion system proposed for ETOPS.
These considerations would be made on a case-by-case basis and would need to
provide a demonstrated level of propulsion system reliability in terms of IFSD rate. See
paragraph 3 ‘Risk Management and Risk Model’.
(3) Data Required for the Assessment

AMC 20-6
(i) A list of all engine shutdown events for all causes (excluding normal training
events). The list should provide the following for each event:
(A) date;
(B) airline;
(C) aeroplane and engine identification (model and serial number);
(D) power-unit configuration and modification history;
(E) engine position;
(F) symptoms leading up to the event, phase of flight or ground operation;
(G) weather/environmental conditions and reason for shutdown and any
comment regarding engine restart potential;
(ii) All occurrences where the intended thrust level was not achieved, or where
crew action was taken to reduce thrust below the normal level (for whatever
reason):
(iii) Unscheduled engine removals/shop visit rates;
(iv) Total engine hours and aeroplane cycles;
(v) All events should be considered to determine their effects on ETOPS operations;
(vi) Additional data as required;
(vii) The Agency will also consider relevant design and test data.
b. Early ETOPS
(1) Acceptable Early ETOPS certification plan
Where type design approval for Early ETOPS is sought at the first entry into service, the
engineering assessment can be based on substantiation by analysis, test, in-service
experience, CS-E 1040 compliance or other means to show that the propulsion system
will minimise failures and malfunctions, and will achieve an IFSD rate that is compatible
with the specified safety target associated with catastrophic loss of thrust. An approval
plan, defining the early ETOPS reliability validation tests and processes, must be
submitted by the applicant to the Agency for agreement. This plan must be
implemented and completed to the satisfaction of the Agency before an ETOPS type
design approval will be granted for a propulsion system.
(2) Propulsion System Validation Test
The propulsion system for which approval is being sought should be tested in
accordance with the following schedule. The propulsion system for this test should be
configured with the aeroplane installation nacelle and engine build-up hardware
representative of the type certificate standards.
Tests of simulated ETOPS service operation and vibration endurance should consist of
3,000 representative service start-stop cycles (take-off, climb, cruise, descent,
approach, landing and thrust reverse), plus three simulated diversions at maximum
continuous thrust for the Maximum Approved Diversion Time for which ETOPS

AMC 20-6
eligibility is sought. These diversions are to be approximately evenly distributed over

the cyclic duration of the test, with the last diversion to be conducted within 100 cycles
of the completion of the test.
This test must be run with the high speed and low speed main engine rotors
unbalanced to generate at least 90 percent of the applicant’s recommended
maintenance vibration levels. Additionally, for engines with three main engine rotors,
the intermediate speed rotor must be unbalanced to generate at least 90 percent of
the applicant’s recommended acceptance vibration level. The vibration level shall be
defined as the peak level seen during a slow acceleration/deceleration of the engine
across the operating speed range. Conduct the vibration survey at periodic intervals
throughout the 3000 cycle test. The average value of the peak vibration level observed
in the vibration surveys must meet the 90% minimum requirement. Minor adjustments
in the rotor unbalance (up or down) may be necessary as the test progresses in order
to meet the required average vibration level requirement. Alternatively, to a method
acceptable to the Agency, an applicant may modify their test to accommodate a
vibration level marginally less than 90% or greater than 100% of the vibration level
required in lieu of adjusting rotor unbalance as the test progresses.
Each one hertz (60 rpm) bandwidth of the high speed rotor service start-stop cycle
speed range (take-off, climb, cruise, descent, approach, landing and thrust reverse)
must be subjected to 3x106 vibration cycles. An applicant may conduct the test in any
rotor speed step increment up to 200 rpm as long as the service start-stop cycle speed
range is covered. For a 200 rpm step the corresponding vibration cycle count is to be
10 million cycles. In addition, each one hertz bandwidth of the high speed rotor
transient operational speed range between flight idle and cruise must be subjected to
3x105 vibration cycles. An applicant may conduct the test in any rotor speed step
increment up to 200 rpm as long as the transient service speed range is covered. For a
200 rpm step the corresponding vibration cycle count is to be 1 million cycles.
At the conclusion of the test, the propulsion system must be:
(i) Visually inspected according to the applicant’s on-wing inspection
recommendations and limits.
(ii) Completely disassembled and the propulsion system hardware must be
inspected in accordance with the service limits submitted in compliance with
relevant instructions for continued airworthiness. Any potential sources of in-
flight shutdown, loss of thrust control, or other power loss encountered during
this inspection must be tracked and resolved in accordance with paragraph 5 of
this Appendix 1.
3. RISK MANAGEMENT AND RISK MODEL
Propulsion systems approved for ETOPS must be sufficiently reliable to assure that defined safety
targets are achieved.
a. For ETOPS with a Maximum Approved Diversion Time of 180 minutes or less
An early review of information for modern fixed-wing jet-powered aircraft shows that the
rate of fatal accidents for all causes is in the order of 0·3 x 10-6 per flying hour. The reliability

AMC 20-6
of aeroplane types approved for extended range operation should be such that they achieve
at least as good an accident record as equivalent technology equipment. The overall target
of 0 3 x 10-6 per flying hour has therefore been chosen as the safety target for ETOPS
approvals up to 180 minutes.
When considering safety targets, an accepted practice is to allocate appropriate portions of
the total to the various potential contributing factors. By applying this practice to the overall
target of 0·3 x 10 -6 per flying hour, in the proportions previously considered appropriate,
the probability of a catastrophic accident due to complete loss of thrust from independent
causes must be no worse than 0·3 x 10-8 per flying hour.
Propulsion system related accidents may result from independent cause events but, based
on historical evidence, result primarily from events such as uncontained engine failure
events, common cause events, engine failure plus crew error events, human error related
events and other. The majority of these factors are not specifically exclusive to ETOPS.
Using an expression developed by ICAO, (ref. AN-WP/5593 dated 15/2/84) for the calculation
of engine in-flight shutdown rate, together with the above safety objective and accident
statistics, a relationship between target engine in-flight shutdown rate for all independent
causes and maximum diversion time has been derived. This is shown in Figure 1.
In order that type design approval may be granted for extended operation range, it will be
necessary to satisfy the Agency that after application of the corrective actions identified
during the engineering assessment (see Appendix 1, section 4: ENGINEERING ASSESSMENT.
CRITERIA FOR ACCEPTABLE RELIABILITY VALIDATION METHODS), the target engine in-flight
shutdown rates will be achieved. This will provide assurance that the probability objective
for loss of all thrust due to independent causes will be met.

AMC 20-6
Target IFSD Rates vs Diversion Time

2-engined aeroplane
Diversion Times 180 minutes or less
0.040
IFSD rate/1000 engine hours
0.030
0.020
60 90 120 150 180
Diversion Time (minutes)
Figure 1
b. For ETOPS with a Maximum Approved Diversion Time of greater than 180 minutes
The propulsion systems IFSD rate target should be compatible with the objective that the
catastrophic loss of thrust from independent causes is no worse than extremely improbable,
based on maximum ETOPS flight duration and maximum ETOPS rule time.
For ETOPS with Maximum Approved Diversion Times longer than 180 minutes, to meet this
objective the powerplant installations must comply with the safety objectives of CS 25.1309,
the goal should be that the catastrophic loss of thrust from independent causes should be
extremely improbable (see AMC 25.1309). The defined target for ETOPS approvals with
diversion times of 180 minutes or less, for catastrophic loss of thrust from independent
causes, is 0.3x10-8/hr (see paragraph 3 of this Appendix). This target was based on engine
IFSD rates that were higher than can be and are being achieved by modern ETOPS
airframes/engines. To achieve the same level of safety for ETOPS approvals beyond
180 minutes as has been achieved for ETOPS approvals of 180 minutes or less, the propulsion
system reliability IFSD rate target needs to be set and maintained at a level that is compatible
with an Extremely Improbable safety objective (i.e. 1.0x10-9/ flight hr).
For example, a target overall IFSD rate of 0.01/1000 hr. (engine hours) that is maintained
would result in the loss of all thrust on two engine aeroplanes being extremely improbable
even assuming the longest time envisaged. The risk model formula summarised for a two-
engine aeroplane is:
p/flight hour = [2(Cr x{T-t}) x Mr(t)] divided by T
(1) p is the probability of a dual independent propulsion unit failure on a twin,

AMC 20-6
(2) 2 is the number of opportunities for an engine failure on a twin (2),

(3) Cr is cruise IFSD rate (0.5x overall rate), Mr is max continuous IFSD rate (2x overall
rate), T is planned max flight duration in hours (departure to planned arrival airport),
and t is the diversion or flight time in hours to a safe landing. IFSD rates, based on
engine manufacturers’ historical data from the last ten years of modern large turbofan
engines, presented to the JAA/EASA and ARAC ETOPS working groups, have shown
cruise IFSD rates to be of the order of 0.5x overall rate, and the max continuous IFSD
rate (estimated from engine fleet analysis) to be 2x overall rate. Then, for an IFSD goal
of .010/1000EFH overall, the cruise IFSD rate is .005/1000EFH, and the max continuous
rate is .020/1000EFH.
(4) Sample calculation (max flight case scenario): assume T = 20 hour max flight duration,
an engine failure after 10 hours, then continued flight time required is t = 10 hours,
using the ETOPS IFSD goal of .010/1000EFH or less, results in a probability of p=1 E-
9/hour (i.e. meets extremely improbable safety objective from independent causes).
Figure 2
Target IFSD Rates vs Diversion Time

2-engined aeroplane
Diversion Times above 180 minutes
0.015
IFSD rate/1000 engine hours
0.014
0.013
0.012
0.011
0.010
0.009
0.008
3 4 5 6 7 8 9 10
Diversion Time (hours)
4. ENGINEERING ASSESSMENT CRITERIA FOR ACCEPTABLE RELIABILITY VALIDATION METHODS

The following criteria identify some areas to be considered during the engineering assessment
required for either reliability validation method.

AMC 20-6
a. There are maintenance programmes, engine on-wing health monitoring programmes, and
the promptness and completeness in incorporating engine service bulletins, etc., that
influence an operator’s ability to maintain a level of reliability. The data and information
required will form a basis from which a world-fleet engine shut down rate will be established,
for use in determining whether a particular airframe/engine combination complies with
criteria for extended range operation.
b. An analysis will be made on a case-by-case basis, of all significant failures, defects and
malfunctions experienced in service or during testing, including reliability validation testing,
for the particular airframe/engine combination. Significant failures are principally those
causing or resulting in in-flight shut down or flameout of the engine(s), but may also include
unusual ground failures and/or unscheduled removal of engines. In making the assessment,
consideration should be given to the following:
(1) The type of propulsion system, previous experience, whether the power-unit is new or
a derivative of an existing model, and the operating thrust level to be used after one
engine shutdown;
(2) The trends in the cumulative twelve month rolling average, updated quarterly, of in-
flight shutdown rates versus propulsion system flight hours and cycles;
(3) The demonstrated effect of corrective modifications, maintenance, etc. on the
possible future reliability of the propulsion system;
(4) Maintenance actions recommended and performance and their effect on propulsion
system and APU failure rates;
(5) The accumulation of operational experience which covers the range of environmental
conditions likely to be encountered;
(6) Intended maximum flight duration and maximum diversion in the ETOPS segment,
used in the extended range operation under consideration.
c. Engineering judgement will be used in the analysis of paragraph b. above, such that the
potential improvement in reliability, following the introduction of corrective actions
identified during the analysis, can be quantified.
d. The resultant predicted reliability level and the criteria developed in accordance with section
3 (RISK MANAGEMENT AND RISK MODEL) should be used together to determine the
maximum diversion time for which the particular airframe/engine combination qualifies.
e. The type design standard for type approval of the airframe/engine combination, and the
engine, for ETOPS will include all modifications and maintenance actions for which full or
partial credit is taken by the (S)TC holder and other actions required by the Agency to
enhance reliability. The schedule for incorporation of type design standard items should
normally be established in the Configuration, Maintenance and Procedures (CMP) document,
for example in terms of calendar time, hours or cycles.
f. When third country (S)TC holders’ and/or third country operator’s data are evaluated, the
respective foreign Authorities will be offered to participate in the assessment.
g. ETOPS Reliability Tracking Board (RTB)’s Findings.

AMC 20-6
Once an assessment has been completed and the RTB has documented its findings, the
Agency will declare whether or not the particular airframe/engine combination and engine
satisfy the relevant considerations of this AMC. Items recommended qualifying the
propulsion system, such as maintenance requirements and limitations will be included in the
Assessment Report (chapter II section 10 of this AMC).
h. In order to establish that the predicted propulsion system reliability level is achieved and
subsequently maintained, the (S) TC holder should submit to the Agency an assessment of
the reliability of the propulsion system on a quarterly basis. The assessment should
concentrate on the ETOPS configured fleet and should include ETOPS related events from the
non-configured fleet of the subject airframe/engine combination and from other
combinations utilising a related engine model.
5. EARLY ETOPS OCCURRENCES REPORTING & TRACKING
a. The holder of a (supplemental) type certificate of an engine, which has been approved for
ETOPS without service experience in accordance with this AMC, should establish a system to
address problems and occurrences encountered on the engine that could affect the safety of
operations and timely resolution.
b. The system should contain a means for: the prompt identification of ETOPS related events,
the timely notification of the event to the Agency, proposing a resolution of the event and
obtaining Agency’s approval. The implementation of the problem resolution can be
accomplished by way of Agency approved change(s) to the type design, the manufacturing
process, or an operating or maintenance procedure.
c. The reporting system should be in place for at least the first 100,000 fleet engine hours. The
reporting requirement remains in place until the fleet has demonstrated a stable in-flight
shut down rate in accordance with the targets defined in this Appendix 1.
d. For the early ETOPS service period, an applicant must define the sources and content of the
service data that will be made available to them in support of their occurrence reporting and
tracking system. The content of this data should be adequate to evaluate the specific cause
of all service incidents reportable under Part 21A.3(c), in addition to the occurrences that
could affect the safety of operations, and should be reported, including:
(1) In-flight shut down events and rates;
(2) Inability to control the engine or obtain desired power;
(3) Precautionary thrust reductions (except for normal troubleshooting as allowed in the
aircraft flight manual);
(4) Degraded propulsion in-flight start capability;
(5) un-commanded power changes or surges.
(6) diversion or turn-back
(7) failures or malfunctions of ETOPS significant systems
(8) Unscheduled engine removals for conditions that could result in one of the reportable
items listed above.

AMC 20-6
6. CONTINUED AIRWORTHINESS OF TYPE DESIGN

For ETOPS, the Agency will periodically review its original findings by means of a Reliability Tracking
Board. In addition, the Agency document containing the CMP standard will be revised as necessary.
Note: The Reliability Tracking Board will usually comprise specialists from aeroplane and engine
disciplines (see also Appendix 2).
Periodic meetings of the ETOPS Reliability Tracking Board are normally frequent at the start of the
assessment of a new product. The periodicity is adjusted by the Agency upon accumulation of
substantial service experience if there is evidence that the reliability of the product is sufficiently
stable. The periodic meetings of the board are discontinued once an ETOPS product, or family of
products, has been declared mature by the Agency.
Note: The overall engine IFSD rate should be viewed as a world-fleet average target figure of engine
reliability (representative of the airframe/engine combination being considered) and if exceeded,
may not, in itself, trigger action in the form of a change to the ETOPS design standard or a reduction
in the ETOPS approval status of the engine. The actual IFSD rate and its causes should be assessed
with considerable engineering judgement. For example, a high IFSD rate early after the
commencement of the operation may be due to the limited number of hours contributing to the
high rate. There may have been only one shut down. The underlying causes have to be considered
carefully. Conversely, a particular single event may warrant corrective action implementation, even
though the overall IFSD rate objective is being achieved.
a. Mature ETOPS products
A family of ETOPS products with a high degree of similarity is considered as mature ones if:
(1) The product family has accumulated at least 250,000 flight hours for an aeroplane
family or 500,000 operating hours for an engine family;
(2) The product family has accumulated service experience covering a comprehensive
spectrum of operating conditions (e.g. cold, hot, high, and humid);
(3) Each ETOPS approved model or variant in the family has achieved the reliability
objectives for ETOPS and has remained stable at or below the objectives fleet-wide for
at least two years;
New models or significant design changes may not be considered mature until they have
individually satisfied the condition of paragraph 6.a above.
The Agency makes the determination of when a product or a product family is considered
mature.
b. Surveillance of mature ETOPS products
The (S)TC holder of an ETOPS product which the Agency has found mature, should institute
a process to monitor the reliability of the product in accordance with the objectives defined
in this Appendix 1. In case of occurrence of an event or series of events or a statistical trend
that implies a deviation of the reliability of the ETOPS fleet, or a portion of the ETOPS fleet
(e.g. one model or a range of serial numbers), above the limits specified for ETOPS in this
AMC, the (S)TC holder should:

AMC 20-6
(1) Inform the Agency and define a means to restore the reliability through a Minor
Revision of the CMP document, with a compliance schedule to be agreed with the
Agency if the situation has no immediate safety impact;
(2) Inform the Agency and propose an ad-hoc follow-up by the Agency until the concern
has been alleviated or confirmed if the situation requires further assessment;
(3) Inform the Agency and propose the necessary corrective action(s) to be mandated by
the Agency through an AD if a direct safety concern exists.
In the absence of a specific event or trend requiring action, the (S)TC holder should provide
the Agency with the basic statistical indicators prescribed in this Appendix 1 on a yearly basis.
c. Minor Revision of the ETOPS CMP Document
A Minor Revision of the ETOPS CMP document is one that contains only editorial
adjustments, configurations, maintenance and procedures equivalent to those already
approved by the Agency or new reliability improvements which have no immediate impact
on the safety of ETOPS flights and which are introduced as a means to control the continued
compliance with the reliability objectives of ETOPS.
Minor revisions of the ETOPS CMP document should be approved by authorised signatories
personnel of the (S)TC holder under the provisions of its approved Design Organisation
Handbook.
7. DESIGN ORGANISATION APPROVALS
(S)TC holders of products approved for ETOPS should hold a Design Organisation Approval (DOA)
conforming to EASA Part-21, with the appropriate terms of approval and privileges. Their approved
Design Organisation Handbook (DOH) must contain an appropriate description of the organisation
and procedures covering all applicable tasks and responsibilities of EASA Part-21 and this AMC.
[Amdt 20/7]

AMC 20-6
Appendix 2 to AMC 20-6 – Aircraft Systems Reliability Assessment

1. ASSESSMENT PROCESS
The intent of this Appendix is to provide additional clarification to sections 7 and 8 of chapter II of
this AMC. Airframe systems are required to show compliance with CS 25.1309. To establish whether
a particular airframe/engine combination has satisfied the reliability requirements concerning the
aircraft systems for extended range operations, an assessment will be made by the Agency, using
all pertinent systems data provided by the applicant. To accomplish this assessment, the Agency
will need world-fleet data (where available) and data from various sources (operators, (S)TC holder,
original equipment manufacturers (OEM)). This data should be extensive enough and of sufficient
maturity to enable the Agency to assess with a high level of confidence, using engineering and
operational judgement, that the risk of systems failures during a normal ETOPS flight or a diversion,
is sufficiently low in direct relationship with the consequence of such failure conditions, under the
operational environment of ETOPS missions.
The Agency will declare whether or not the current system reliability of a particular airframe/engine
combination satisfies the relevant criteria.
Included in the declaration, if the airframe/engine combination satisfy the relevant criteria, will be
the airframe build standard, systems configuration, operating conditions and limitations, required
to qualify the ETOPS significant systems as suitable for extended range operations.
Alternatively, where type design approval for Early ETOPS is sought at first entry into service, the
engineering assessment can be based on substantiation by analysis, test, in-service experience or
other means to show that the airframe significant systems will minimise failures and malfunctions,
and will achieve a failure rate that is compatible with the specified safety target.
2. SYSTEM SAFETY ASSESSMENT ‘SSA’ (including reliability analysis)
The System Safety Assessment (SSA) which should be conducted in accordance with CS 25.1309 for
all ETOPS significant systems should follow the steps below:
a. Conduct a (supplemental) Functional Hazard Assessment (FHA) considering the ETOPS
missions. In determining the effect of a failure condition during an ETOPS mission, the
following should also be reviewed:
(1) Crew workload over a prolonged period of time;
(2) Operating conditions at single engine altitude;
(3) Lesser crew familiarity with the procedures and conditions to fly to and land at
diversion aerodromes.
b. Introduce any additional failure scenario/objectives necessary to comply with this AMC.
c. For compliance demonstration of ETOPS significant system reliability to CS 25.1309 there will
be no distinction made between ETOPS group 1 and group 2 systems. For qualitative analysis
(FHA), the maximum flight time and the maximum ETOPS diversion time should be
considered. For quantitative analysis (SSA), the average ETOPS mission time and maximum
ETOPS diversion time should be considered. Consideration should be given to how the
particular airframe/engine combination is to be utilised, and analyse the potential route
structure and city pairs available, based upon the range of the aeroplane.

AMC 20-6
d. Consider effects of prolonged time and at single engine altitude in terms of continued
operation of remaining systems following failures.
e. Specific ETOPS maintenance tasks, intervals and specific ETOPS flight procedures necessary
to attain the safety objectives, shall be included in the appropriate approved documents (e.g.
CMP document, MMEL).
f. Safety assessments should consider the flight consequences of single or multiple system
failures leading to a diversion and the probability and consequences of subsequent failures
or exhaustion of the capacity of time critical systems, which might occur during the diversion.
Safety assessments should determine whether a diversion should be conducted to the
nearest aerodrome or to an aerodrome presenting better operating conditions, considering:
(1) The effect of the initial failure condition on the capability of the aeroplane to cope with
adverse conditions at the diversion aerodrome, and
(2) The means available to the crew to assess the extent and evolution of the situation
during a prolonged diversion.
The aircraft flight manual and the flight crew warning and alerting and display systems should
provide clear information to enable the flight crew to determine when failure conditions are such
that a diversion is necessary.
3. RELIABILITY VALIDATION METHODS
There are two extremes in the ETOPS process with respect to maturity; one is the demonstration
of stable reliability by the accumulation of in-service experience and the other is by a design,
analysis and test programmes, agreed between the (S)TC holders and the Agency/Authority.
a. In-service Experience/Systems Safety Assessment (SSA)
In-service experience should generally be in accordance with that identified in Appendix 1 for
each airframe/engine combination. When considering the acceptability of airframe systems
for ETOPS, maturity should be assessed in terms of used technology and the particular design
under review.
In performing the SSA’s, defined in paragraph 2 of this Appendix 2, particular account will be
taken of the following:
(1) For identical or similar equipment to those used on other aeroplanes, the SSA failure
rates should be validated by in-service experience:
(i) The amount of in-service experience (either direct or related) should be
indicated for each equipment of an ETOPS significant system.
(ii) Where related experience is used to validate failure modes and rates, an analysis
should be produced to show the validity of the in-service experience.
(iii) In particular, if the same equipment is used on a different airframe/engine
combination, it should be shown that there is no difference in operating
conditions (e.g., vibrations, pressure, temperature) or that these differences do
not adversely affect the failure modes and rates.

AMC 20-6
(iv) If in-service experience with similar equipment on other aeroplanes is claimed

to be applicable, an analysis should be produced substantiating the reliability
figures used on the quantitative analysis. This substantiation analysis should
include details of the differences between the similar and new equipment,
details of the in-service experience of the similar equipment and details of any
"lessons learnt" from modifications introduced and included in the new
equipment.
(v) For certain equipment, (e.g., IDGs, TRUs, bleeds and emergency generators) this
analysis may have to be backed up by tests. This should be agreed with the
Agency.
(2) For new or substantially modified equipment, account should be taken in the SSA for
the lack of validation of the failure rates by service experience.
A study should be conducted to determine the sensitivity of the assumed SSA failure
condition probabilities to the failure rates of the subject equipment.
Should a failure case probability be sensitive to this equipment failure rate and close
to the required safety objective, particular provision precautions should be applied
(e.g. temporary dispatch restrictions, inspections, maintenance procedures, crew
procedures) to account for the uncertainty, until the failure rate has been
appropriately validated by in-service experience.
b. Early ETOPS
Where type design approval for Early ETOPS is sought at the first entry into service of the
airframe/engine combination, the engineering assessment can be based on substantiation
by analysis, test, in-service experience (the same engine or airframe with different engines)
or other means, to show that the ETOPS significant systems will achieve a failure rate that is
compatible with the specified safety objective. An approval plan, defining the early ETOPS
reliability validation tests and processes, should be submitted by the (S)TC’s holders to the
Agency for agreement. This certification plan should be completed and implemented to the
satisfaction of the Agency before an ETOPS type design approval will be granted.
(1) Acceptable Early ETOPS approval plan
In addition to the above considerations, the following should be complied with for an
Early ETOPS approval:
(i) Aeroplane Testing
For each airframe/engine combination that has not yet accumulated at least
15,000 engine hours in service, to be approved for ETOPS, one or more
aeroplanes should conduct flight testing which demonstrates that the
airframe/engine combination, its components and equipment are capable for,
and function properly, during ETOPS flights and ETOPS diversions. These flight
tests may be coordinated with, but they are not in place of flight testing required
in Part 21.35(b)(2).
The flight test programme should include:

AMC 20-6
(A) Flights simulating actual ETOPS operation, including normal cruise

altitude, step climbs and APU operation if required for ETOPS;
(B) Demonstration of the maximum normal flight duration with the maximum
diversion time for which eligibility is sought;
(C) Engine inoperative maximum time diversions to demonstrate the
aeroplane and propulsion system’s capability to safely conduct an ETOPS
diversion, including a repeat of a MCT diversion on the same engine;
(D) Non-normal conditions to demonstrate the aeroplane’s capability to
safely conduct an ETOPS diversion under worst case probable system
failure conditions;
(E) Diversions into representative operational diversionary airports;
(F) Repeated exposure to humid and inclement weather on the ground
followed by long range operations at normal cruise altitude;
(G) The flight testing should validate the adequacy of the aeroplane’s flying
qualities, performance and flight crew’s ability to deal with the conditions
of paragraphs (C)/(D)&(E) above.
(H) The engine-inoperative diversions must be evenly distributed among the
number of engines in the applicant’s flight test programme except as
required by paragraph (C) above.
(I) The test aeroplane(s) must be operated and maintained using the
recommended operations and maintenance manual procedures during
the aeroplane demonstration test.
(J) At the completion of the aeroplane(s) demonstration testing, the ETOPS
significant systems must undergo an operation or functional check per the
Instructions for Continued Airworthiness of CS 25.1529. The engines must
also undergo a gas path inspection. These inspections are intended to
identify any abnormal conditions that could result in an in-flight shutdown
or diversion. Any abnormal conditions must be identified, tracked and
resolved in accordance with subpart (2) below. This inspection
requirement can be relaxed for ETOPS significant systems similar in design
to proven models.
(K) Maintenance and Operational Procedures. The applicant must validate all
ETOPS significant systems maintenance and operational procedures. Any
problems found as a result of the validation must be identified, tracked
and resolved in accordance with paragraph subpart (2) below.
(ii) APU Testing
If an APU is required for ETOPS, one APU of the type to be certificated with the
aeroplane should complete a test consisting of 3000 equivalent aeroplane
operational cycles. Following completion of the demonstration test, the APU
must be disassembled and inspected. Any potential sources of in-flight start

AMC 20-6
and/or run events should be identified, tracked and resolved in accordance with
paragraph subpart (2) below.
(2) Early ETOPS Occurrence Reporting & Tracking
(i) The holder of a (S)TC of an aeroplane which has been approved for ETOPS
without service experience in accordance with this AMC, should establish a
system to address problems and occurrences encountered on the airframe and
propulsion systems that could affect the safety of ETOPS operations and timely
resolution for these events;
(ii) The system should contain a means for the prompt identification of ETOPS
related events, the timely notification of the event to the Agency and proposing
to, and obtaining Agency’s approval for the resolution of this event. The
implementation of the problem resolution can be accomplished by way of an
Agency approved change(s) to the type design, the manufacturing process, or
an operating or maintenance procedure.
(iii) The reporting system should be in place for at least the first 100,000 flight hours.
The reporting requirement remains in place until the airframe and propulsion
systems have demonstrated stable reliability in accordance with the required
safety objectives
(iv) If the airframe/engine combination certified is a derivative of a previously
certificated aeroplane, these criteria may be amended by the Agency, to require
reporting on only those changed systems.
(v) For the early ETOPS service period, an applicant must define the sources and
content of in-service data that will be made available to them in support of their
occurrence reporting and tracking system. The content of this data should be
adequate to evaluate the specific cause of all service incidents reportable under
Part 21.A.3(c), in addition to the occurrences that could affect the safety of
ETOPS operations and should be reported, including:
(A) In-flight shutdown events;
(B) Inability to control the engine or obtain desired power;
(C) Precautionary thrust reductions (except for normal troubleshooting as
allowed in the Aircraft Flight Manual);
(D) Degraded propulsion in-flight start capability;
(E) Inadvertent fuel loss or availability, or uncorrectable fuel imbalance in
flight;
(F) Technical air turn-backs or diversions associated with an ETOPS Group 1
system;
(G) Inability of an ETOPS Group 1 system, designed to provide backup
capability after failure of a primary system, to provide the required
backup capability in-flight;

AMC 20-6
(H) Any loss of electrical power or hydraulic power system, during a given
operation of the aeroplane;
(I) Any event that would jeopardise the safe flight and landing of the
aeroplane during an ETOPS flight.
4. CONTINUING SURVEILLANCE
In order to confirm that the predicted system reliability level is achieved and maintained, the (S)TC
holder should monitor the reliability of airframe ETOPS significant systems after entry into service.
The (S)TC’s holder should submit a report to the Agency, initially on a quarterly basis (for the first
year of operation) and thereafter on a periodic basis and for a time to be agreed with the Agency.
The monitoring task should include all events on ETOPS significant systems, from both the ETOPS
and non-ETOPS fleet of the subject family of airframes. This additional reliability monitoring is
required only for ETOPS Group 1 systems.
5. CONTINUED AIRWORTHINESS
a. Reliability Tracking Board
The Agency will periodically review its original findings by means of a Reliability Tracking
Board. In addition, the Agency document containing the CMP standard will be revised as
necessary.
Note: The Reliability Tracking Board will usually comprise specialists from aeroplane and
engine disciplines. (See also Appendix 1).
Periodic meetings of the ETOPS Reliability Tracking Board are normally frequent at the start
of the assessment of a new product. The periodicity is adjusted by the Agency upon
accumulation of substantial in-service experience if there is evidence that the reliability of
the product is sufficiently stable. The periodic meetings of the board are discontinued once
an ETOPS product, or family of products, has been declared mature by the Agency.
b. Mature ETOPS products
A family of ETOPS products with a high degree of similarity is considered as mature when:
(1) The product family has accumulated at least 250,000 flight hours for an aeroplane
family;
(2) The product family has accumulated service experience covering a comprehensive
spectrum of operating conditions (e.g. cold, hot, high, humid);
(3) Each ETOPS approved model or variant in the family has achieved the reliability
objectives for ETOPS and has remained stable at or below the objectives fleet-wide for
at least two years;
New models or significant design changes may not be considered mature until they have
individually satisfied the conditions specified above.
The Agency makes the determination of when a product or a product family is considered
mature.
c. Surveillance of mature ETOPS products

AMC 20-6
The (S)TC holder of an ETOPS product which the Agency has found mature, should institute
a process to monitor the reliability of the product in accordance with the objectives defined
in this Appendix. In case of occurrence of an event, a series of events or a statistical trend
that implies a deviation of the reliability of the ETOPS fleet, or a portion of the ETOPS fleet
(e.g. one model or a range of serial numbers), above the limits specified for ETOPS, the (S)TC
should:
(1) Inform the Agency and define a means to restore the reliability through a Minor
Revision of the CMP document, with a compliance schedule to be agreed with the
Agency if the situation has no immediate safety impact;
(2) Inform the Agency and propose an ad-hoc follow-up by the Agency until the concern
has been alleviated, or confirmed if the situation requires further assessment;
(3) Inform the Agency and propose the necessary corrective action(s) to be mandated by
the Agency through an AD if a direct safety concern exists.
In the absence of a specific event or trend requiring action, the (S)TC holder should provide
the Agency with the basic statistical indicators prescribed in this Appendix 2 on a yearly basis.
d. Minor Revision of the ETOPS CMP Document
A Minor Revision of the ETOPS CMP document is one that contains only editorial
adjustments, configurations, maintenance and procedures equivalent to those already
approved by the Agency, or new reliability improvements which have no immediate impact
on the safety of ETOPS flights and which are introduced as a means to control the continued
compliance with the reliability objectives of ETOPS.
Minor revisions of the ETOPS CMP document should be approved by authorised signatories
of the Design Organisation and under the provisions of its approved Design Organisation
Handbook.
6. DESIGN ORGANISATION APPROVAL
(S)TC holders of products approved for ETOPS should hold a Design Organisation Approval (DOA)
conforming to EASA Part-21, with the appropriate terms of approval and privileges. Their approved
Design Organisation Handbook (DOH) must contain an appropriate description of the organisation
and procedures covering all applicable tasks and responsibilities of EASA Part-21 and this AMC.
[Amdt 20/7]

AMC 20-6
Appendix 3 to AMC 20-6 – Operational Limitations

1. AREA OF OPERATION
An operator is, when specifically approved, authorised to conduct ETOPS flights within an area
where the diversion time, at any point along the proposed route of flight, to an adequate ETOPS
en-route alternate aerodrome, is within the operator’s approved diversion time (under standard
conditions in still air) at the approved one-engine-inoperative cruise speed.
2. OPERATOR’S APPROVED DIVERSION TIME
The procedures established by the operator should ensure that ETOPS is only planned on routes
where the Operator’s Approved Diversion Time to an Adequate ETOPS en-route alternate
Aerodrome can be met.
3. ISSUE OF THE ETOPS OPERATIONS APPROVAL BY THE COMPETENT AUTHORITY
The approval issued by the Competent Authority for ETOPS operations should be based on the
following information provided by the operator:
a. Specification of the particular airframe/engine combinations, including the current approved
CMP document required for ETOPS as normally identified in the AFM;
b. Authorised area of operation;
c. Minimum altitudes to be flown along planned and diversionary routes;
d. Operator’s Approved Diversion Time;
e. Aerodromes identified to be used, including alternates, and associated instrument
approaches and operating minima;
f. The approved maintenance and reliability programme for ETOPS;
g. Identification of those aeroplanes designated for ETOPS by make and model as well as serial
number and registration;
h. Specification of routes and the ETOPS diversion time necessary to support those routes;
i. The one-engine-inoperative cruise speed, which may be area specific, depending upon
anticipated aeroplane loading and likely fuel penalties associated with the planned
procedures;
j. Processes and related resources allocated to initiate and sustain ETOPS operations in a
manner that demonstrates commitment by management and all personnel involved in ETOPS
continued airworthiness and operational support;
k. The plan for establishing compliance with the build standard required for Type Design
Approval, e.g. CMP document compliance.
[Amdt 20/7]

AMC 20-6
Appendix 4 to AMC 20-6 – Flight Preparation and In-flight Procedures

1. GENERAL
The flight release considerations specified in this paragraph are in addition to the applicable
operational requirements. They specifically apply to ETOPS. Although many of the considerations
in this AMC are currently incorporated into approved programmes for other aeroplanes or route
structures, the unique nature of ETOPS necessitates a re-examination of these operations to ensure
that the approved programmes are adequate for this purpose.
2. MINIMUM EQUIPMENT LIST (MEL)
The system redundancy levels appropriate to ETOPS should be reflected in the Master Minimum
Equipment List (MMEL). An operator’s MEL may be more restrictive than the MMEL considering the
kind of ETOPS operation proposed, equipment and in-service problems unique to the operator.
Systems and equipment considered to have a fundamental influence on safety may include, but are
not limited to, the following:
a. electrical;
b. hydraulic;
c. pneumatic;
d. flight instrumentation, including warning and caution systems;
e. fuel;
f. flight control;
g. ice protection;
h. engine start and ignition;
i. propulsion system instruments;
j. navigation and communications, including any route specific long range navigation and
communication equipment;
k. auxiliary power-unit;
l. air conditioning and pressurisation;
m. cargo fire suppression;
n. engine fire protection;
o. emergency equipment;
p. systems and equipment required for engine condition monitoring.
In addition, the following systems are required to be operative for dispatch for ETOPS with
diversion times above 180 minutes:
q. Fuel Quantity Indicating System (FQIS);
r. APU (including electrical and pneumatic supply to its designed capability), if necessary to
comply with ETOPS requirements;

AMC 20-6
s. Automatic engine or propeller control system;

t. Communication system(s) relied on by the flight crew to comply with the requirement for
communication capability.
3. COMMUNICATION AND NAVIGATION FACILITIES
For releasing an aeroplane on an ETOPS flight, the operators should ensure that:
a. Communications facilities are available to provide under normal conditions of propagation
at all planned altitudes of the intended flight and the diversion scenarios, reliable two-way
voice and/or data link communications;
b. Visual and non-visual aids are available at the specified alternates for the anticipated types
of approaches and operating minima.
4. FUEL SUPPLY
a. General
For releasing an aeroplane on an ETOPS flight, the operators should ensure that it carries
sufficient fuel and oil to meet the applicable operational requirements and any additional
fuel that may be determined in accordance with this Appendix.
b. Critical Fuel Reserve
In establishing the critical fuel reserves, the applicant is to determine the fuel necessary to
fly to the most critical point (at normal cruise speed and altitude, taking into account the
anticipated meteorological conditions for the flight) and execute a diversion to an ETOPS en-
route alternate under the conditions outlined in this Appendix, the ‘Critical Fuel Scenario’
(paragraph c. below).
These critical fuel reserves should be compared to the normal applicable operational
requirements for the flight. If it is determined by this comparison that the fuel to complete
the critical fuel scenario exceeds the fuel that would be on board at the most critical point,
as determined by applicable operational requirements, additional fuel should be included to
the extent necessary to safely complete the Critical Fuel Scenario. When considering the
potential diversion distance flown account should be taken of the anticipated routing and
approach procedures, in particular any constraints caused by airspace restrictions or terrain.
c. Critical Fuel Scenario.
The following describes a scenario for a diversion at the most critical point. The applicant
should confirm compliance with this scenario when calculating the critical fuel reserve
necessary.
Note 1: If an APU is one of the required power sources, then its fuel consumption should be
accounted for during the appropriate phases of flight.
Note 2: Additional fuel consumptions due to any MEL or CDL items should be accounted for
during the appropriate phases of flight, when applicable.
The aeroplane is required to carry sufficient fuel taking into account the forecast wind and
weather to fly to an ETOPS route alternate assuming the greater of:

AMC 20-6
(1) A rapid decompression at the most critical point followed by descent to a 10,000 ft or
a higher altitude if sufficient oxygen is provided in accordance with the applicable
(2) Flight at the approved one-engine-inoperative cruise speed assuming a rapid
decompression and a simultaneous engine failure at the most critical point followed
by descent to a 10,000 ft or a higher altitude if sufficient oxygen is provided in
accordance with the applicable operational requirements.
(3) Flight at the approved one-engine-inoperative cruise speed assuming an engine failure
at the most critical point followed by descent to the one-engine-inoperative cruise
altitude.
Upon reaching the alternate, hold at 1500 ft above field elevation for 15 minutes and
then conduct an instrument approach and landing.
Add a 5% wind speed factor (i.e., an increment to headwind or a decrement to
tailwind) on the actual forecast wind used to calculate fuel in the greater of (1), (2) or
(3) above to account for any potential errors in wind forecasting. If an operator is not
using the actual forecast wind based on wind model acceptable to the competent
authority, allow 5% of the fuel required for (1), (2) or (3) above, as reserve fuel to allow
for errors in wind data. A wind aloft forecasting distributed worldwide by the World
Area Forecast System (WAFS) is an example of a wind model acceptable to the
competent authority.
d. Icing
Correct the amount of fuel obtained in paragraph c. above taking into account the greater
of:
(1) the effect of airframe icing during 10% of the time during which icing is forecast
(including ice accumulation on unprotected surfaces, and the fuel used by engine and
wing anti-ice during this period).
(2) fuel for engine anti-ice, and if appropriate wing anti-ice for the entire time during
which icing is forecast.
Note: Unless a reliable icing forecast is available, icing may be presumed to occur when
the total air temperature (TAT) at the approved one-engine-inoperative cruise speed
is less than +10°C, or if the outside air temperature is between 0°C and -20°C with a
relative humidity (RH) of 55% or greater.
The operator should have a programme established to monitor aeroplane in-service
deterioration in cruise fuel burn performance and including in the fuel supply
calculations sufficient fuel to compensate for any such deterioration. If there is no data
available for such a programme the fuel supply should be increased by 5% to account
for deterioration in cruise fuel burn performance.
5. ALTERNATE AERODROMES
To conduct an ETOPS flight, the ETOPS en-route alternate aerodromes, should meet the weather
requirements of planning minima for an ETOPS en-route alternate aerodromes contained in the
applicable operational requirements. ETOPS planning minima apply until dispatch. The planned en-

AMC 20-6
route alternates for using in the event of propulsion system failure or aeroplane system failure(s)
which require a diversion should be identified and listed in the cockpit documentation (e.g.
computerised flight plan) for all cases where the planned route to be flown contains an ETOPS point
See also Appendix 5 to this AMC ‘ETOPS En-route Alternate Aerodromes’.
6. IN-FLIGHT RE-PLANNING AND POST-DISPATCH WEATHER MINIMA
An aeroplane whether or not dispatched as an ETOPS flight may not re-route post dispatch without
meeting the applicable operational requirements and satisfy by a procedure that dispatch criteria
have been met. The operator should have a system in place to facilitate such re-routes.
Post-dispatch, weather conditions at the ETOPS en-route alternates should be equal to or better
than the normal landing minima for the available instrument approach.
7. DELAYED DISPATCH
If the dispatch of a flight is delayed by more than one hour, pilots and/or operations personnel
should monitor weather forecasts and airport status atthe nominated en-route alternates to ensure
that they stay within the specified planning minima requirements until dispatch.
8. DIVERSION DECISION MAKING
Operators shall establish procedures for flight crew, outlining the criteria that indicate when a
diversion or change of routing is recommended whilst conducting an ETOPS flight. For an ETOPS
flight, in the event of the shutdown of an engine, these procedures should include the shutdown of
an engine, fly to and land at the nearest aerodrome appropriate for landing.
Factors to be considered when deciding upon the appropriate course of action and suitability of an
aerodrome for diversion may include but are not limited to:
a. Aircraft configuration/weight/systems status;
b. Wind and weather conditions en route at the diversion altitude;
c. Minimum altitudes en route to the diversion aerodrome;
d. Fuel required for the diversion;
e. Aerodrome condition, terrain, weather and wind;
f. Runways available and runway surface condition;
g. Approach aids and lighting;
h. RFFS* capability at the diversion aerodrome;
i. Facilities for aircraft occupants - disembarkation & shelter;
j. Medical facilities;
k. Pilot’s familiarity with the aerodrome;
l. Information about the aerodrome available to the flight crew.
Contingency procedures should not be interpreted in any way that prejudices the final authority
and responsibility of the pilot-in-command for the safe operation of the aeroplane.

AMC 20-6
Note: for an ETOPS en-route alternate aerodrome, a published RFFS category equivalent to ICAO
category 4, available at 30 minutes notice, is acceptable.
9. IN-FLIGHT MONITORING
During the flight, the flight crew should remain informed of any significant changes in conditions at
designated ETOPS en-route alternate aerodromes. Prior to the ETOPS Entry Point, the forecast
weather, established aeroplane status, fuel remaining, and where possible field conditions and
aerodrome services and facilities at designated ETOPS en-route alternates are to be evaluated. If
any conditions are identified which could preclude safe approach and landing on a designated en-
route alternate aerodrome, then the flight crew should take appropriate action, such as re-routing
as necessary, to remain within the operator’s approved diversion time of an en-route alternate
aerodrome with forecast weather to be at or above landing minima. In the event this is not possible,
the next nearest en-route alternate aerodrome should be selected provided the diversion time does
not exceed the maximum approved diversion time. This does not override the pilot in command’s
authority to select the safest course of action.
10. AEROPLANE PERFORMANCE DATA
The operator should ensure that the Operations Manual contains sufficient data to support the
critical fuel reserve and area of operations calculation.
The following data should be based on the information provided by the (S)TC holder. The
requirements for one-engine-inoperative performance en-route can be found in the applicable
Detailed one-engine-inoperative performance data including fuel flow for standard and non-
standard atmospheric conditions and as a function of airspeed and power setting, where
appropriate, covering:
a. drift down (includes net performance);
b. cruise altitude coverage including 10,000 feet;
c. holding;
d. altitude capability (includes net performance);
e. missed approach.
Detailed all-engine-operating performance data, including nominal fuel flow data, for standard and
non-standard atmospheric conditions and as a function of airspeed and power setting, where
appropriate, covering:
a. Cruise (altitude coverage including 10,000 feet); and
b. Holding.
It should also contain details of any other conditions relevant to extended range operations which
can cause significant deterioration of performance, such as ice accumulation on the unprotected
surfaces of the aeroplane, Ram Air Turbine (RAT) deployment, thrust reverser deployment, etc.
The altitudes, airspeeds, thrust settings, and fuel flow used in establishing the ETOPS area of
operations for each airframe/engine combination should be used in showing the corresponding
terrain and obstruction clearances in accordance with the applicable operational requirements.

AMC 20-6
11. OPERATIONAL FLIGHT PLAN

The type of operation (i.e. ETOPS, including the diversion time used to establish the plan) should be
listed on the operational flight plan as required by the applicable operational requirements.
[Amdt 20/7]

AMC 20-6
Appendix 5 to AMC 20-6 – ETOPS En-Route Alternate Aerodromes

1. SELECTION OF EN-ROUTE ALTERNATE AERODROMES

For an aerodrome to be nominated as an ETOPS en-route alternate for the purpose of this AMC, it
should be anticipated that at the expected times of possible use it is an adequate ETOPS aerodrome
that meets the weather and field conditions defined in the paragraph below titled ‘Dispatch Minima
– En-Route Alternate Aerodromes’ or the applicable operational requirements.
To list an aerodrome as an ETOPS en-route alternate, the following criteria should be met:
a. The landing distances required as specified in the AFM for the altitude of the aerodrome, for
the runway expected to be used, taking into account wind conditions, runway surface
conditions, and aeroplane handling characteristics, permit the aeroplane to be stopped
within the landing distance available as declared by the aerodrome authorities and computed
in accordance with the applicable operational requirements.
b. The aerodrome services and facilities are adequate to permit an instrument approach
procedure to the runway expected to be used while complying with the applicable
aerodrome operating minima.
c. The latest available forecast weather conditions for a period commencing at the earliest
potential time of landing and ending one hour after the latest nominated time of use of that
aerodrome, equals or exceeds the authorised weather minima for en-route alternate
aerodromes as provided for by the increments listed in Table 1 of this Appendix. In addition,
for the same period, the forecast crosswind component plus any gusts should be within
operating limits and within the operators maximum crosswind limitations taking into account
the runway condition (dry, wet or contaminated) plus any reduced visibility limits.
d. In addition, the operator’s programme should provide flight crews with information on
adequate aerodromes appropriate to the route to be flown which are not forecast to meet
en-route alternate weather minima. Aerodrome facility information and other appropriate
planning data concerning these aerodromes should be provided to flight crews for use when
executing a diversion.
2. DISPATCH MINIMA – EN-ROUTE ALTERNATE AERODROMES
An aerodrome may be nominated as an ETOPS en-route alternate for flight planning and release
purposes if the available forecast weather conditions for a period commencing at the earliest
potential time of landing and ending one hour after the latest nominated time of use of that
aerodrome, equal or exceed the criteria required by Table 1 below.
Table 1. Planning Minima
Approach Facility Ceiling Visibility

Precision Approach Authorised DH/DA plus an Authorised visibility plus an
increment of 200 ft increment of 800 metres
Non-Precision Approach or Authorised MDH/MDA plus an Authorised visibility plus an
Circling approach increment of 400 ft increment of 1500 metres
The above criteria for precision approaches are only to be applied to Category 1 approaches.

AMC 20-6
When determining the usability of an Instrument Approach (IAP), forecast wind plus any gusts
should be within operating limits, and within the operators maximum crosswind limitations taking
into account the runway condition (dry, wet or contaminated) plus any reduced visibility limits.
Conditional forecast elements need not be considered, except that a PROB 40 or TEMPO condition
below the lowest applicable operating minima should be taken into account.
When dispatching under the provisions of the MEL, those MEL limitations affecting instrument
approach minima should be considered in determining ETOPS alternate minima.
3. EN-ROUTE ALTERNATE AERODROME PLANNING MINIMA – ADVANCED LANDING SYSTEMS
The increments required by Table 1 are normally not applicable to Category II or III minima unless
specifically approved by the Authority.
Approval will be based on the following criteria:
a. Aircraft is capable of engine-inoperative Cat II/III landing; and
b. Operator is approved for normal Cat II/III operations.
The competent authority may require additional data (such as safety assessment or in-service
records) to support such an application. For example, it should be shown that the specific aeroplane
type can maintain the capability to safely conduct and complete the Category II/III approach and
landing, in accordance with EASA CS-AWO, having encountered failure conditions in the airframe
and/or propulsion systems associated with an inoperative engine that would result in the need for
a diversion to the route alternate aerodrome.
Systems to support one-engine inoperative Category II or III capability should be serviceable if
required to take advantage of Category II or III landing minima at the planning stage.
[Amdt 20/7]

AMC 20-6
Appendix 6 to AMC 20-6 – ETOPS Training Programme

The operator’s ETOPS training programme should provide initial and recurrent training for flight crew as
follows:
1. INTRODUCTION TO ETOPS REGULATIONS
a. Brief overview of the history of ETOPS;
b. ETOPS regulations;
c. Definitions;
d. Approved One-Engine-Inoperative Cruise Speed;
e. ETOPS Type Design Approval – a brief synopsis;
f. Maximum approved diversion times and time-limited systems capability;
g. Operator’s Approved Diversion Time;
h. Routes and aerodromes intended to be used in the ETOPS area of operations;
i. ETOPS Operations Approval;
j. ETOPS Area and Routes;
k. ETOPS en-route alternates aerodromes including all available let-down aids;
l. Navigation systems accuracy, limitations and operating procedures;
m. Meteorological facilities and availability of information;
n. In-flight monitoring procedures;
o. Computerised Flight Plan;
p. Orientation charts, including low level planning charts and flight progress charts usage
(including position plotting);
q. Equal Time Point;
r. Critical fuel.
2. NORMAL OPERATIONS
a. Flight planning and Dispatch
(1) ETOPS Fuel requirements
(2) Route Alternate selection - weather minima
(3) Minimum Equipment List – ETOPS specific
(4) ETOPS service check and Tech log
(5) Pre-flight FMS Set up
b. Flight performance progress monitoring
(1) Flight management, navigation and communication systems

AMC 20-6
(2) Aeroplane system monitoring

(3) Weather monitoring
(4) In-flight fuel management – to include independent cross checking of fuel quantity
3. ABNORMAL AND CONTINGENCY PROCEDURES:
a. Diversion Procedures and Diversion ‘decision making’.
Initial and recurrent training to prepare flight crews to evaluate potential significant system
failures. The goal of this training should be to establish crew competency in dealing with the
most probable contingencies. The discussion should include the factors that may require
medical, passenger related or non-technical diversions.
b. Navigation and communication systems, including appropriate flight management devices in
degraded modes.
c. Fuel Management with degraded systems.
d. Initial and recurrent training which emphasises abnormal and emergency procedures to be
followed in the event of foreseeable failures for each area of operation, including:
(1) Procedures for single and multiple failures in flight affecting ETOPS sector entry and
diversion decisions. If standby sources of electrical power significantly degrade the
cockpit instrumentation to the pilots, then training for approaches with the standby
generator as the sole power source should be conducted during initial and recurrent
training.
(2) Operational restrictions associated with these system failures including any applicable
MEL considerations.
4. ETOPS LINE FLYING UNDER SUPERVISION (LFUS)
During the introduction into service of a new ETOPS type, or conversion of pilots not previously
ETOPS qualified where ETOPS approval is sought, a minimum of two ETOPS sectors should be
completed including an ETOPS line check.
ETOPS subjects should also be included in annual refresher training as part of the normal process.
5. FLIGHT OPERATIONS PERSONNEL OTHER THAN FLIGHT CREW
The operator’s training programme in respect to ETOPS should provide training where applicable
for operations personnel other than flight crew (e.g. dispatchers), in addition to refresher training
in the following areas:
a. ETOPS Regulations/Operations Approval
b. Aeroplane performance/Diversion procedures
c. Area of Operation
d. Fuel Requirements
e. Dispatch Considerations MEL, CDL, weather minima, and alternate airports
f. Documentation
[Amdt 20/7]

AMC 20-6
Appendix 7 to AMC 20-6 – Typical ETOPS Operations Manual

Supplement
The ETOPS operations manual can take the form of a supplement or a dedicated manual, and it could be
divided under these headings as follows:
PART A. GENERAL/BASIC
a. Introduction
(1) Brief description of ETOPS
(2) Definitions
b. Operations approval
(1) Criteria
(2) Assessment
(3) Approved diversion time
c. Training and Checking
d. Operating procedures
e. ETOPS operational procedures
f. ETOPS Flight Preparation and Planning
(1) Aeroplane serviceability
(2) ETOPS Orientation charts
(3) ETOPS alternate aerodrome selection
(4) En-route alternate weather requirements for planning
(5) ETOPS computerised Flight Plans
g. Flight Crew Procedures
(1) Dispatch
(2) Re-routing or diversion decision-making
(3) ETOPS verification (following maintenance) flight requirements
(4) En-route Monitoring
PART B. AEROPLANE OPERATING MATTERS
This part should include type-related instructions and procedures needed for ETOPS.
a. Specific type-related ETOPS operations
(1) ETOPS specific limitations
(2) Types of ETOPS operations that are approved
(3) Placards and limitations

AMC 20-6
(4) OEI speed(s)

(5) Identification of ETOPS aeroplanes
b. Dispatch and flight planning, plus in-flight planning
(1) Type-specific flight planning instructions for use during dispatch and post dispatch
(2) Procedures for engine(s)-out operations, ETOPS (particularly the one-engine-inoperative
cruise speed and maximum distance to an adequate aerodrome should be included)
c. ETOPS Fuel Planning
d. Critical Fuel Scenario
e. MEL/CDL considerations
f. ETOPS specific Minimum Equipment List items
g. Aeroplane Systems
(1) Aeroplane performance data including speed schedules and power settings
(2) Aeroplane technical differences, special equipment (e.g. satellite communications) and
modifications required for ETOPS
PART C. ROUTE AND AERODROME INSTRUCTIONS
This part should comprise all instructions and information needed for the area of operation, to include
the following as necessary:
a. ETOPS area and routes, approved area(s) of operations and associated limiting distances
b. ETOPS an-route alternates
c. Meteorological facilities and availability of information for in-flight monitoring
d. Specific ETOPS computerised Flight Plan information
e. Low altitude cruise information, minimum diversion altitude, minimum oxygen requirements and
any additional oxygen required on specified routes if MSA restrictions apply
f. Aerodrome characteristics (landing distance available, take off distance available) and weather
minima for aerodromes that are designated as possible alternates
PART D. TRAINING
This part should contain the route and aerodrome training for ETOPS operations. This training should have
twelve-months of validity or as required by the applicable operational requirements. Flight crew training
records for ETOPS should be retained for 3 years or as required by the applicable requirements.
The operator's training programme in respect to ETOPS should include initial and recurrent
training/checking as specified in this AMC.
[Amdt 20/7]

AMC 20-6
Appendix 8 to AMC 20-6 – Continuing Airworthiness Considerations

1. APPLICABILITY
The requirements of this Appendix apply to the continuing airworthiness management
organisations (CAMO) managing the aircraft for which an ETOPS operational approval is sought, and
they are to be complied with in addition to the applicable continuing airworthiness requirements
of Part-M. They specifically affect:
a. Occurrence reporting;
b. Aircraft maintenance programme and reliability programme;
c. Continuing airworthiness management exposition;
d. Competence of continuing airworthiness and maintenance personnel.
2. OCURRENCE REPORTING
In addition to the items generally required to be reported in accordance with AMC 20-8, the
following items concerning ETOPS should be included:
a. in-flight shutdowns;
b. diversion or turn-back;
c. un-commanded power changes or surges;
d. inability to control the engine or obtain desired power; and
e. failures or malfunctions of ETOPS significant systems having a detrimental effect to ETOPS
flight.
Note: status messages, transient failures, intermittent indication of failure, messages tested
satisfactorily on ground not duplicating the failure should only be reported after an assessment by
the operator that an unacceptable trend has occurred on the system
The report should identify as applicable the following:
a. aircraft identification;
b. engine, propeller or APU identification (make and serial number);
c. total time, cycles and time since last shop visit;
d. for systems, time since overhaul or last inspection of the defective unit;
e. phase of flight; and
f. corrective action.
The Competent Authority and the (S)TC holder should be notified within 72 hours of events
reportable through this programme.
3. MAINTENANCE PROGRAMME AND RELIABILITY PROGRAMME
The quality of maintenance and reliability programmes can have an appreciable effect on the
reliability of the propulsion system and the ETOPS Significant Systems. The Competent Authority
should assess the proposed maintenance and reliability programme’s ability to maintain an

AMC 20-6
acceptable level of safety for the propulsion system and the ETOPS Significant Systems of the
particular airframe/engine combination.
3.1 MAINTENANCE PROGRAMME:
The maintenance programme of an aircraft for which ETOPS operational approval is sought,
should contain the standards, guidance and instructions necessary to support the intended
operation. The specific ETOPS maintenance tasks identified by the (S)TC holder in the
Configuration, Maintenance and Procedures document (CMP) or equivalent should be
included in the maintenance programme and identified as ETOPS tasks.
An ETOPS Maintenance task could be an ETOPS specific task or/and a maintenance task
affecting an ETOPS significant system. An ETOPS specific task could be either an existing task
with a different interval for ETOPS, a task unique to ETOPS operations, or a task mandated
by the CMP further to the in-service experience review (note that in the case ETOPS is
considered as baseline in the development of a maintenance program, no “ETOPS specific”
task may be identified in the MRB).
The maintenance programme should include tasks to maintain the integrity of cargo
compartment and pressurisation features, including baggage hold liners, door seals and drain
valve condition. Processes should be implemented to monitor the effectiveness of the
maintenance programme in this regard.
3.1.1 PRE-DEPARTURE SERVICE CHECK
An ETOPS service check should be developed to verify the status of the aeroplane and
the ETOPS significant systems. This check should be accomplished by an authorised
and trained person prior to an ETOPS flight. Such a person may be a member of the
flight crew.
3.2 RELIABILITY PROGRAMME:
3.2.1 GENERAL
The reliability programme of an ETOPS operated aircraft should be designed with early
identification and prevention of failures or malfunctions of ETOPS significant systems
as the primary goal. Therefore the reliability programme should include assessment of
ETOPS Significant Systems performance during scheduled inspection/testing, to detect
system failure trends in order to implement appropriate corrective action such as
scheduled task adjustment.
The reliability programme should be event-orientated and incorporate:
a. reporting procedures in accordance with section 2: Occurrence reporting
b. operator’s assessment of propulsion systems reliability
c. APU in-flight start programme
d. Oil consumption programme
e. Engine Condition Monitoring programme
f. Verification programme
3.2.2 ASSESSMENT OF PROPULSION SYSTEMS RELIABILITY

AMC 20-6
a. The operator’s assessment of propulsion systems reliability for the ETOPS fleet
should be made available to the competent Authority (with the supporting data)
on at least a monthly basis, to ensure that the approved maintenance
programme continues to maintain a level of reliability necessary for ETOPS
operations as established in chapter II section 6.3.
b. The assessment should include, as a minimum, engine hours flown in the period,
in-flight shutdown rate for all causes and engine removal rate, both on a 12-
months moving average basis. Where the combined ETOPS fleet is part of a
larger fleet of the same aircraft/engine combination, data from the total fleet
will be acceptable.
c. Any adverse sustained trend to propulsion systems would require an immediate
evaluation to be accomplished by the operator in consultation with the
competent authority. The evaluation may result in corrective action or
operational restrictions being applied.
d. A high engine in-flight shutdown rate for a small fleet may be due to the limited
number of engine operating hours and may not be indicative for an
unacceptable trend. The underlying causes for such an increase in the rate will
have to be reviewed on a case-by-case basis in order to identify the root cause
of events so that the appropriate corrective action is implemented.
e. If an operator has an unacceptable engine in-flight shutdown rate caused by
maintenance or operational practices, then the appropriated corrective actions
should be taken.
3.2.3 APU IN-FLIGHT START PROGRAMME
a. Where an APU is required for ETOPS and the aircraft is not operated with this
APU running prior to the ETOPS entry point, the operator should initially
implement a cold soak in-flight starting programme to verify that start reliability
at cruise altitude is above 95%.
Once the APU in-flight start reliability is proven, the APU in-flight start
monitoring programme may be alleviated. The APU in-flight start monitoring
programme should be acceptable to the competent authority.
b. The Maintenance procedures should include the verification of in-flight start
reliability following maintenance of the APU and APU components, as defined
by the OEM, where start reliability at altitude may have been affected.
3.2.4 OIL CONSUMPTION MONITORING PROGRAMME
The oil consumption monitoring programme should reflect the (S)TC holder’s
recommendations and track oil consumption trends. The monitoring programme must
be continuous and include all oil added at the departure station.
If oil analysis is recommended to the type of engine installed, it should be included in
the programme.
If the APU is required for ETOPS dispatch, an APU oil consumption monitoring
programme should be added to the oil consumption monitoring programme.

AMC 20-6
3.2.5 ENGINE CONDITION MONITORING PROGRAMME

The engine condition monitoring programme should ensure that a one-engine-
inoperative diversion may be conducted without exceeding approved engine limits
(e.g. rotor speeds, exhaust gas temperature) at all approved power levels and expected
environmental conditions. Engine limits established in the monitoring programme
should account for the effects of additional engine loading demands (e.g. anti-icing,
electrical, etc.), which may be required during the one-engine-inoperative flight phase
associated with the diversion.
The engine condition monitoring programme should describe the parameters to be
monitored, method of data collection and corrective action process. The programme
should reflect manufacturer’s instructions and industry practice. This monitoring will
be used to detect deterioration at an early stage to allow for corrective action before
safe operation of the aircraft is affected.
3.2.6 VERIFICATION PROGRAMME
The operator should develop a verification programme to ensure that the corrective
action required to be accomplished following an engine shutdown, any ETOPS
significant system failure or adverse trends or any event which require a verification
flight or other verification action are established. A clear description of who must
initiate verification actions and the section or group responsible for the determination
of what action is necessary should be identified in this verification programme. ETOPS
significant systems or conditions requiring verification actions should be described in
the Continuing Airworthiness Management Exposition (CAME). The CAMO may
request the support of (S)TC holder to identify when these actions are necessary.
Nevertheless the CAMO may propose alternative operational procedures to ensure
system integrity. This may be based on system monitoring in the period of flight prior
to entering an ETOPS area.
4. CONTINUING AIRWORTHINESS MANAGEMENT EXPOSITION
The CAMO should develop appropriate procedures to be used by all personnel involved in the
continuing airworthiness and maintenance of the aircraft, including supportive training
programmes, duties, and responsibilities.
The CAMO should specify the procedures necessary to ensure the continuing airworthiness of the
aircraft particularly related to ETOPS operations. It should address the following subjects as
applicable:
a. General description of ETOPS procedures
b. ETOPS maintenance programme development and amendment
c. ETOPS reliability programme procedures
(1) Engine/APU oil consumption monitoring
(2) Engine/APU Oil analysis
(3) Engine conditioning monitoring
(4) APU in-flight start programme

AMC 20-6
(5) Verification programme after maintenance

(6) Failures, malfunctions and defect reporting
(7) Propulsion System Monitoring/Reporting
(8) ETOPS significant systems reliability
d. Parts and configuration control programme
e. Maintenance procedures that include procedures to preclude identical errors being applied
to multiple similar elements in any ETOPS significant system
f. Interface procedures with the ETOPS maintenance contractor, including the operator ETOPS
procedures that involve the maintenance organisation and the specific requirements of the
contract
g. Procedures to establish and control the competence of the personnel involved in the
continuing airworthiness and maintenance of the ETOPS fleet.
5. COMPETENCE OF CONTINUING AIRWORTHINESS AND MAINTENANCE PERSONNEL
The CAMO organisation should ensure that the personnel involved in the continuing airworthiness
management of the aircraft have knowledge of the ETOPS procedures of the operator.
The CAMO should ensure that maintenance personnel that are involved in ETOPS maintenance
tasks:
a. Have completed an ETOPS training programme reflecting the relevant ETOPS procedures of
the operator, and,
b. Have satisfactorily performed ETOPS tasks under supervision, within the framework of the
Part-145 approved procedures for Personnel Authorisation.
5.1. PROPOSED TRAINING PROGRAMME FOR PERSONNEL INVOLVED IN THE CONTINUING
AIRWORTHINESS AND MAINTENANCE OF THE ETOPS FLEET
The operator’s ETOPS training programme should provide initial and recurrent training for as
follows:
1. INTRODUCTION TO ETOPS REGULATIONS
a. Contents of AMC 20-6
b. ETOPS Type Design Approval – a brief synopsis
2. ETOPS OPERATIONS APPROVAL
a. Maximum approved diversion times and time-limited systems capability
b. Operator’s Approved Diversion Time
c. ETOPS Area and Routes
d. ETOPS MEL
3. ETOPS CONTINUING AIRWORTHINESS CONSIDERATIONS
a. ETOPS significant systems

AMC 20-6
b. CMP and ETOPS aircraft maintenance programme

c. ETOPS pre-departure service check
d. ETOPS reliability programme procedures
(1) Engine/ APU oil consumption monitoring
(2) Engine/APU Oil analysis
(3) Engine conditioning monitoring
(4) APU in-flight start programme
(5) Verification programme after maintenance
(6) Failures, malfunctions and defect reporting
(7) Propulsion System Monitoring/Reporting
(8) ETOPS significant systems reliability
e. Parts and configuration control programme
f. CAMO additional procedures for ETOPS
g. Interface procedures between Part-145 organisation and CAMO
[Amdt 20/7]

AMC 20-8A
AMC 20-8A
AMC 20-8A Occurrence reporting

1. INTENT
This AMC is interpretative material and provides guidance in order to determine when occurrences
should be reported to EASA, competent authorities and other organisations.
It also describes the objective of the overall occurrence-reporting system, including internal and
external functions.
2. APPLICABILITY
(a) This AMC only applies to occurrence reporting by persons or organisations that are subject
to Regulation (EU) No 748/2012 and Regulation (EU) No 1321/2014.
(b) In most cases, the obligation to report is on the holders of a certificate or approval, which in
most cases are organisations, but in some cases can be a natural person. In addition some
reporting requirements are directed to persons. However, in order not to complicate the
text, only the term ‘organisation’ is used.
(c) The AMC does not specifically address dangerous goods reporting. This subject is covered in
specific operational requirements and guidance, and in European Union regulations and ICAO
documents, namely:
(i) Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical
requirements and administrative procedures related to air operations pursuant to
Regulation (EC) No 216/2008 of the European Parliament and of the Council;
(ii) ICAO Annex 18 ‘Safe Transport of Dangerous Goods by Air’; and
(iii) ICAO Doc 9284-AN/905, ‘Technical Instructions for the Safe Transport of Dangerous
Goods by Air’.
3. OBJECTIVE OF OCCURRENCE REPORTING
(a) The occurrence-reporting system is an essential part of the overall monitoring function. The
objective of the occurrence-reporting, collection, investigation and analysis systems
described in the applicable requirements of Regulation (EU) 2018/1139, as well as of
Regulation (EU) No 376/2014 and the delegated and implementing acts adopted on the basis
thereof is to use the reported information to contribute to the improvement of aviation
safety and it should not be used to attribute blame or liability or to establish benchmarks for
safety performance.
(b) The detailed objectives of the occurrence-reporting systems are to:
(i) enable an assessment of the safety implications of each occurrence to be made,
including previous similar occurrences, so that any necessary action can be initiated;
this includes determining what had occurred and why, and what might prevent a
similar occurrence from happening in the future;

AMC 20-8A
(ii) ensure that knowledge of occurrences is disseminated so that other persons and
organisations may learn from them.
(c) The occurrence-reporting system is complementary to the normal day-to-day procedures
and ‘control’ systems and is not intended to duplicate or supersede any of them. The
occurrence-reporting system is a tool to identify those occasions where routine procedures
have failed.
(d) Occurrences should remain in the database when judged reportable by the person
submitting the report as the significance of such reports may only become obvious at a later
date.
4. REPORTING TO EASA AND COMPETENT AUTHORITIES
(a) For organisations that have their principal place of business in a Member State, Commission
Implementing Regulation (EU) 2015/1018 provides a classification of the occurrences in civil
aviation for which reporting is mandatory. This list should not be understood as being an
exhaustive collection of all the issues that may pose a significant risk to aviation safety, and
therefore reporting should not be limited to the items listed therein and the additional items
identified in points 21.A.129(f) and 21.A.165(f) of Part 21.
For organisations that do not have their principal place of business in a Member State, such
a list is provided in Section 9.
(b) These lists are based on the following general airworthiness requirements:
(i) The design rules for products, parts and appliances prescribe that an occurrence that
is defined as a failure, malfunction, defect or other occurrence related to a product or
part, which has resulted or may result in an unsafe condition, must be reported to
EASA.
(ii) The product and part production rules prescribe that products or parts released from
the production organisation with deviations from the applicable design data that could
lead to a potential unsafe condition, as identified with the holder of the type certificate
(TC) or design approval holder (DAH), must be reported to the competent authority.
(iii) The continuing airworthiness rules stipulate that an occurrence that is defined as any
safety-related event or condition of an aircraft or component identified by the
organisation that endangers or, if not corrected or addressed, could endanger an
aircraft, its occupants or any other person, must be reported to the competent
authority.
(iv) In addition, the continuing airworthiness rules prescribe that any incident,
malfunction, technical defect, exceedance of technical limitations, occurrence that
would highlight inaccurate, incomplete or ambiguous information, contained in the
Instructions for Continued Airworthiness (ICA) established in accordance with
Regulation (EU) No 748/2012, or other irregular circumstance that has or may have
endangered an aircraft, its occupants or any other person, must be reported to the
competent authority and to the organisation responsible for the design of the aircraft.
(c) Reporting does not remove the responsibility of the reporter or the organisation to initiate
actions to prevent similar occurrences from happening in the future.

AMC 20-8A
(d) A design or maintenance programme may include additional reporting requirements for
failures or malfunctions associated with that approval or programme.
5. REPORTING TIME — MANDATORY REPORTING — INITIAL REPORT
(a) The period of 72 hours is normally understood to start from when the person or organisation
became aware of the occurrence. This means that there may be up to 72 hours maximum for
a person to report to the organisation or to directly report to the competent authority, plus
72 hours maximum for the organisation to report to the competent authority.
(b) Within the overall limit of 72 hours for the submission of a report, the organisation should
determine the degree of urgency based on the severity of consequence judged to have
resulted from the occurrence:
(i) Where an occurrence is judged to have resulted in an immediate and particularly
severe consequence, EASA and/or the competent authority expects to be notified
immediately, and by the fastest possible means (e.g. telephone, fax, telex, e-mail) of
whatever details are available at that time. This initial notification should then be
followed up by a report within 72 hours.
A typical example of severe consequences would be an uncontained Engine failure that
results in damage to the aircraft primary structure.
(ii) Where the occurrence is judged to have resulted in a less immediate and less
significant risk, the report submission may be delayed up to the maximum of 72 hours
in order to provide more details or more reliable information.
6. CONTENT OF INITIAL REPORTS
(a) For organisations that have their principal place of business in a Member State, the content
of mandatory reports and, where possible, voluntary reports, is defined in Annex I to
Regulation (EU) No 376/2014.
(b) For organisations that do not have their principal place of business in a Member State,
mandatory reports and, where possible, voluntary reports, should include the information
below:
(i) when: UTC date;
(ii) where: State/area of occurrence — location of occurrence;
(iii) aircraft-related information: aircraft identification, State of Registry, make-model
series, aircraft category, propulsion type, mass group, aircraft serial number, and
aircraft registration number;
(iv) aircraft operation and history of flight: operator, type of operation, last departure
point, planned destination, flight phase;
(v) weather: the relevant weather;
(vi) where relevant, air-navigation-services-(ANS)-related information: ATM contribution,
service affected, ATS unit name;
(vii) where relevant, aerodrome-related information: location indicator (ICAO airport
code), location on the aerodrome; and

AMC 20-8A
(viii) aircraft-damage- or personal-injury-related information: severity in terms of the

highest level of damage and injury, the number and type of injuries to persons on the
ground and in the aircraft.
7. REPORTING TIME — FOLLOW-UP REPORTS
(a) For organisations that have their principal place of business in a Member State, the reporting
timelines for follow-up reports are those defined in Article 13 of Regulation (EU)
No 376/2014.
(b) For organisations that do not have their principal place of business in a Member State, the
following applies: where the organisation identifies an actual or potential aviation safety risk
as a result of their analysis of occurrences or groups of occurrences reported to EASA, it
should:
(i) transmit the following information to EASA within 30 days from the date of notification
of the occurrence to EASA:
(1) the preliminary results of the risk assessment performed; and
(2) any preliminary mitigation action to be taken;
(ii) where required, transmit the final results of the risk analysis to EASA as soon as they
are available and, in principle, no later than 3 months from the date of the initial
notification of the occurrence to EASA.
8. REPORTING AMONG ORGANISATIONS
(a) In addition to reporting occurrences to the competent authority or EASA, reporting among
organisations should be considered. Such reporting will depend on the type of the
organisation, its interfaces with other organisations, and their respective safety policies and
procedures, as well as the extent of contracting or subcontracting.
(b) Organisations may develop a customised list of occurrences to be reported among them,
adapted to their particular aircraft, operations or products, and the organisations with which
they interface. Such a customised list of occurrences to be reported among organisations is
usually included or referenced in the organisation’s expositions/handbooks/manuals. Any
such lists should, however, not be considered to be definitive or exhaustive, and it is essential
for the reporter to use their judgement of the degree of risk or potential hazard that is
involved.
(c) The following provides a non-exhaustive list of reporting lines that exist for the reporting of
occurrences among organisations related to unsafe or non-airworthy conditions:
(i) production organisation to the organisation responsible for the design;
(ii) maintenance organisation/continuing airworthiness management organisation
(CAMO) to the organisation responsible for the design;
(iii) maintenance organisation/CAMO to the operator;
(iv) operator to the organisation responsible for the design; and
(v) production organisation to another production organisation.

AMC 20-8A
(d) The ‘design approval holder’ is a general term, which can be any one or a combination of the
following natural persons or organisations:
(i) the holder of type certificate (TC) of an aircraft, Engine or Propeller;
(ii) the holder of a supplemental type certificate (STC) on an aircraft, Engine or Propeller;
(iii) the holder of a European technical standard order (ETSO) authorisation; or
(iv) the holder of a repair design approval or a change to a type design approval.
(e) If it can be determined that the occurrence has an impact on or is related to an aircraft
component which is covered by a separate design approval/authorisation (TC, STC or ETSO),
then the holder of such approval/authorisation should be informed. Such information must
be part of the reporting to the ‘main’ design approval holder. If an occurrence concerns a
component which is covered by a TC, STC, repair or change design approval or an ETSO
authorisation (e.g. during maintenance), then only that TC, STC, repair or change design
approval holder or ETSO authorisation holder needs to be informed by the reporting person
or organisation that first determined the impact of the TC, STC, repair or change design or
ETSO authorisation.
(f) Any organisation that reports to the design approval holder should actively support any
investigations that may be initiated by that organisation. Support should be provided by a
timely response to information requests, and by making available the affected components,
parts or appliances for the purpose of the investigation, subject to an agreement with the
respective component, part or appliance owners. Design approval holders are expected to
provide feedback to the reporting organisations on the results of their investigations.
(g) To ensure that there is effective reporting among organisations, it is important that:
(i) an interface is established between the organisations to ensure that there is an
effective and timely exchange of information related to occurrences;
(ii) any relevant safety issue is identified; and
(iii) it is clearly established which party is responsible for taking further action, if required.
(h) Organisations should establish procedures to be used for reporting among them, which
should include as a minimum:
(i) a description of the applicable requirements for reporting;
(ii) the scope of such reporting, considering the organisation’s interfaces with other
organisations, including any contracting and subcontracting;
(iii) a description of the reporting mechanism, including reporting forms, means, and
deadlines;
(iv) safeguards to ensure the confidentiality of the reporter and protection of personal
data; and
(v) the responsibilities of the organisations and personnel involved in reporting, including
for reporting to the competent authority.
Such procedures should be included in the organisation’s expositions/handbooks/manuals.

AMC 20-8A
Figure 1 below presents a simplified scheme of the reporting lines.
Figure 1
9. REPORTABLE OCCURRENCES — MANDATORY REPORTING

For organisations that do not have their principal place of business in a Member State, the text
below provides a classification of occurrences in civil aviation for which reporting is mandatory. This
list should not be understood as being an exhaustive collection of all the issues that may pose a
significant risk to aviation safety and, therefore, reporting should not be limited to the items listed
therein and the additional items identified in points 21.A.129(f) and 21.A.165(f) of Part 21.
9.1. MANUFACTURING
Products, parts or appliances released from the production organisation with deviations from the
applicable design data that could lead to a potential unsafe condition as identified by the holder of
the type certificate or design approval.
9.2. DESIGN
Any failure, malfunction, defect or other occurrence related to a product, part or appliance which
has resulted, or may result, in an unsafe condition.
Remark: This list is applicable to occurrences that occur on a product, part or appliance covered by
the type certificate (TC), restricted type certificate (RTC), supplemental type certificate (STC), ETSO
authorisation, major repair design approval or any other relevant approval deemed to have been
issued in line with Commission Regulation (EU) No 748/2012.

AMC 20-8A
9.3. MAINTENANCE AND CONTINUING AIRWORTHINESS MANAGEMENT

(a) Serious structural damage (for example, cracks, permanent deformation, delamination,
debonding, burning, excessive wear, or corrosion) found during maintenance of the aircraft
or component.
(b) Serious leakage or contamination of fluids (for example, hydraulic, fuel, oil, gas or other
fluids).
(c) A failure or malfunction of any part of an Engine or power plant and/or transmission that
results in either or both of the following:
(i) non-containment of components/debris;
(ii) failure of the Engine mount structure.
(d) Damage to a Propeller, or a failure or defect of a Propeller, which could lead to in-flight
separation of the Propeller or any major portion of the Propeller and/or malfunctions of the
Propeller control.
(e) Damage to a main rotor gearbox/attachment, or a failure or defect of a main rotor
gearbox/attachment, which could lead to an in-flight separation of the rotor assembly and/or
malfunctions of the rotor control.
(f) A significant malfunction of a safety-critical system or equipment, including a malfunction of
an emergency system or equipment during maintenance testing, or a failure to activate these
systems after maintenance.
(g) The incorrect assembly or installation of components of the aircraft found during an
inspection or test procedure that was not intended for that specific purpose.
(h) An incorrect assessment of a serious defect, or a serious non-compliance with the MEL or the
technical logbook procedures.
(i) Serious damage to the electrical wiring interconnection system (EWIS).
(j) Any defect in a life-controlled critical part that causes its retirement before the completion
of its full service life.
(k) The use of products, components or materials from an unknown or suspect origin, or
unserviceable critical components.
(l) Misleading, incorrect or insufficient applicable maintenance data or procedures, including
language issues, which could lead to significant maintenance errors.
(m) The incorrect control or application of aircraft maintenance limitations or scheduled
maintenance.
(n) Releasing an aircraft to service from maintenance if there remains any non-compliance which
endangers flight safety.
(o) Serious damage caused to an aircraft during maintenance activities due to incorrect
maintenance or the use of inappropriate or unserviceable ground support equipment that
requires additional maintenance actions.
(p) Identified occurrences of burning, melting, smoke, arcing, overheating or fire.

AMC 20-8A
(q) Any occurrence in which human performance, including the fatigue of the personnel, has
directly contributed, or could have contributed, to an accident or a serious incident.
(r) A significant malfunction, reliability issue, or recurrent recording quality issue that affects a
flight recorder system (such as a flight data recorder system, a data link recording system or
a cockpit voice recorder system) or a lack of the information needed to ensure the
serviceability of a flight recorder system.
[Amdt 20/19]

AMC 20-9
AMC 20-9
AMC 20-9 Acceptable Means of Compliance for the Approval of

Departure Clearance via Data Communications over ACARS
1 PREAMBLE
1.1 This AMC is issued in response to the EUROCONTROL Convergence and Implementation Plan
that recommends an interim deployment of air-to-ground and ground- to-air data link
applications based on the existing airline ACARS technology. One such application is
Departure Clearance (DCL) data link now operational at various airports in Europe (as
indicated in AIPs). Aircraft operators, on a voluntary basis, may take advantage of DCL over
ACARS where it is available, subject to any arrangements that may be required by their
responsible operations authority.
1.2 The use of ACARS for data link purposes is a transitional step to data link applications that
will use VDL Mode 2 and the Aeronautical Telecommunications Network (ATN), compliant
with ICAO SARPS, as proposed in the EUROCONTROL LINK2000+ programme8.
1.3 Described in EUROCAE document ED-85A (hereafter “ED-85A”), Data Link Application System
document (DLASD) for the “Departure Clearance” Data Link Service, DCL over ACARS is a
control tower application providing direct communication between the flight crew and the
air traffic controller. ED-85A addresses three domains: airborne, ground ATC, and
communication service providers. It deals also with associated flight crew and controller
procedures. ED-85A takes account of EUROCAE document ED-78 which describes the global
processes including approval planning, co-ordinated requirements determination,
development and qualification of a system element, entry into service, and operations.
2 PURPOSE
2.1 This AMC is intended for operators seeking to use Departure Clearance via data link over
ACARS as described in ED-85A. It may assist also other stakeholders such as airspace planners,
air traffic service providers, ATS system manufacturers, communication service providers,
aircraft and equipment manufacturers, and ATS regulatory authorities to advise them of the
airborne requirements and procedures, and the related assumptions.
2.2 This AMC provides a method for evaluating compliance of a data link system to the
requirements of ED-85A, and the means by which an aircraft operator can satisfy an authority
that operational considerations have been addressed.
3 SCOPE
3.1 This AMC addresses DCL over ACARS using the ARINC 623 protocol as elaborated in EUROCAE
document ED-85A and promoted by the EUROCONTROL Convergence and Implementation
Plan as an interim data link application pending maturity of the LINK2000+ programme. The
AMC is not directly applicable to Pre-Departure Clearance (PDC) as used in the USA and some
other states. For PDC approval, guidance may be found in FAA document Safety and
8
Information on LINK2000+ is available at web site www.eurocontrol.int/link2000

AMC 20-9
Interoperability Requirements for Pre- Departure Clearance, issued by AIR-100 on April 21,
1998. A comparison of PDC with DCL may be found in Appendix 1.
3.2 This AMC is not applicable to the phased implementation of data link services within the
EUROCONTROL LINK2000+ programme, in particular, DCL over the Aeronautical
Telecommunications Network via VHF Digital Data Link (VDL) Mode 2. In this case, the Safety
and Performance Requirements (EUROCAE ED-120) and the Interoperability Requirements
(EUROCAE ED-110) are established using EUROCAE document ED-78A, Guidelines for
Approval of the Provision and use of Air Traffic Services supported by Data Communications.
Guidance for the implementation of DCL over ATN may be found in EASA document AMC 20-
11.
3.3 The operational requirements for the DCL application are published in the EUROCONTROL
document OPR/ET1/ST05/1000, Edition 2, October 15, 1996, Transition guidelines for initial
air ground data communication services. The EUROCONTROL document includes the re-
issued clearance capability, however document ED-85A does not address this capability and
it is not included in the scope of this AMC.
3.4 For the remainder of this document, the acronym DCL should be interpreted to mean DCL
over ACARS using the ARINC 623 protocol unless stated otherwise.
4 REFERENCE DOCUMENTS
4.1 Related Requirements
CS/FAR 25.1301, 25.1307, 25.1309, 25.1322, 25.1431, 25.1581, or equivalent requirements
of CS 23, 27 and 29 if applicable.
4.2 Related Standards and Guidance Material
ICAO Doc 9694 AN/955 Manual of Air Traffic Services (ATS) Data Link
Applications
Doc 4444 Rules of the Air and Air Traffic Services
Draft Proposal PANS-Air Traffic Management
Annex 11 Air Traffic Services
Doc 8585 Designators for Aircraft Operating agencies,
Aeronautical Authorities and Services
Doc 8643 Aircraft Type Designators
EASA AMC 25-11 Electronic Display Systems
EUROCONTROL CIP: COM. Implement Air/Ground Communication
ET2.SO4; 2.1.5 Services- Interim step on non-ATN (ACARS) services.
OPR/ET1/ST05/1000 Transition guidelines for initial air ground data
communication services
ESARR 4 Risk assessment and mitigation in ATM
FAA AC 25-11 Electronic Display Systems.
AC 120-COM Initial Air Carrier Operational Approval for use of
Digital Communication Systems
AC 20-140 Guidelines for design approval of aircraft data
communications systems

AMC 20-9
98-Air-PDC Safety and Interoperability requirement for Pre-

Departure-Clearance (PDC). (Air-100, April 21,1998)
EUROCAE ED 78 Guidance material for the establishment of data link
supported ATS Services
ED-85A Data Link Application System document (DLASD) for
the “ departure Clearance ” data link service
ED-112 Minimum operational performance specification for
Crash protected airborne recorder systems
RTCA DO 224 Minimum Aviation System Performance Standards
(MASPS) for Advanced VHF Digital Data
Communications Including Compatibility with Digital
Voice Techniques.
SAE ARP 4791 Human Machine Interface on the flight deck
5 ASSUMPTIONS
Applicants should note that this AMC is based on the assumptions stated in Chapter 3 of ED-85A
together with the following that concern the measures taken by the responsible airspace
authorities to safeguard DCL operations.
5.1 ATS Provider
5.1.1 The data link service for DCL has been shown to satisfy applicable airspace safety
regulations and the relevant ATS domain performance, safety and interoperability
requirements of ED-85A.
5.1.2 Procedures for the use of DCL take account of the performance limitations of ACARS
and the airborne implementation capabilities meeting at least the provisions of this
AMC.
Note: Some aircraft ACARS installations approved to earlier standards are classified as
“Non Essential” without guarantees of performance or integrity. Consequently,
procedures are necessary to compensate for any deficiency and to safeguard
operations. ED-85A addresses this issue.
5.1.3 Appropriate procedures are established to minimise the possibility of failure to detect
inconsistency in the case of a complex clearance.
5.1.4 Each ATS provider has published a list of communication service providers that may be
used by aircraft operators for the DCL application. The list should take account of
internetworking arrangements between service providers.
5.1.5 The procedures of the ATS provider state the actions that should be taken in the event
of an inadequate communication service from the communications service provider
(CSP).
5.2 Communications Service Provider
The communications service provider does not modify the operational information (content
and format) exchanged between the ATS provider and the airborne equipment.
5.3 Aeronautical Information Service

AMC 20-9
Each State offering a DCL service by data link publishes in its AIP, or equivalent notification,
availability of the service, relevant procedures, and confirmation of compliance with ED-85A.
5.4 Message Integrity
The Cyclic Redundancy Check (CRC) is implemented as required by ED-85A and is providing
integrity of the end-to-end data link transmission path. On this basis, Performance Technical
Requirement PTR_3 of ED-85A need not be demonstrated.
6 AIRWORTHINESS CONSIDERATIONS
6.1 General
6.1.1 The installation will need to be shown compliant with the airborne domain
requirements allocated as per ED-85A (§7.1) covering the Interoperability Operational
Requirements, the Interoperability Technical Requirements, the Performance
Technical Requirements, the Safety Operational & Technical Requirements.
6.1.2 If multiple ATS data link applications are available to the aircraft, the crew interface
and related crew procedures will need to be based on a common and compatible
philosophy.
6.2 Required Functions
An acceptable minimum airborne installation comprises the following functions:
(a) A means of data communication appropriate to the area of operation, e.g. plain old
ACARS over AVLC (Aviation VHF Link Control) through VHF or SATCOM;
Note: VDL Mode 2 equipment can be used provided that radio transceiver is compliant
with ED-92A.
(b) A means to manage data communications and to control the data communications
system;
(c) A means to easily check and modify the parameters of the DCL request;
(d) “Visual” alerting of an incoming message, visible to both pilots;
(e) Means to display the text message, e.g. a single display readable by both
crewmembers or a dedicated display for each pilot.
(f) A means to accept the DCL delivered by the ATS.
6.3 Recommended Functions
(a) “Audible” alerting of an incoming message;
(b) A means to print the messages;
(c) Recording of DCL messages and flight crew responses on an accident flight recorder.
Note: Data Link recording may be required in accordance with OPS rules.

AMC 20-9
7 ACCEPTABLE MEANS OF AIRWORTHINESS COMPLIANCE

7.1 Airworthiness
7.1.1 When demonstrating compliance with this AMC, the following specific points should
be noted:
(a) Compliance with the airworthiness requirements for intended function and
safety may be demonstrated by equipment qualification, safety analysis of the
interface between the communications management system and data sources,
structural analyses of new antenna installations, equipment cooling verification,
and evidence of a suitable human to machine interface. The DCL function will
need to be demonstrated by end-to-end ground testing that verifies system
operation, either with an appropriate ATS unit, or by means of test equipment
that has been shown to be representative of the actual ATS unit.
Note: This limited testing assumes that the communication systems (VHF or
SATCOM) have been shown to satisfactorily perform their intended functions in
the flight environment in accordance with applicable requirements.
(b) The safety analysis of the interface between the communications management
system and its data sources should show that, under normal or fault conditions,
no unwanted interaction which adversely affects essential systems can occur.
7.1.2 To minimise the certification effort for follow-on installations credit may be granted
for applicable certification and test data obtained from equivalent aircraft
installations.
7.2 Performance
The installation should be shown to meet the airborne domain performance requirements
allocated by ED-85A (§7.1). Demonstration of Performance Technical Requirement PTR_A1
may be difficult for some airborne installations. The applicant may choose an alternative
acceptable means of compliance for PTR_A1 consisting in an end-to-end demonstration of
PTR_5 & PTR-6 of ED-85A (§5.2) with an appropriate ATS unit and communication service
provider.
7.3 Aircraft Flight Manual
The Flight Manual should state the following limitation.
Note: This limited entry assumes that a detailed description of the installed system and
related operating instructions are available in other operating or training manuals and that
operating procedures take account of ED-85A.
Limitation: The Departure Clearance (DCL) over ACARS application has been demonstrated
with data link services declared compliant with EUROCAE document ED- 85A.
7.4 Existing installations
The applicant will need to submit a compliance statement that shows how the criteria of this
AMC have been satisfied for existing installations. Compliance may be established by
inspection of the installed system to confirm the availability of required features and
functionality.

AMC 20-9
Note: It is not intended that aircraft which have received airworthiness approval in
compliance with ED-85 requirement should be reinvestigated where the installation is
compliant with Section 6, 7 and 8 of this AMC.
8 OPERATIONAL CONSIDERATIONS
8.1 Flight Plan Information
8.1.1 The Aircraft Identification transmitted by data link will need to conform to the ICAO
format and correspond with the flight identity as entered in the applicable flight plan.
8.1.2 Aircraft type designator includes both Aircraft Type and Sub-type and shall be coded
in accordance with the format described in ICAO document 8643 at its latest edition.
However, certain ACARS equipment can be pre-programmed only with Aircraft Type
with the possibility of manual insertion of Sub-type via the system control panel.
Absence of the Sub-type information may lead either to a rejected departure clearance
request at some airports, or the issue of an inappropriate clearance where the aircraft
performance capability is not taken into account. Where, to obtain the DCL service,
Sub-type needs to be entered manually, the entry should be verified.
8.2 Operational Safety Aspects
8.2.1 Failure Conditions are presented in ED-85A (§6) together with the resulting safety
requirements and operational means of mitigation. Failure Condition FC3 (undetected
erroneous SID) is discussed further in the following paragraphs.
8.2.2 When a SID construct is simple and unambiguous (e.g. only one SID for one runway
magnetic orientation (QFU) and one destination) so allowing the flight crew and the
ATS controller to independently detect any inconsistency in the DCL, then additional
means of mitigation are not required.
8.2.3 For other, more complex cases where the SID construction prevents the flight crew
and the controller from readily detecting any inconsistency, a specific flight crew to
controller procedure will need to be implemented to verify the clearance. This may be
stated in the AIP or other notification issued by the State where aircraft will operate
and use DCL service.
Note (1): In some countries (e.g. United Kingdom, AIC 125/1999, France AIC A19/00),
following the investigation of level violations, voice confirmation of cleared altitude or
flight level and SID identification is already required even for voice delivered departure
clearance on the first contact with the approach control/departure radar. In such
cases, no additional confirmation procedure is required.
Note (2): The ATS may agree that voice confirmation is not required where the data
link function is certificated with an integrity level corresponding to the Essential
category of CS25.1309.
8.2.4 In all cases, flight crews will need to comply with any mitigating procedures published
by the States where aircraft will operate and use DCL service.
8.2.5 The assumptions of Section 5 need to be satisfied as a condition for operational use.

AMC 20-9
8.3 Operations Manual and Training

8.3.1 The Operations Manual shall reflect the Flight Manual statement of paragraph 7.3 and
define operating procedures for use of the DCL.
8.3.2 Flight crew training should address:
(a) The different data link services available using the same airborne equipment
(e.g. differences between DCL and PDC applications as described in Annex 1);
(b) ATS procedures for DCL; and
(c) The required format for the flight identification input.
8.3.3 Subject to any arrangements that may be required by the responsible operations
authority in respect of amendments to the Operations Manual, and the approval of
training programmes, the aircraft operator may implement operations using DCL over
ACARS.
8.4 Incident reporting
Significant incidents associated with a departure clearance transmitted by data link that
affects or could affect the safe operation of the aircraft will need to be reported in
accordance with applicable operational rules, and to the authority responsible for the airport
where the DCL service was provided.
AVAILABILITY OF DOCUMENTS
EUROCAE documents may be purchased from EUROCAE, 17 rue Hamelin, 75783 Paris Cedex 16, France,
(Fax: 33 1 45 05 72 30). Web site: www.eurocae.org.
JAA documents are available from the JAA publisher Information Handling Services (IHS). Information on
prices, where and how to order is available on both the JAA web site www.jaa.nl and the IHS web site
www.avdataworks.com.
EUROCONTROL documents may be requested from EUROCONTROL, Documentation Centre, GS4, Rue de
la Fusee, 96, B-1130 Brussels, Belgium; (Fax: 32 2 729 9109 or web site www.eurocontrol.int).
ICAO documents may be purchased from Document Sales Unit, International Civil Aviation Organisation,
999 University Street, Montreal, Quebec, Canada H3C 5H7, (Fax: 1 514 954 6769, e-mail:
[email protected]) or through national agencies.
FAA documents may be obtained from Department of Transportation, Subsequent Distribution Office
SVC-121.23, Ardmore East Business Centre, 3341 Q 75th Avenue, Landover, MD 20785, USA. Web site
www.faa.gov/aviation.htm
RTCA documents may be obtained from RTCA Inc, 1828 L Street, NW., Suite 805, Washington, DC 20036,
USA., (Tel: 1 202 833 9339; Fax 1 202 833 9434). Web site: www.rtca.org.
SAE documents may be obtained from SAE World Headquarters, 400 Commonwealth Drive, Warrendale,
PA 15096-0001, USA. Telephone 1-877-606-7323 (U.S. and Canada only) or 724/776-4970 (elsewhere).
Web site www.sae.org.
[Amdt 20/1]

AMC 20-9
Appendix 1 to AMC 20-9 PDC versus DCL: A Comparison

The US Pre-Departure Clearance.

In the United States, the concept of Pre-departure Clearance is used where PDC messages are delivered
via the airlines own ACARS network and operational host computer. The airline host, or the flight crew,
initiates the process for the generation of the PDC by submitting the flight plan information to the air
traffic service, which in turn forwards the flight strip information to the appropriate airport control tower.
Approximately 30 minutes before the aircraft is scheduled to depart, the approved PDC is transmitted
from the tower via ground-ground data link to the airline host computer. The airline host responds with
an acknowledgement that ultimately feeds back to the tower PDC workstation. Depending upon the
airline capabilities, the PDC may then be transmitted directly to the aircraft flight deck via the ACARS data
link. If the aircraft is not equipped with ACARS, the approved PDC is sent to an airport gate printer for
delivery by hand in printed format to the aircraft. For a clearance requested from the aircraft, the flight
crew will initiate a PDC request via the ACARS data link network to the airline host computer. The host
will then respond via the ACARS network with the approved PDC.
Thus, the airline is responsible for ensuring that the clearance is delivered to the flight crew. Without PDC,
Instrument Flight Rule (IFR) clearances for departing aircraft are provided by the clearance-delivery
controller via a tower voice channel.
The PDC is pre-formatted in an ARINC 620 free text message. The ARINC 623 standard also may be used
but it is not required. All failures are classified Minor by the fact that flight crew has to follow a procedure
to verify the information with the initial flight plan and, by voice communication, with departure control.
Guidance on the use of PDC may be found in FAA document Safety and Interoperability Requirements for
Pre-Departure Clearance, issued by AIR-100 on April 21, 1998.
The European Departure Clearance.
In Europe, departure clearance over ACARS is a direct ATC to pilot data link communication based on the
EUROCAE ED-85A and ARINC 623 standards. The clearance delivered by data link is fully considered as an
ATC departure clearance and it is not the responsibility of the airline to ensure delivery via its own
facilities. ARINC 623 provides enhanced integrity of end-to-end communication, compared to ARINC 620
as used in the USA. However, flight crew verification procedures may still be required due to departure
clearance options such as alternative SIDs, or to satisfy AIP requirements for local safety reasons.
Current operational implementation in Europe does not include a re-issued clearance capability, which is
under study by some ATS providers.
[Amdt 20/1]

AMC 20-9
Appendix 2 to AMC 20-9 Common Terms

Reference should be made to EUROCAE document ED-85A for definition of terms.

Abbreviations
ACARS Aircraft Communication, Addressing and Reporting System
AIP Aeronautical Information Publication
ARINC Aeronautical Radio Inc.
ATS Air Traffic Services
CPDLC Controller-Pilot Data Link Communication
DCL Departure Clearance
ESARR EUROCONTROL Safety Regulatory Requirement
EUROCAE European Organisation for Civil Aircraft Equipment
PDC Pre-departure Clearance (as used in USA)
PTR Performance Technical Requirement
RTCA RTCA Inc.
SAE Society of Automotive Engineers
SARPS ICAO Standards and Recommended Practices
SID Standard Instrument Departure
VDL VHF Digital Link
[Amdt 20/1]

AMC 20-10
AMC 20-10
AMC 20-10 Acceptable Means of Compliance for the Approval of

Digital ATIS via Data Link over ACARS
1 PREAMBLE
1.1 This AMC is issued in response to the EUROCONTROL Convergence and Implementation Plan
that recommends an interim deployment of air-to-ground and ground-to-air data link
applications based on the existing airline ACARS technology. One such application is Digital
Automated Terminal Information Services (D-ATIS) now planned to be operational at various
airports in Europe. Aircraft operators, on a voluntary basis, may take advantage of D-ATIS
where it is available, provided the service is verified in accordance with operational
procedures acceptable to the responsible operations authority.
1.2 The use of ACARS for data link purposes is a transitional step to data link applications that
will use VHF Digital Link (VDL) Mode 2 and the Aeronautical Telecommunications Network
(ATN), compliant with ICAO SARPS, as proposed in the EUROCONTROL LINK2000+
programme9.
1.3 Described in EUROCAE document ED-89A, Data Link Application System document (DLASD)
for the “ATIS” Data Link Service, D-ATIS is a control tower application providing direct
communication of ATIS information to the flight crew and, optionally automatic updating of
this information. The ED-89A document addresses three domains: airborne, ground ATC, and
communication service providers. It deals also with associated flight crew and air traffic
service provider procedures. ED-89A incorporates the protocols and message formats
formerly published in ARINC Specification 623, and takes account of EUROCAE document ED-
78 which describes the global processes including approval planning, co-ordinated
requirements determination, development and qualification of a system element, entry into
service, and operations.
2. PURPOSE
2.1 This AMC is intended for operators intending to use Digital ATIS over ACARS as described in
document EUROCAE ED-89A. It may assist also other stakeholders such as airspace planners,
air traffic service providers (ATSP), ATS system manufacturers, communication service
providers (CSP), aircraft and equipment manufacturers, and ATS regulatory authorities to
advise them of the airborne requirements and procedures, and the related assumptions.
2.2 This AMC provides a method for evaluating compliance of a data link system to the
requirements of ED-89A, and the means by which an aircraft operator can satisfy an authority
that operational considerations have been addressed.
3 SCOPE
3.1 This AMC addresses D-ATIS over ACARS using the ARINC 623 protocol as elaborated in
EUROCAE document ED-89A and promoted by the EUROCONTROL Convergence and
9
Information on LINK2000+ is available at web site www.eurocontrol.int/link2000

AMC 20-10
Implementation Plan as an interim data link application pending maturity of the LINK 2000+
programme.
3.2 Other implementation of D-ATIS service may exist in the world. They are not necessarily
identical to the service defined within this AMC and EUROCAE document ED-89A. For
example, application message formats may differ. Similarly, the ATSP may send ATIS
information to an ACARS communication service provider who then distributes it to
subscriber operators. This should not be considered as an air traffic service offered directly
by an ATSP. In the USA, guidance on ATIS data link approval for use in the US airspace, may
be found in FAA document 98-AIR D-ATIS: Safety and Interoperability Requirements for ATIS.
3.3 This AMC is not applicable to the phased implementation of data link services within the
EUROCONTROL LINK2000+ programme, in particular, D-ATIS over the Aeronautical
Telecommunications Network via VHF Digital Link (VDL) Mode 2. In this case, the Safety and
Performance Requirements (EUROCAE ED-120) and the Interoperability Requirements
(EUROCAE ED-110) have been established using EUROCAE document ED-78A, Guidelines for
Approval of the Provision and use of Air Traffic Services supported by Data Communications.
Guidance for the implementation of data link over ATN may be found in EASA document AMC
20-11.
3.4 The operational requirements for the D-ATIS application are published in EUROCONTROL
document OPR/ET1/ST05/1000, Transition guidelines for initial air ground data
communication services.
3.5 For the remainder of this document, the acronym D-ATIS should be interpreted to mean D-
ATIS over ACARS using the ARINC 623 protocol in accordance with ED-89A unless stated
otherwise.
4.1 Related Requirements
CS/FAR 25.1301, 25.1307, 25.1309, 25.1322, 25.1431, 25.1581, or equivalent requirements
of CS 23, 27 and 29, if applicable.
4.2 Related Standards and Guidance Material
ICAO Doc 9694 AN/955 Manual of Air Traffic Services (ATS) Data Link
Applications
Doc 4444 Rules of the Air and Air Traffic Services
Annex 11 Air Traffic Services
Doc 8585 Designators for Aircraft Operating agencies,
Aeronautical Authorities and Services.
EASA AMC 25-11 Electronic Display Systems
EUROCONTROL CIP: COM. Implement Air/Ground Communication Services-
ET2.SO4; 2.1.5 Interim step on non-ATN (ACARS) services.
OPR/ET1/ST05/1000 Transition guidelines for initial air ground data
communication services
ESARR 4 Risk assessment and mitigation in ATM
FAA AC 25-11 Electronic Display Systems.

AMC 20-10
AC 120-70 Initial Air Carrier Operational Approval for use of

Digital Communication Systems
AC 20-140 Guidelines for design approval of aircraft data
communications systems
98-Air-D-ATIS Safety and Interoperability requirement for D-ATIS
(Air-100, April 21,1998)
EUROCAE ED 78 Guidance material for the establishment of data link
supported ATS Services
ED-89A Data Link Application System document (DLASD) for
the “ATIS” data link service
ED-92A Minimum Operational Performance specification for
an airborne VDL Mode 2 Transceiver
ED-112 Minimum operational performance specification for
Crash protected airborne recorder systems
Note: Includes criteria for recording of data link
messages.
RTCA DO-224 Minimum Aviation System Performance Standards
(MASPS) for Advanced VHF Digital Data
Communications Including Compatibility with Digital
Voice Techniques.
SAE ARP 4791 Human Machine Interface on the flight deck
5 ASSUMPTIONS
Applicants should note that this AMC is based on the assumptions stated in Chapter 3 of document
ED-89A together with the following that concern the measures taken by the responsible airspace
authorities to safeguard operations affected by the transmission of D-ATIS.
5.1 ATS Provider
5.1.1 The data link service for ATIS has been shown to satisfy applicable airspace safety
regulations and the relevant ATS domain performance, safety and interoperability
requirements of ED-89A.
5.1.2 The ATS Provider ensures that information provided through D-ATIS service is fully
consistent with the voice information broadcast over VHF.
5.1.3 Appropriate procedures are established to minimise the possibility of failure to detect
any inconsistency in ATIS information for approach, landing and take off.
5.1.4 Each ATS provider has published a list of communication service providers that may be
used by aircraft operators for the D-ATIS application. The list should take account of
internetworking arrangements between service providers.
5.1.5 The procedures of the ATS provider state the actions that should be taken in the event
of an inadequate communication service from the communications service provider.
5.2 Communications Service Provider
The communications service provider does not modify the operational information (content
and format) exchanged between the ATS provider and the airborne equipment.

AMC 20-10

The availability of the D-ATIS service, a statement of compliance with ED-89A, and additional
relevant procedures are published in the AIP or other notification issued by the States where
D-ATIS is offered.
5.4 Message Integrity
The Cyclic Redundancy Check (CRC) is implemented as required by ED-89A and is providing
integrity of the end-to-end data link transmission path. On this basis, Performance Technical
Objective PTO_3 of ED-89A need not be demonstrated by end systems. The PTO_3
requirement is applicable only to the Communication Service Provider and limits the amount
of corrupted messages that would be detected and rejected by end-systems.
Note: The CRC is described in ARINC Specification 622 Chapter 5.
6.1 General
6.1.1 The installation will need to meet the airborne domain requirements allocated as per
ED-89A (§7.1) covering the Interoperability Operational Requirements, the
Interoperability Technical Requirements, the Performance Technical Requirements,
and the Safety Operational & Technical Requirements.
6.1.2 If multiple ATS data link applications are available to the aircraft, the crew interface
and related crew procedures will need to be based on a common and compatible
philosophy.
6.2 Required Functions
An acceptable minimum airborne installation comprises the following functions:
(a) A means of data communication appropriate to the area of operation, e.g. plain old
ACARS over AVLC (Aviation VHF Link Control) through VHF or SATCOM;
Note: VDL Mode 2 equipment can be used provided that radio transceiver is compliant
with ED-92A.
(b) A means to manage data communications and to control the data communications
system.
(c) A means to easily check and modify the D-ATIS request parameters.
(d) A means of attracting the attention of the flight crew to an incoming message.
Notes:
(1) Activation of a printer may suffice to meet this need.
(2) The means used will need to be such as to avoid confusion with other,
non-data link, flight deck alerting devices.
(3) The need for temporary suppression of the attention-getter during critical
flight phases should be considered.

AMC 20-10
(e) Means to display the text message, e.g. a single display readable by both pilots or a
dedicated display for each pilot. For the interim deployment of D-ATIS over ACARS, a
printer may serve as the primary display for messages subject to compliance with
paragraph 7.3 of this AMC.
6.3 Recommended Functions
(a) A means to print the message.
(b) Recording of D-ATIS messages and flight crew requests on an accident flight recorder.
Note: Data Link recording may be required in accordance with OPS rules.
7 ACCEPTABLE MEANS OF AIRWORTHINESS COMPLIANCE
7.1 Airworthiness
7.1.1 When demonstrating compliance with this AMC, the following should be noted:
(a) Compliance with the airworthiness requirements for intended function and
safety may be demonstrated by equipment qualification, safety analyses of the
interfaces between components of the airborne communications equipment,
structural analyses of new antenna installations, equipment cooling verification,
and evidence of a suitable human to machine interface. The D-ATIS function will
need to be demonstrated by end-to-end ground testing that verifies system
operation, either with an appropriate ATS unit, or by means of test equipment
that has been shown to be representative of an actual ATS unit.
Note:
This limited testing assumes that the communication systems (VHF or SATCOM)
have been shown to satisfactorily perform their intended functions in the flight
environment in accordance with applicable requirements.
(b) The safety analysis of the interface between the ACARS and other systems
should show that, under normal or fault conditions, no unwanted interaction
that adversely affects essential systems can occur.
(c) Where a printer is used as the primary display of the ATIS message, its
readability should be shown to be adequate for this purpose, and that it does
not present an unacceptable risk of an erroneous display.
Note:
This does not preclude the use of a printer classified as non-essential provided
it has demonstrated a satisfactory in-service record that supports compliance
with paragraph 7.3 of this AMC.
7.1.2 To minimise the certification effort for follow-on installations, the applicant may claim
credit, from the responsible authority, for applicable certification and test data
obtained from equivalent aircraft installations.
7.2 Performance
The installation will need to be shown compliant with the airborne domain performance
requirements allocated by ED-89A (§7.1). Demonstration of Performance Technical

AMC 20-10
Requirement PTR_A1 may be difficult for some airborne installations. The applicant may
choose an alternative acceptable means of compliance for PTR_A1 consisting in an end-to-
end demonstration of PTR_5 & PTR_6 of ED-89A (§5.2) with an appropriate ATS unit and
communication service provider.
7.3 Safety Objectives
objectives and operational means of mitigation. Failure Condition FC3 (Non-detected
corrupted ATIS presented to an aircrew) requires that the occurrence of such a hazard
at the aircraft level be demonstrated improbable.
7.3.2 ED-89A takes into account the possibility of using ACARS approved to earlier standards
and classified as “non-essential” without guarantees of performance or integrity.
Consequently, additional procedures are necessary to compensate for any deficiency
and to safeguard operations. (See §8 of this AMC)
The Aircraft Flight Manual (AFM) or the Pilot’s Operating Handbook (POH), whichever is
applicable, should identify the D-ATIS over ACARS application as having been demonstrated
with data link services declared compliant with EUROCAE document ED-89A.
If certification was not achieved at the level “essential”, the AFM or POH, whichever is
applicable,shall remind the crew that they are responsible for checking the D-ATIS
information received over ACARS is consistent with their request, or revert to a voice ATIS.
The applicant will need to submit a compliance statement that shows how the criteria of this
AMC have been satisfied for existing installations. Compliance may be established by
inspection of the installed system to confirm the availability of required features and
functionality.
Note: It is not intended that aircraft which have received airworthiness approval in
compliance with ED 89 requirement should be reinvestigated where the installation is
compliant with Section 6, 7 and 8 of this AMC.
requirements and operational means of mitigation. Failure Condition FC3 (Non-
detected corrupted ATIS presented to an aircrew) is discussed further in the following
paragraphs.
8.1.2 Applying existing ICAO operational procedures can independently verify the majority
of ATIS parameters. Certain information may need to be verified by additional
operational procedures. Examples include runway surface conditions, air and dew
point temperatures, and other essential operational information.
8.1.3 If the aircraft system is classified and certified as “non-essential”, additional flight crew
verification procedures will need to be defined to compensate for this deficiency.

AMC 20-10
8.1.4 When the airborne system is certified as “essential”, then integrity and performance
can be considered as acceptable without a voice ATIS cross check unless otherwise
required by the AIP.
8.1.5 It is important that crew are aware that they remain responsible for checking that
received ATIS information corresponds to their request in terms of airfield name, date,
type of ATIS (D or A) and type of contract. In case of inconsistency, reversion to voice
ATIS is required.
Note: ED-89A (§6) SOR-A1 (check of name of airfield), SOR-A2 (ATIS letter
acknowledgement at first contact) and SOR-A3 (check of global consistency of
information) require checks irrespective of the level of classification of the data link
system
8.1.6 Flight crews will need to comply with any additional mitigating procedures published
by the States where aircraft will operate and use a D-ATIS service.
8.1.7 The assumptions of Section 5 of this AMC need to be satisfied as a condition for
operational use.
8.2.1 The Operations Manual shall reflect the Flight Manual statement of paragraph 7.4, and
to define operating procedures for the use of D-ATIS via ACARS taking into account the
Operational Considerations discussed in paragraph 8 of this AMC.
8.2.2 Similarly, flight crew training shall address:
(a) The different data link services available using the same airborne equipment
(e.g. differences between ATIS provided through D-ATIS service that are
declared to conform to ED-89A requirements, and ATIS received through other
means such as ACARS AOC).
(b) The procedures for safe use of D-ATIS over ACARS.
8.2.3 Subject to any arrangements that may be required by the responsible operations
authority in respect of amendments to the Operations Manual, and the approval of
training programmes, the aircraft operator may implement operations using D-ATIS
over ACARS without the need for further formal operational approval.
Significant incidents associated with a D-ATIS transmitted by data link that affects or could
affect the safe operation of the aircraft will need to be reported in accordance with applicable
operational rules. The incident should be reported also to the ATS authority responsible for
the airport where the D-ATIS service is provided.
AVAILABILITY OF DOCUMENTS
EUROCAE documents may be purchased from EUROCAE, 17 rue Hamelin, 75783 Paris Cedex 16, France,
(Fax: 33 1 45 05 72 30). Web site: www.eurocae.org
JAA documents are available from the JAA publisher Information Handling Services (IHS). Information on
prices, where and how to order is available on both the JAA web site: www.jaa.nl and the IHS web site:

AMC 20-10
www.avdataworks.com. JAA documents transposed to publications of the European Aviation Safety

Agency (EASA) are available on the EASA web site www.easa.eu.int
EUROCONTROL documents may be requested from EUROCONTROL, Documentation Centre, GS4, Rue de
la Fusee, 96, B-1130 Brussels, Belgium; (Fax: 32 2 729 9109). Web site: www.eurocontrol.int
ICAO documents may be purchased from Document Sales Unit, International Civil Aviation Organisation,
999 University Street, Montreal, Quebec, Canada H3C 5H7, (Fax: 1 514 954 6769, e-mail:
[email protected]) or through national agencies.
FAA documents may be obtained from Department of Transportation, Subsequent Distribution Office
SVC-121.23, Ardmore East Business Centre, 3341 Q 75th Avenue, Landover, MD 20785, USA.
RTCA documents may be obtained from RTCA Inc, 1828 L Street, NW. Suite 805, Washington, DC 20036,
USA., (Tel: 1 202 833 9339; Fax 1 202 833 9434). Web site: www.rtca.org
SAE documents may be obtained from SAE World Headquarters, 400 Commonwealth Drive, Warrendale,
PA 15096-0001, USA. Telephone 1-877-606-7323 (U.S. and Canada only) or 724/776-4970 (elsewhere).
Web site: www.sae.org
[Amdt 20/1]

AMC 20-10
Appendix 1 to AMC 20-10 Common Terms

Reference should be made to EUROCAE document ED-89A for definition of terms.

Abbreviations
ACARS Aircraft Communication, Addressing and Reporting System
AIP Aeronautical Information Publication
ATIS Automatic Terminal Information Service
ATSP Air Traffic Service Provider
D-ATIS Digital ATIS
ARINC Aeronautical Radio Inc.
ATS Air Traffic services
CPDLC Controller-Pilot Data Link Communication
ESARR EUROCONTROL Safety Regulatory Requirement
EUROCAE European Organisation for Civil Aircraft Equipment
NAS National Airspace System (USA)
PTR Performance Technical Requirement
PTO Performance Technical Objective
RTCA RTCA Inc.
SAE Society of Automotive Engineers
SARPS ICAO Standards and Recommended Practices
VDL VHF Digital Link
[Amdt 20/1]

AMC 20-15
AMC 20-15
AMC 20-15 Airworthiness Certification Considerations for the

Airborne Collision Avoidance System (ACAS II) with optional Hybrid
Surveillance
1 PREAMBLE
This Acceptable Means of Compliance (AMC) provides a means that can be used to obtain an
airworthiness approval for the installation of ACAS II equipment which may include optional hybrid
surveillance. It is issued to support the operational requirement that requires the carriage of ACAS
II.
Hybrid Surveillance is an optional feature that allows ACAS II to use a combination of active
surveillance, i.e. actively interrogating the Mode-S Transponders of surrounding aircraft, and
passive surveillance, i.e. use of ADS-B position and altitude data (extended squitter), to update an
ACAS II track.
An applicant may elect to use an alternative means of compliance. However, those alternative
means of compliance must meet the relevant requirements and ensure a safety objectives as
defined in paragraph 5 are met. Compliance with this AMC is not mandatory.
2 RELEVANT REQUIREMENTS
The provisions to which this AMC applies are:
CS 25.1301, 1302, 1309, 1322, 1333, 1431, 1459, 1529 and 1581.
CS 23.1301, 1309, 1322, 1431, 1459, 1529 and 1581.
CS 27.1301, 1309, 1322, 1459, 1529 and 1581
CS 29.1301, 1309, 1322, 1333, 1431, 1459, 1529 and 1581
3 REFERENCE MATERIAL
EU OPS10 1.160, 1.668, 1.1045, 1.398
AMC 25.1302, AMC 25.1309, AMC 25.1322 and AMC 25-11.
ETSO-C113 Airborne Multipurpose Electronic Displays
ETSO-C119c Traffic Alert and Collision Avoidance System (TCAS) Airborne Equipment, TCAS
II.
ETSO-2C112() Air Traffic Control Radar Beacon System/Mode Select (ATCRBS/Mode S)
Airborne Equipment
10 Council Regulation (EEC) No 3922/91 on the harmonisation of technical requirements and administrative procedures in the field of civil
aviation. Regulation as last amended by Regulation (EC) No 1899/2006 of the European Parliament and of the Council of 12 December 2006
(OJ L 377, 27.12.2006, p. 1).

AMC 20-15
EUROCAE ED-143 including change 1 Minimum Operational Performance Standards for Traffic Alert
and Collision Avoidance Systems (TCAS) Airborne Equipment.
EUROCAE ED-112 Minimum Operational Performance Specification for Crash Protected Airborne
Recorder Systems
RTCA DO-300 including change 1 Minimum Operational Performance Standards (MOPS) for
Traffic Alert and Collision Avoidance System II (TCAS II) Hybrid surveillance.
4 MINIMUM EQUIPMENT QUALIFICATION
4.1 An acceptable minimum certification standard for the ACAS II equipment including optional
hybrid surveillance is EASA ETSO-C119c.
4.2 An acceptable minimum certification standard for the associated Mode S transponder is
EASA ETSO-2C112().
5 SAFETY OBJECTIVES
The applicant should perform a Functional Hazard Assessment (FHA) and System Safety Assessment
(SSA) for the proposed ACAS II installation. For the purposes of this AMC, a system includes all
airborne devices contributing to the ACAS II function. Guidance is provided in AMC 25.1309 or FAA
AC 23-1309-1() or AC 27-1B or AC 29-2C. Acceptable probability levels for functionality and alerts
are given below:
5.1 The probability of failure of the installed system to perform its intended function from a
reliability and availability perspective should be shown to be no greater than 1x10-3 per flight
hour.
5.2 The probability of failure of the system to provide the required RA aural or visual alert, when
required, without a failure indication should be shown to be no greater than 1x10- 4 per flight
hour in the terminal environment and 1x10-5 per flight hour in the en-route environment. See
note 1.
5.3 The probability of a false or misleading RA aural and visual alert due to a failure of the system
should be shown to be no greater than 1x10-4 per flight hour in the terminal environment
and 1x10-5 per flight hour in the en-route environment. See note 1.
Note: The definition of a ‘misleading alert’ is when an RA condition exists, and an RA is issued,
but the RA gives incorrect guidance. The definition of a ‘false alert’ is when an RA is
issued, but an RA condition does not exist.
5.4 Failure of the installed ACAS II must not degrade the integrity of any essential or critical system
which has an interface with the ACAS II.
The use of Hybrid Surveillance including transitions from active to passive surveillance and
vice versa, using a system that complies with the requirements of RTCA DO-300 including
Change 1, is assumed not to compromise the safety of ACAS II.
Note 1: In terminal airspace the frequency of encounters, where another aircraft could be
present, may be assumed to be once every 10 hours. In en-route airspace the
frequency of encounters, where another aircraft could be present, may be assumed to
be once every 200 hours. Different frequencies may be used if supported by
operational data.

AMC 20-15
6 HARDWARE AND INSTALLATION

6.1 General Considerations:
The installation should include as a minimum a single ACAS II system and a single Mode S
Transponder that meet the requirements of paragraph 4.
6.2 Aural Alerts:
(a) TA and RA aural alerts should be presented by the prescribed voice announcements
via flight deck loudspeakers.
(b) Consideration should be given to presenting ACAS II voice announcements via
headsets at a preset level.
(c) A means for the pilot to cancel active voice announcements and visual indicators is
permitted but should not be necessary where voice announcements have a specific
duration.
(d) The ACAS II voice announcements should be consistent with the general philosophy of
other flight deck aural alerting systems. In particular, the prioritisation and
compatibility of alerts and voice announcements from different warning systems
should be consistent with each other. The alert priorities should be wind shear, TAWS
and then ACAS II. Altitude callout advisories which occur simultaneously with ACAS II
advisories are permitted, but the audibility of each voice alert will need to be
understandable.
(e) The adequacy of aural levels will need to be demonstrated.
Note: For rotorcraft, TA and RA aural alerts should be presented via headsets at a preset level
6.3 Displays & Indications
(a) Warning and Caution alerts should comply with the guidance provided in AMC 25.1322
unless otherwise stated in this AMC.
(b) The display of Traffic and Resolution Advisory information should be consistent with
the guidance provided in AMC 25.1322 and with paragraph 5.4 of AMC 25.1302.
(c) Resolution Advisory guidance should be presented at each pilot station in the pilot’s
primary field of view.
Resolution Advisories may be presented on EFIS or IVSI displays provided their primary
functions are not compromised.
(d) A discrete red warning Resolution Advisory enunciator or an Instantaneous Vertical
Speed Indicator (IVSI) with a lighted red indication or Primary Flight Display (PFD) with
a lighted red indication or an electronic attitude display with an alphanumeric message
should be located in each pilot’s primary field of view.
(e) A means to display traffic information to each flight crew member should be provided.
Traffic information may be provided on weather radar (WXR), Electronic Flight
Instrument System (EFIS), Instantaneous Vertical Speed Indicator (IVSI) or other
compatible display screen which has been demonstrated to meet the guidance of AMC
25-11, provided their primary functions are not compromised. A separate dedicated

AMC 20-15
traffic display, readily visible to both pilots, is an acceptable alternative. In case a Multi
Function Display is used, the display should meet the requirements of ETSO-C113.
(f) Discrete TA caution lights are optional.
(g) ACAS II Resolution and Traffic Advisories which trigger the Master Warning System will
not be accepted.
(h) An indication of ACAS II system and sensor failures which prevents correct operation
should be provided.
(i) An indication that the ACAS II system is operating in TA mode should be provided.
(j) ACAS II should be automatically switched to TA mode, if ACAS II and wind shear voice
or ACAS II and TAWS voice announcements occur simultaneously.
(k) The adequacy of display visibility needs to be demonstrated.
(l) The flight crew should be aware, at all times, of the operational state of the ACAS II
system. Any change of the operational state of the ACAS II system is to be enunciated
to the flight crew via suitable means.
6.4 ACAS II Controls:
(a) Control of the ACAS II should be readily accessible to the flight crew.
(b) A means to initiate the ACAS II Self Test function should be provided.
6.5 Antennas:
(a) Either a directional antenna and an omni-directional antenna, or two directional
antennas may be installed.
Note: when installing a directional antenna and an omni-directional antenna the omni-
directional antenna should be the lower antenna.
(b) The physical locations of the transponder antennas and the ACAS II antennas will need
to satisfy isolation and longitudinal separation limits. The physical location should also
ensure that propellers or rotors do not interfere with system operation, if applicable.
ACAS II antennas may be installed with an angular offset from the aircraft centreline
not exceeding 5 degrees.
6.6 Interfaces:
(a) Pressure altitude information will need to be obtained from the same sensor source
that supplies the Mode S Transponder(s) and the flight deck altitude display(s). This
source should be the most accurate source available on the aircraft. Altitude
information should be provided via a digital data bus. ICAO Gray (Gillham) code should
not be used.
(b) An interface to a radio altimeter sensor should be provided.
(c) Inhibit logic selected for input to the ACAS II to take account of the aircraft
performance limitations will need to be evaluated and justified unless accepted for an
earlier ACAS II standard.
(d) Other interfacing for discrete data should be provided, as required.

AMC 20-15
(e) The ACAS II installation should provide an interface with the flight recorder(s).
(f) Recording of ACAS II data should be accomplished in accordance with EUROCAE ED-
112.
Note: Information necessary to retrieve and convert the stored data into engineering
units should be provided.
(g) Interfaces between systems should be analysed to show no unwanted interaction
under normal or fault conditions.
7 CERTIFICATION TESTING
Ground testing will need to be performed with due consideration of the possible risk of nuisance
advisories in operating aircraft. The precautions provided in Appendix 1 should be followed.
7.1 The bulk of testing for a modification to install ACAS II can be achieved by ground testing that
verifies system operation and interfaces with aircraft systems.
7.2 The ground tests should include:
(a) verification check of the ICAO 24 bit airframe address.;
(b) bearing accuracy check of intruder. A maximum error of ± 15 degrees in azimuth should
be demonstrated for each quadrant. Larger errors may be acceptable in the tail area
of the aircraft;
(c) failure of sensors which are interfaced to ACAS II. A test should be performed to ensure
that the effect on ACAS II agrees with the predicted results;
(d) correct warning prioritisation. The alert priorities should be wind shear, TAWS and
then ACAS II;
(e) electromagnetic interference evaluation to ensure that ACAS II does not cause
interference with other aircraft systems;
(f) the correct operation of any aircraft configurations which result in, by design, the
inhibition of RAs.
7.3 Flight testing of an initial installation should evaluate overall operation including:
(a) surveillance range;
Note: Surveillance range may vary depending on airspace conditions.
(b) target azimuth reasonableness.
(c) freedom from unwanted interference;
(d) assessment, during adverse flight conditions, of instrument visibility, display lighting,
sound levels and intelligibility of aural messages;
(e) the effects of electrical transients;
(f) validity and usability of Traffic information when the aircraft is subject to attitude
changes of ± 15 degrees in pitch and ± 30 degrees in roll;
(g) the correct operation of any aircraft configurations which result in, by design, the
inhibition of RAs;

AMC 20-15
Note: these tests may be considered to be a subset of the ground tests performed in
paragraph 7.2 (f). Only those aircraft configurations which are practical to
perform in an airborne environment need to be assessed.
(h) electromagnetic interference evaluation to ensure that ACAS II does not cause
interference with other aircraft systems.
7.4 Flight testing to demonstrate RA performance in a planned encounter between aircraft will
not normally be required for an ACAS II – Mode S equipment combination, previously
demonstrated as performing correctly. Planned encounter flight testing should not be
attempted without the agreement of the Agency.
7.5 To minimise the certification effort for ACAS II for additional aircraft types listed in the type
certificate, the applicant may claim credit, for applicable certification and flight test data
obtained from equivalent aircraft installations, including testing performed for ACAS II
version 6.04A or 7.0. Flight Testing of ACAS II will not normally be required where acceptable
evidence exists relating to the previous certification standard of ACAS II. This assumes the
introduction ACAS II involves equipment replacements only.
7.6 Equipment that meets the acceptable minimum certification standard for the ACAS II
equipment (see paragraph 4.1) has demonstrated that hybrid surveillance function does not
degrade the performance of the ACAS II active surveillance. Therefore, when the optional
hybrid surveillance function is enabled, specific installation testing of this function is not
required.
8 MAINTENANCE
The Instructions for Continued Airworthiness (ICA) should include the following:
8.1 Maintenance instructions for on aircraft ACAS II testing including the precautions of Appendix
1.
8.2 Maintenance instructions for the removal and installation of any directional antenna should
include instructions to verify the correct display of ACAS II traffic in all four quadrants.
9 AIRCRAFT FLIGHT MANUAL/PILOT OPERATING HANDBOOK
The Aircraft Flight Manual (AFM) or the Pilots Operating Handbook (POH) should provide at least
the following limited set of information. This limited set assumes that a detailed description of the
installed system and related operating instructions are available in other operating or training
manuals.
Note: Aircraft malfunctions which would prevent the aircraft from following ACAS II climb
indication, and which do not automatically inhibit the ACAS II climb indication, should be
addressed (e.g. as a cautionary note) in the AFM/POH.
9.1 Limitations Section: The following Limitations should to be included:
(a) Deviation from the ATC assigned altitude is authorised only to the extent necessary to
comply with an ACAS II Resolution Advisory (RA).
9.2 Emergency Procedures Section: none.
9.3 Normal Procedures Section: The ACAS II flight procedures should address the following:

AMC 20-15
(a) For a non-crossing RA, to avoid negating the effectiveness of a coordinated manoeuvre
by the intruder aircraft, advice that vertical speed should be accurately adjusted to
comply with the RA.
(b) Non-compliance by one aircraft can result in reduced vertical separation with the need
to achieve safe horizontal separation by visual means.
(c) A caution that under certain conditions, indicated manoeuvres may significantly
reduce stall margins with the need to respect the stall warnings.
(d) Advice that evasive manoeuvring should be limited to the minimum required to
comply with the RA.
(e) When a Climb RA is given with the aircraft in landing configuration, a normal go-around
procedure should be initiated.
10 AVAILABILITY OF DOCUMENTS
EASA documents may be obtained from EASA (European Aviation Safety Agency), 101253, D50452
Koln Germany or via the Website: http://www.easa.europa.eu/ws_prod/g/rg_certspecs.php.
EUROCAE documents may be purchased from EUROCAE, 102 rue Etienne Dolet, 92240 Malakoff,
France, (Fax: +33 1 46 55 62 65), or website: www.eurocae.net.
RTCA documents may be obtained from RTCA Inc, 1828 L Street, NW., Suite 805, Washington, DC
20036, USA, (Tel.: +1 202 833 9339; Fax: +1 202 833 9434). Website: www.rtca.org.
FAA documents may be obtained from Superintendent of Documents, Government Printing Office,
Washington DC, 20402-9325, USA. Website: www.faa.gov.

AMC 20-15
Appendix 1 to AMC 20-15 – ACAS II/Mode S Transponder Ground

Testing Precautions
Transponder/ACAS II system testing is a known source of ‘nuisance’ ACAS II warnings. The following
information provides guidance which should be followed to minimise this risk:
— When not required, ensure all transponders are selected to ‘OFF’ or ‘Standby’.
— Before starting any test, contact the local Air Navigation Service Provider (ANSP) or Air Traffic
Service (ATS) and advise them of your intention to conduct transponder testing. Advise of your start
time and test duration. Also inform them of the altitude(s) at which you will be testing, your
intended Aircraft Identification (Flight Id) and your intended Mode A code.
— Set the Mode A code to 7776 (or other Mode A code agreed with Air Traffic Control Unit).
Note: The Mode A code 7776 is assigned as a test code by the ORCAM Users Group, specifically for
the testing of transponders.
— Set the Aircraft Identification (Flight Id) with the first 8 characters of the company name. This is the
name of the company conducting the tests.
— Where possible, perform the testing inside a hangar to take advantage of any shielding properties
it may provide.
— As a precaution, where practicable, use antenna transmission covers whether or not testing is
performed inside or outside.
— When testing the altitude (Mode C or S) parameter, radiate directly into the ramp test set via the
prescribed attenuator.
— In between testing, i.e. to transition from one altitude to another, select the transponder to
‘standby’ mode.
— If testing transponder/ACAS II system parameters that do not require ‘altitude’, set altitude to
– 1000 feet (minus 1000 feet) or greater than 60,000 feet. This will minimise the possibility of ACAS
II warning to airfield and over flying aircraft.
— When testing is complete select the transponder(s) to ‘OFF’ or ‘Standby’.

AMC 20-15
Appendix 2 to AMC 20-15 – List of Acronyms

ACAS Airborne Collision Avoidance System

AMC Acceptable Means of Compliance
ANSP Air Navigation Service Provider
ATC Air Traffic Control
ATCRBS Air Traffic Control Radar Beacon System
ATS Air Traffic Service
CS Certification Specifications
EASA European Aviation Safety Agency
EFIS Electronic Flight Instrument System
ETSO European Technical Standard Order
EU European Union
EUROCAE European Organisation for Civil Aviation Equipment
FHA Failure Hazard Analysis
ICA Instructions for Continued Airworthiness
ICAO International Civil Aviation Organization
IVSI Instantaneous Vertical Speed Indicator
MEL Minimum Equipment List
ORCAM Originating Region Code Allocation Method
RA Resolution Advisory
SSA System Safety Assessment
TA Traffic Advisory
TCAS Traffic Alert and Collision Avoidance System
WXR Weather Radar
[Amdt 20/8]

AMC 20-19
AMC 20-19
AMC 20-19 Passenger Service and In-Flight Entertainment (IFE)

Systems
0 PREAMBLE
This document provides acceptable means of compliance (AMC) to obtain approval for the installation of
in-flight entertainment (IFE) systems. It has been developed on the basis of Joint Aviation Authorities
Temporary Guidance Leaflet (JAA TGL) No 17, and addresses the following concerns:
(a) the increase in the complexity of the IFE systems due to the additional cables, as well as the increase
in the power needed for IFE systems;
(b) the potential consequences on the aircraft or passengers of system/electrical faults, including the
risks of smoke, fire or interference with aircraft systems; these concerns are validated by adverse
service experience with different types of aircraft;
(c) the potential consequences for other aircraft systems due to the transmitting capability of the IFE
systems; and
(d) the lack of specific guidance on the installation of IFE systems, as these systems are categorised as
non-essential services, even though these systems may affect compliance with the applicable
provisions for seats and emergency evacuation.
1 PURPOSE
This AMC has been created to provide guidance to aircraft installers and equipment manufacturers on the
airworthiness of IFE systems and equipment installed on civil aircraft. It does not constitute a regulation.
It highlights safety concerns about IFE systems, and contains acceptable means of compliance to address
those concerns and obtain airworthiness approval of such systems. An applicant for such an approval may
choose another means of compliance.
2 RELATED CERTIFICATION SPECIFICATIONS (CSs)
Some of the certification specifications for which this AMC can be used are listed below. This list is for
reference only and should not be considered as comprehensive. Additional CS-25 provisions are
referenced where applicable. Provisions with the same number (e.g. CS 25.301) are generally read across
to the other CSs (e.g. 27.301 and 29.301). However, please note that in some cases, the same topic is
addressed by different provisions (e.g. for a specific CS-25 provision, the corresponding CS-23 provision
may have a different number):
— CS 25.301, 303, 305, 307, 333, 337, 341, 365(g), 471, 561, 562, 581, 601, 603, 605, 609, 611, 785,
787, 789, 791, 811, 831, 853, 863, 869, 899, 1301, 1309, 1319, 1327, 1351, 1353, 1357, 1360, 1423,
1431, 1441, 1703, 1705, 1707, 1709, 1715, 1719, 1721, 1723;
— for CS-23:
— AMC-20 — Amendment 19 SUBPART A — GENERAL AMC 20-19 Annex to ED Decision
2020/010/R Page 149 of 581 — Amendments 1 to 4: CS 23.561, 562, 785, 787, 791, 811, 867,
1301, 1309, 1327, 1351, 1353, 1357, 1359, 1431, 1441;

AMC 20-19
— Amendment 5: CS 23.2265, 2270, 2315, 2320, 2325, 2330, 2335, 2500, 2505, 2510, 2525,
2605, 2615;
— CS 27.561, 562, 610, 785, 787, 807, 853, 1301, 1309, 1319, 1327, 1351, 1353, 1357, 1365; and
— CS 29.561, 562, 610, 785, 787, 807, 853, 1301, 1309, 1319, 1327, 1351, 1353, 1357, 1359, 1431.
The documents listed below are standards and guidance that were in force when this AMC (AMC 20-19)
was adopted. Later or previous amendments may apply whenever the retained certification basis allows
for it.
(a) ED Decision 2017/020/R, AMC-20 — Amendment 14, AMC 20-115D, Airborne software
development assurance using EUROCAE ED-12 and RTCA DO-178, 19 October 2017
(b) ED Decision 2020/010/R, AMC 20 — Amendment 19, AMC 20-152A, Development Assurance for
Airborne Electronic Hardware, July 2020
(c) ED Decision 2020/006/R, AMC 20 — Amendment 18, AMC 20-42, Airworthiness information
security risk assessment, 24 June 2020
(d) ED Decision 2014/029/R, AMC and GM to Part-CAT — Issue 2, Amendment 1, Portable electronic
devices, AMC/GM to CAT.GEN.MPA.140, 24 September 2014, as amended by ED Decision
2019/008/R of 27 February 2019
(e) EASA Certification Memorandum No CM-ES-001, Certification of Power Supply Systems for Portable
Electronic Device, Issue 1, 7 June 2012
(f) EASA Certification Memorandum No CM-ES-003, Guidance to Certify an Aircraft as PED tolerant,
Issue 1, 23 August 2017
(g) International Civil Aviation Organization (ICAO) Doc 9284-AN/905, Technical Instructions for the
Safe Transport of Dangerous Goods by Air (Addendum No. 2), 30 June 2005
(h) Federal Aviation Administration (FAA) Advisory Circular (AC) 21-16G, RTCA Document DO-160
versions D, E, F, and G, ‘Environmental Conditions Initiated by: AIR-100 and Test Procedures for
Airborne Equipment’, 22 June 2011
(i) FAA Policy Memorandum PS-ANM100-2000-00105 (also numbered 00-111-160), Interim Policy
Guidance for Certification of In-Flight Entertainment Systems on Title 14 CFR Part 25 Aircraft (Policy
Number 00-111-160), 18 September 2011
(j) FAA AC 91.21-1D, Use of Portable Electronic Devices Aboard Aircraft, 27 October 2017
(k) FAA AC 20.168, Certification Guidance for Installation of Non-Essential, Non-Required Aircraft Cabin
Systems & Equipment (CS&E), 21 July 2010
(l) FAA AC 20.115D, Airborne Software Development Assurance Using EUROCAE ED-12( ) and RTCA
DO-178( ), 21 July 2017 AMC-20 — Amendment 19 SUBPART A — GENERAL AMC 20-19 Annex to
ED Decision 2020/010/R Page 150 of 581
(m) FAA AC 21.49, Gaining Approval of Seats with Integrated Electronic Components, 9 February 2011
(n) EUROCAE ED-14G, RTCA DO-160G, Environmental Conditions and Test Procedures for Airborne
Equipment, May 2011, December 2010

AMC 20-19
(o) RTCA DO-313, Certification Guidance for Installation of Non-Essential, Non-Required Aircraft Cabin
Systems and Equipment, 2 October 2008
(p) Society of Automotive Engineers Aerospace Recommended Practice (SAE ARP) 5475, Abuse Load
Testing for In-Seat Deployable Video Systems, 20 June 2005
(q) Aeronautical Radio, Incorporated (ARINC) 628, Cabin Equipment Interfaces, 27 December 1993
(r) MIL-STD-1472G, Human Engineering, 11 January 2012
3.1 Abbreviations
The following abbreviations are used in this AMC:
AC advisory circular
AFM aircraft flight manual
AMC acceptable means of compliance
AMM aircraft maintenance manual
ARP aerospace recommended practice
CB circuit breaker
CCOM cabin crew operations manual
COTS commercial off-the-shelf
CRI certification review item
CSs certification specifications
DAH design approval holder
DDP declaration of design and performance
DBS direct-broadcast satellite
EASA European Union Aviation Safety Agency
ELA electrical-load analysis
EMI electromagnetic interference
ESD electrostatic discharge
ETSO European technical standard order
EWIS electrical-wiring interconnection system
FCOM flight crew operations manual
FDAL functional development assurance level
FHA functional hazard assessment
GM guidance material

AMC 20-19
GSM global system for mobile communications
GUI graphical user interface
ICA Instructions for Continued Airworthiness
ICAO International Civil Aviation Organization
IDAL item development assurance level
IEEE Institute of Electrical and Electronics Engineers
IFE in-flight entertainment
LAN local area network
MCA mobile communications on aircraft
MMEL master minimum equipment list
MoC means of compliance
OEM original-equipment manufacturer
PA public address
PABX private automatic branch exchange
PED portable electronic device
PFIS passenger flight information system
PSS power supply system
RTCA Radio Technical Commission for Aeronautics
R/T real time; real-time (as modifier)
SAE ARP Society of Automotive Engineers Aerospace Recommended Practice
SP special condition
STC supplemental type certificate
SWPM standard wiring practices manual
TC type certificate
T-PED transmitting portable electronic device
USB universal serial bus
VAC volts alternating-current
VDC volts direct-current
Wi-Fi wireless fidelity
WLAN wireless local area network

AMC 20-19
3.2 Definitions
The following definitions used in this AMC apply:
Term Definition
In-flight entertainment systems On-board systems that provide passengers with (safety) information,
connectivity and entertainment
Installer Type certificate (TC), supplemental type certificate (STC) or design

approval holder (DAH)
COTS equipment Equipment that is not designed or manufactured for use in aircraft, but
is purchased by the installer for use in a particular aircraft system
4 SCOPE
Communication, information and entertainment systems are often provided for the convenience of
aircraft passengers. As customer services improve, those systems are becoming more sophisticated and
complex. Subsystem design features are often unique, based on the needs of operators, thus leading to
many different possible IFE system configurations that depend both on the specific operator requirements
and the cabin layout.
The following non-exhaustive list contains some examples of IFE systems:
(a) systems that provide passengers with audio entertainment and the related controls;
(b) systems that provide passengers with video entertainment and the related controls;
(c) passenger flight information systems (PFISs);
(d) systems that provide passengers with information, e.g. safety videos;
(e) interfaces to, and functions of, systems for controlling some cabin environment parameters such
as, for example, reading lights, general cabin illumination, crew call buttons, air vents, etc.;
(f) systems that provide passengers with wired and/or wireless data distribution for entertainment
connectivity including television (TV) and communication access (i.e. telephone, internet).
The aim of this AMC is to provide general criteria for the approval of such systems and equipment as they
are installed in aircraft. The following aspects are addressed: mechanical installation, electrical
installation, software/hardware aspects and electromagnetic compatibility, as well as the assessment of
the potential hazards. In some cases, the application of this AMC, in conjunction with the certification
basis for the product, is deemed to be sufficient.
For certain systems and equipment, additional certification material may be needed to address the
aspects that are not covered by this AMC. Some examples are:
— IFE systems with wireless-communication capabilities (e.g. wireless fidelity (Wi-Fi) access points,
mobile-phone systems);
— electrical outlets installed in the cabin for connecting portable electronic devices (PEDs);
— lithium batteries;
— data-loading systems;

AMC 20-19
— data communication systems (e.g. satellite TV, radios, passenger telephone systems, etc.); and
— large monitors/displays.
5 APPROVAL CONSIDERATIONS (AT AIRCRAFT LEVEL)
Section 6 below provides a summary of the issues that are pertinent to the safety of the aircraft, its
occupants and maintenance personnel, which the equipment manufacturer and the installer should
consider. Since IFE system installations are typical for commercially used large aeroplanes, it is expected
that the approach to be followed for General Aviation (GA) aircraft will be different (for the purpose of
this AMC, ‘General Aviation aircraft’ are those aircraft that comply with the CS-23 specifications). Section
6.7 below provides guidance in this regard. Some general considerations are presented below:
(a) The applicant for the approval of an IFE system should demonstrate compliance with the applicable
aircraft certification basis. The installed IFE system should function as intended, and no ‘credit’
should be given for its performance capability. Substantiation is required to demonstrate that the
IFE system and equipment in their installations and in operation do not interfere with the operation
of other aircraft systems, or do not cause any hazard to the aircraft, to its occupants, or to
maintenance personnel.
(b) If part of an IFE system is designed to transmit the required safety information (e.g. the passenger
briefing), the replacement system should also meet the safety objectives required for that function.
The installer should identify these safety objectives, which depend on the type of function for which
the IFE system is used.
(c) The applicant may use existing approvals for interfacing equipment (e.g. IFE system parts mounted
in seats). However, the applicant should ensure that all the applicable airworthiness provisions are
addressed. For example, European technical standard orders (ETSOs) on seats do not contain
electrical provisions; therefore, the electrical aspects of the seats should be reviewed to ensure that
the installation of IFE system equipment does not invalidate the original ETSO for the seats.
(d) If other aircraft system installations are affected by the installation of the equipment of the IFE
system, then the applicable requirements for these affected systems should be taken into account.
(e) If an IFE system is designed to be available for the operating crew, EASA should approve the related
flight operation limitations.
(f) The applicant should demonstrate that any non-essential equipment (which includes equipment
installed for the purpose of passenger entertainment), as installed:
— is not a source of danger in itself;
— does not prejudice the proper functioning of an essential service; and
— does not in any way reduce the airworthiness of the aircraft to which it is fitted, even in the
event of a failure to perform its intended functions.
For example, for large aeroplanes, compliance should be demonstrated with CS 25.1309. A
functional hazard assessment (FHA) should be performed to identify the IFE system failure scenarios
and the worst possible consequences (e.g. electrical shock) for the aircraft and its occupants. This
assessment should take into account electrical, electronic, and component faults that may result in
a short circuit and/or electrical arcing and/or the release of smoke. Particular attention should be
given to the likelihood of the following:

AMC 20-19
— accidental damage due to exposure of wiring or components in the cabin, such as wires that
are pinched in the seat track;
— misuse of the equipment by passengers, such as the incorrect stowage of video screens,
stepping on or kicking the seat electronic box, spilling liquids, etc.;
— electronic-component breakdowns; and
— wire chafing.
(g) The installer should demonstrate that the equipment of the IFE system has been installed in
accordance with the equipment manufacturer’s declaration of design and performance (DDP) and
their installation instructions. The demonstration may, in addition, involve the examination and
testing of the equipment. Subpart O ‘EUROPEAN TECHNICAL STANDARD ORDERAUTHORISATIONS’
of Annex I (Part 21) to Regulation (EU) No 748/2012 and the related AMC 21.A.608 provide guidance
on drafting and formatting the DDP.
(h) If an operator allows passengers to use PEDs on board the aircraft, it should have procedures in
place to control the use of those PEDs. Regulation (EU) No 965/2012 and the related ED Decisions
contain, respectively, requirements and associated AMC and GM on PEDs. For commercial air
transport (CAT) operations, the corresponding requirement is point CAT.GEN.MPA.140 of Annex IV
(Part-CAT).
(i) If environmental testing of the IFE system equipment is required, EUROCAE ED-14/RTCA DO 160
‘Environmental Conditions and Test Procedures for Airborne Equipment’ may be followed. This is
addressed in Section 0.1 below.
6 SYSTEMS INSTALLATION
6.1 Mechanical systems — aspects
6.1.1 Equipment location
The equipment and its controls should be positioned in locations where they do not impede the
movement or the duties of the flight crew or the cabin crew (including in crew rest areas), or the normal
movement of passengers.
(a) In a light aircraft, for example, if audio entertainment is audible to the pilot, a means to control the
sound level should be provided to the pilot. Visual-entertainment equipment should be located
where it does not distract the crew.
(b) Equipment should be located and, where necessary, protected to minimise the risk of injury to the
occupants of the aircraft during a normal flight or an emergency landing. For equipment AMC-20
— Amendment 19 SUBPART A — GENERAL AMC 20-19 Annex to ED Decision 2020/010/R Page 156
of 581 with cords in large aeroplanes, for example, the lengths of the cords should be determined
by their possible effects on the egress capability of the occupants. The cords should not span across
a main aisle such that they may become entangled in other features (such as armrests), thus
impeding egress. Means for proper and easy stowage should be provided.
(c) Equipment used for screens should not obscure any required notices or information signs (e.g.
‘Exit’, ‘No Smoking’, ‘Fasten Seat Belt’ signs, etc.). For video monitors in large-aeroplane
installations, the following should apply:
(1) For video monitors installed above the aisle:

AMC 20-19
— all the installations should be such that the required ‘exit’ signs are still visible whether
the monitors are fixed or retractable; if this is not possible, additional ‘EXIT’ signs are
required;
— fixed video monitors should be such that the minimum distance between the cabin
floor and the lowest point of the monitor is 185 cm (73 in); and
— retractable video monitors that do not meet the 185-cm (73-in) limit in the deployed
position should not have sharp edges or should be padded, and they should be able to
be stowed manually without requiring exceptional strength.
(2) For video monitors installed underneath overhead compartments:
— all the installations should be such that the required signs (e.g. ‘No Smoking’, ‘Fasten
Seat Belts’ signs, etc.) are visible whether the monitors are fixed or retractable; if this
is not possible, additional signs are required;
— fixed video monitors should be padded and should not be installed above or between
the seat backs of seat rows that border the access to emergency exits; and
— retractable video monitors should be able to be stowed manually without requiring
exceptional strength and should not be installed above or between the seat backs of
seat rows that border the access to emergency exits.
(d) Connecting units for wired on-board data exchange (e.g. USBs, local area networks (LANs), etc.)
should be designed so that their use is obvious to the crew and passengers. Placards close to their
outlet units should describe their capabilities and functions.
Units that are capable of supplying power with:
— a voltage greater than or equal to 42 V;
— power greater than 15 W; or
— a current greater than 3 A,
should be treated as power outlets.
(e) For individual video monitors attached to the seats (e.g. to the seat armrests, seat backs, movable
hinge arms), the protection of the seat occupants, as well as of the crew and passengers moving
around the cabin, should be considered. Video monitor installations should be such that injuries
due to contact with sharp edges/corners during normal operation and turbulence are avoided. The
abuse loading of video monitors (e.g. if a passenger leans on the monitor when taking or leaving
their seat) should be accounted for. The criteria of SAE ARP5475 ‘Abuse Load Testing for In-Seat
Deployable Video Systems’ or alternatives, as agreed by EASA, may be used in assessing designs
regarding this aspect.
6.1.2 Construction and attachment strength
(a) Any seat/monument installation, after modification, should continue to comply with the original
certification basis.
(b) Equipment, attachments, supporting structures, and their constituent parts should be constructed
such that they do not break loose when subjected to the loads (either for flight or for emergency
ditching) that are prescribed in the relevant CSs. Some commercial off-the-shelf (COTS) equipment

AMC 20-19
might not comply with these provisions and may need to be strengthened before being installed in
an aircraft (see Section 6.6 below on COTS equipment).
(c) The design of IFE-system-related antennas, their location and manner of attachment should be such
that there is no adverse effect on the aircraft systems and no danger to the aircraft under any
foreseeable operating conditions. Remark: If external antennas are installed, the applicant should
address the corresponding certification aspects, for which specific guidance is available (i.e.
antennas in pressurised areas, the installation of large and/or deployable antennas, etc.). The
certification approach for such external antenna installations should be agreed with EASA.
(d) As far as practicable, the equipment should be positioned so that if it breaks loose, it is unlikely to
cause injury or to nullify any of the escape facilities for use after an emergency landing or after
ditching. When such positioning is not practicable, each such item of equipment should be
restrained under any load up to the prescribed ultimate inertia forces for the emergency landing
conditions. Furthermore, for each item of equipment that is subject to frequent installation and
removal, the local attachments of these items should be designed to withstand 1.33 times the
specified loads (see CS 25.561(c)(2)). Compliance with CS 25.365(g) should also be considered.
Note 1: The structural provisions applicable to equipment can vary depending upon the type and
size of the aircraft in which the equipment is installed; if the equipment is designed to be
installed in any aircraft, then the applicant should consult all the relevant airworthiness CSs
and create an envelope of conditions for design purposes.
Note 2: If an STC holder installs the equipment, they may need to consult the TC holder to obtain
data on the vertical-acceleration factors (resulting from gusts and aircraft manoeuvres) that
are applicable to a given aircraft type and to the proposed location of the equipment.
(e) If the IFE system is installed in a seat or in a monument adjacent to a seat, the installation may need
to be reapproved for structural integrity and, if appropriate, for the emergency-landing dynamic
conditions, including the occupant injury criteria. For large aeroplanes, for example, to avoid head
injuries (CS 25.562(b) and CS 25.562(c), as referenced in CS 25.785) caused by seat-back-mounted
IFE equipment, compliance with CS 25.562(c)(5) should be shown for a fully equipped seat back in
the take-off and landing position.
(f) Weight and stress assessments should be made in cases of already embodied shelves that need to
be relocated.
(g) Glass surfaces may be part of IFE system components, e.g. in display units. The potential hazard for
the occupants in case of breakage of large sheets of glass should be considered. The approach that
the applicant should follow should be agreed with EASA based on CS 25.788 (b). Compliance with
CS.25.365(g) should also be considered.
6.2 Electrical systems — aspects
6.2.1 Power supplies
The IFE system equipment should be powered by an electrical busbar that does not supply power to the
aircraft systems that are necessary for continued safe flight and landing.
The IFE system should be designed to provide circuit protection from overloads and short circuits by
means of suitable protective devices.

AMC 20-19
(a) The method of connection of the equipment to the aircraft electrical system and the operation of
the equipment should not adversely affect the reliability or integrity of the electrical system or any
other electrical unit or system that is essential for the safe operation of the aircraft.
(b) If applicable, the aircraft electrical system should be protected from any unacceptable EMI caused
by a connected PED.
(c) The flight/cabin crew should be provided with a clearly labelled and conspicuous means to
disconnect an IFE system from its source of power at any time, and that means should be as close
as practically possible to the source of power. The disabling/deactivating of component outputs
should not be considered to be an acceptable means to cut off power, i.e. the disabling/deactivating
of the output of a power supply unit, seat electronic box, etc., as opposed to cutting off the input
power of the system. Moreover, pulling system circuit breakers (CBs) as the sole means to cut off
the IFE system power is not considered to be acceptable. This is because CBs are not normally
designed to be used as switches. The pulling and resetting of CBs over a period of time may degrade
their trip characteristics, and then the CBs might not trip when required.
(d) An electrical-load analysis (ELA) should be carried out, taking into account the maximum load that
the IFE system may utilise, to substantiate that the aircraft electrical-power generating system has
sufficient capacity to safely provide the maximum amount of power required by the IFE system to
operate properly. The applicant should base the IFE system ELA on an ELA that accurately reflects
the aircraft’s electrical loads prior to the installation of the IFE system. If this is not available, the
applicant should make measurements of the aircraft’s condition prior to the installation of the IFE
system, and use these measurements for the ELA of the IFE system.
(e) The potential cumulative effect of the installation of multiple IFE units on the harmonic content of
the electrical-power supply should be considered. There have been cases in which the installation
of multiple IFE units with switched mode power supplies has changed the shape of the alternating
current (AC) voltage waveform to the extent that the operation of the aircraft electrical power
supply system (PSS) has been affected.
(f) Where batteries are used, consideration should be given to the stored energy, and provisions
should be made for protection from short circuits and other potential failure modes.
The safety issues associated with the use in the IFE system of batteries whose technology may pose
hazards that are not covered by the current provisions should be addressed by additional provisions to be
agreed with EASA (e.g. for lithium battery technology).
6.2.2 Bonding
The electrical bonding, as well as the protection against static discharge of the installed system and
equipment, should be such as to:
(a) prevent a dangerous accumulation of electrostatic charge; and
(b) minimise the risk of electrical shock to the crew, passengers and maintenance personnel.
The system bonding arrangements should be in accordance with the aircraft manufacturer’s standard
practices, and suitable for conducting any current, including a fault current, which may need to be
conducted. The designer should take into account bonding connections in the system design such that the
loss of a single bond does not result in the loss of more than one essential circuit or in the dangerous
inadvertent operation of any aircraft system.

AMC 20-19
Cabin equipment designers should adhere to the standard practices for bonding, grounding and shielding,
as well as to other methods for eliminating or controlling electrostatic discharge.
All electrical and electronic equipment and/or components should be installed so as to provide a
continuous low-resistance path from their metallic enclosures and wiring to the aircraft bonding structure.
6.2.3 Interference
6.2.3.1 Magnetic effects
Whether the installed IFE system equipment is operating or not, the aircraft compass systems should
continue to meet the prescribed accuracy standards. Where other equipment approved as part of the
aircraft is installed, the installer should take account of the declared compass safe distance when
designing the installation.
Account should be taken of the compass safe distance in respect of both the compass and the flux
detector. The installer should also consider potential interference of the installed IFE system equipment
with the relatively low-level signal of the compass system interconnecting cables.
6.2.3.2 Electromagnetic interference (EMI)
The levels of conducted and radiated interference generated by the equipment via power supply feeders,
by system interfacing or by EMI should not cause an unacceptable degradation of the performance of
other aircraft systems. If some equipment or functions are never used, the applicable system function
should be properly disabled and/or terminated to prevent any interference with other aircraft systems.
(a) Antennas
Antennas for IFE systems should not be located where an unacceptable reduction in the
performance of a mandatory radio system would result. In addition, the effects of a lightning strike
on these antennas should be considered to ensure that essential services are not disrupted by
electrical transients conducted to the aircraft via these antenna leads.
(b) Cumulative interference effects
The actual interference effect on an aircraft receiver may be the cumulative effect of many
potentially interfering signals. For this reason, a system consisting of multiple units should be
operable even in the worst-case orientation when interference tests/demonstrations are
conducted. Tests/demonstrations should take into account the critical configurations of the use of
the IFE system, including the critical configurations of passengers’ portable electronic devices
(PEDs) connected to the IFE system. The test configuration should be agreed with EASA.
(c) Flight phases
If the whole IFE system or parts of it are to be active during the critical flight phases (i.e. takeoff and
landing), particular attention should be paid to the demonstration of non-interference during these
critical flight phases.
6.2.4 Electrical shock
Occupants should be protected against the hazard of electrical shock. Therefore, the applicant should
demonstrate the means to minimise the risk of electrical shock as per CS 25.1360(a). Particular attention
should be given to high-voltage equipment. If high- or low-voltage power outlets are available for
passenger use, the aspects related to the use of PSSs for PEDs should be considered.

AMC 20-19
6.2.5 Wiring harness and routing

The electrical-wiring interconnection system (EWIS) associated with the IFE system should be installed, as
for all other electrical systems, in accordance with the provisions of CS-25 Subpart H, or any equivalent
document accepted by EASA. In order to meet these provisions, the applicant should adhere to the
following guidelines:
— the wiring installation should be in accordance with the standard wiring practices manual (SWPM)
of the aircraft or any equivalent standard accepted by EASA;
— standard original-equipment manufacturer (OEM) wiring or compatible types of wiring should be
used;
— all the data necessary to define the design, in accordance with point 21.A.31 (Annex I (Part 21) to
Regulation (EU) No 748/2012), including the installation drawings and wiring diagrams, shall be
available; and
— where the IFE system EWIS is routed through standard aircraft wiring looms, spacers or equivalent
means of separation should be used to keep the IFE EWIS at a minimum distance from any other
electrical system in accordance with the SWPM of the aircraft.
In the absence of more specific guidelines in the SWPM of the aircraft, 230 VAC voltage power supply
wires should not be routed through standard aircraft wiring looms. As the EWIS connected to the IFE
system is present throughout the cabin (exposed in some cases), the potential for system faults is
increased by the wide exposure to varying hazards (e.g. EWIS chafing in the seat tracks, passengers
stepping on or kicking the seat electronic box, spilled liquids, etc.). Since these systems are exposed to
hazards, the potential to adversely affect other systems that are necessary for the safe operation of the
aircraft significantly increases, as well as the possibility of shock hazards to occupants. Special
consideration should be given to the protection against damage to the IFE EWIS components installed in
the seat itself: they should have appropriate protection means so that passengers cannot damage them
with their feet or access them with their hands. The engineering data that controls the installation of IFE
EWIS and equipment should contain specific and unambiguous provisions for the routing, support and
protection of all IFE EWIS and equipment, and should specify all the parts that are necessary for those
installations.
Care should be taken to ensure that any electrical IFE system equipment installed in aircraft seat
assemblies does not invalidate the seat certification (e.g. the applicable ETSO). In addition, it should be
noted that compliance alone with any applicable ETSO for seats does not cover the electrical equipment
installation aspects of the IFE system.
6.3 Aircraft interaction and interfaces
If an IFE system is electrically interfaced with other aircraft systems, the performance and integrity of
those aircraft systems should not be degraded. Appropriate means should be provided to isolate the IFE
system from the aircraft systems.
(a) If an IFE system is connected to the aircraft avionics system (or any other system that may have a
safety-related function), the installer should demonstrate that no malfunction of the IFE system
may affect the aircraft avionics system. The installer should conduct a safety analysis to substantiate
this. Supplementary to this safety analysis, special attention may be required due to cybersecurity
issues. The installer should assess the information security aspects in accordance with AMC 20-42.

AMC 20-19
(b) If an IFE system interfaces with the public address (PA) function, the use of this system should not
impair the audibility of crew commands or instructions. A PA override feature should be considered
to allow cabin announcements to be heard by passengers.
(c) If an IFE system is available for the operating crew, the operation of this system should not interfere
with, or adversely affect, the crew’s ability to operate other aircraft systems and respond to alerting
systems. The aircraft flight manual (AFM) should contain appropriate limitations and procedures.
The applicant should consider the following design interface features as acceptable means of
compliance:
(1) no access to any form of visual entertainment equipment; AMC-20 — Amendment 19
SUBPART A — GENERAL AMC 20-19 Annex to ED Decision 2020/010/R Page 162 of 581
(2) automatic muting of the IFE systems when any cockpit aural caution or warning is sounding;
there should be no perceptible delay between the muting of the IFE system and the activation
of the caution/warning;
(3) automatic muting of the IFE systems when any real-time (R/T) transmission or reception is in
progress; there should be no perceptible delay between the muting of the IFE system and the
activation of the R/T transmission or reception; and
(4) readily available controls such that the volume of the IFE system is easily reduced.
(d) If an IFE system includes wireless capabilities (wireless local area network (WLAN), mobile phone,
Bluetooth, etc.) to connect with other aircraft equipment and/or passenger or crew transmitting
portable electronic devices (T-PEDs), the installer should address the electromagnetic compatibility
of the aircraft with the intentional emissions of the IFE system, and the approach to be followed in
that respect should be agreed with EASA.
Note: The responsibility for establishing the suitability for use of a PED on a given aircraft model continues
to rest with the operator, as required by point CAT.GEN.MPA.140 (Annex IV (Part-CAT) to Regulation (EU)
No 965/2012).
The design interface features used to comply with the above should be designed with a development
rigour that depends on the function that is being interfaced with or replaced by the IFE system.
6.4 Software/airborne electronic hardware (AEH)
6.4.1 Software architecture
The software architecture of IFE system components should consider the following distinction between:
— core software as part of the functional scope defined in the specification of the component (e.g.
operating systems, hardware drivers, functional applications such as PA), including all the required
core software configuration data (the core software may be field loadable); and
— content data, including content configuration data (it may be field loadable by the aircraft
operator); for IFE system equipment, the aircraft operator is usually required to make some
adjustments and/or changes in the short term; such changes may be related to the content data
and/or content configuration data — some examples of the latter are the following:
— the selection of passenger-accessible graphical user interface (GUI) elements;
— the activation of predefined GUI designs; and

AMC 20-19
— the selection of regional information data (e.g. different country borderlines).

A change in the core software requires a component modification or redesign (change of part number)
and, therefore, leads to a change in the aircraft configuration.
A change in the content data remains in the operational responsibility of the aircraft operator
(field-loadable software) and, therefore, does not lead to a change in the aircraft configuration.
6.4.2 Software development assurance
The item development assurance level (IDAL) required for the IFE system software should be determined
through the functional hazard assessment (FHA) that identifies the worst failure to which the software
may contribute. If the IDAL is equal to IDAL D or greater, AMC 20-115, latest revision, provides guidance
for the production of airborne systems and equipment software that performs its intended function with
a level of confidence in its safety that is compliant with airworthiness provisions. This is an acceptable
standard, and it should be taken into consideration for software in IFE systems, in particular those that
replace or interface with the required functions of the aircraft.
6.4.3 Airborne electronic hardware (AEH) development assurance
The functional development assurance levels (FDALs) identified through the FHA should be used, in
conjunction with the system architecture considerations, in order to determine the IDAL to be used for
the development of airborne electronic hardware (AEH), and to identify the rigour of the development
processes used.
For the development assurance of AEH of IFE systems that replace or interface with the required functions
of the aircraft, the provisions of AMC 20-152, latest revision, apply.
6.5 Other risks
For the risks associated with hazards that may be caused by the IFE system equipment due to the
operating environment of the aircraft, the standard environmental and operational test conditions and
test procedures of EUROCAE ED-14/RTCA DO-160 may be used in combination with FAA AC 21-16G.
The responsibility for selecting the appropriate environmental and operational test conditions and test
procedures lies with the installer. Section 6.5.1 below provides guidance on the selection of the test types.
Sections 6.5.2, 6.5.3 and 6.5.4 below address other associated risks.
6.5.1 Environmental qualification
If the IFE system equipment is not linked to any other aircraft systems and is only connected to a non-
essential power busbar, the following is recommended as a minimum list of environmental tests:
— temperature and altitude,
— temperature variation,
— operational shocks and crash safety,
— vibration,
— power input,
— voltage spikes, and
— emissions of radio frequency energy.

AMC 20-19
The installer is responsible for selecting the appropriate test conditions and for agreeing them with EASA.
The assessment of the installation may prove that some of the above test types are unnecessary or,
contrarily, that additional tests should be performed.
6.5.2 Touch temperature
In addition to CS 25.1360(b), the following should be considered: any hot surfaces of IFE system
components that are accessible to the crew or passengers should not be exposed if inadvertent contact
with those surfaces may pose a hazard.
The definition of MIL-STD-1472G ‘HUMAN ENGINEERING’ applies:
Equipment which, in normal operation, exposes personnel to surface temperatures greater than:
— For momentary contact: 60°C for metal, 68°C for glass, 85°C for plastic or wood;
— For prolonged contact: 49°C for metal, 59°C for glass, 69°C for plastic or wood;
or less than 0°C should be appropriately guarded.
6.5.3 Fluid exposure
If the equipment is mounted in a position where exposure to fluid is possible, for example on or under a
passenger seat, or where catering operations take place or liquid cleaning agents are used regularly, it
should be established that fluid spillage does not render the equipment hazardous. Where possible,
installations in areas susceptible to moisture should be avoided. Otherwise, consideration should be given
to minimise the hazard of liquid ingress, e.g. the inclusion of drip loops in wiring harnesses and the
installation of drip trays.
If the approach described above is followed, the fluid susceptibility test may be disregarded.
6.5.4 Rapid decompression and high-altitude operation
The installer should ensure that no arcing that causes a fire risk or unacceptable levels of interference will
occur in the equipment when the equipment is subjected to an atmospheric pressure that corresponds to
the maximum operating altitude of the aircraft. Alternatively, means should be provided to automatically
disconnect the electrical supply to the equipment when the cabin pressure reduces to a level below which
the safe operation of the equipment is not ensured (e.g. rapid decompression). The guidance of RTCA DO-
313 in this area may also be followed.
This section should be followed in addition to the test conditions of Section 6.5.1.
6.5.5 Explosion, fire, fumes and smoke
(a) The installer should pay particular attention to the quality and design of components such as
transformers, motors and composite connectors in order to minimise the risk of them overheating.
The design of the mounting provisions for IFE system components installed in the passenger cabin
(e.g. passenger seats, closet/cabin partition walls, overhead compartments, etc.) should fully reflect
the cooling provisions for the equipment, including heat sinking, ventilation, proximity to other
sources of heat, etc.
(b) All materials should meet the appropriate flammability provisions. Inadvertent blockage (e.g. by
passengers’ coats, luggage or litter) of any cooling vents should be prevented either by the design
or by operational procedures. Appropriate protection against overheating should be part of the
design of such in-seat systems.

AMC 20-19
(c) For the installation of IFE system components in racks located in the equipment bay that are not
accessible in flight, the installer should address the potential hazard to other essential or critical
systems/equipment located in the equipment bay, in case of an IFE system malfunction. The
installer should substantiate that the worst-case scenario of a possible malfunction of the IFE
system does not affect the components located in the equipment bay that are necessary for safe
flight and landing. This demonstration should account for the risks of:
— overheating,
— smoke release,
— electrical failure, and
— fire propagation.
For large aeroplanes, for example, the following is considered an acceptable means of compliance
in that respect: a hazard analysis to demonstrate that none of the potential ignition risks that
originate from IFE system malfunctions pose a risk of a sustained fire in any area where IFE system
components are located; this demonstration should account for:
— the fire containment properties of the equipment,
— the non-fire-propagating properties of the adjacent materials, and
— the detectability of fire and smoke.
(d) The installer should consider protecting IFE system components that are located in the cabin to
ensure that fault conditions will not result in the failure of components within a unit that may
generate smoke or fumes (e.g. if using tantalum capacitors). In addition, power supplies should
have current-limiting output protection at a suitable level (e.g. in-seat equipment). The IFE system
installation should comply with the applicable fire and smoke provisions of CS 25.831(c), CS
25.853(a), CS 25.863 and CS 25.869(a).
(e) Procedures should be established to terminate the operation of the IFE system at any time, in case
of smoke/fire/explosion. The crew should maintain overall control over the IFE system. If control
over the IFE system is possible via cabin controls only, appropriate procedures should address flight
crew compartment–cabin coordination.
The guidance of RTCA DO-313 in this area may also be followed.
6.6 Commercial off-the-shelf (COTS) equipment
This section provides guidance for the cases in which the installer uses COTS equipment as part of an IFE
system modification.
In principle, the installation of COTS equipment, as for all other IFE system equipment, should follow the
guidance provided in this document. It is, nevertheless, recognised that COTS equipment is supplied from
a market whose industry standards differ from the aviation ones. As a consequence, it may be difficult to
follow some of the guidance of this document.
The main impediments are the following:
— traceability and configuration control; and
— it is burdensome to perform most of the testing in accordance with the state-of-the-art aviation
standards (e.g. EUROCAE ED-14/RTCA DO-160).

AMC 20-19
In certain cases, the installer may directly follow the guidance provided in this document by using specific
design features/adaptations and mitigations in terms of design or operational instructions.
The steps described below compose a road map that the installer may follow to apply for the approval of
COTS equipment as part of an IFE system:
— The installer should perform a safety risk assessment of the potential hazards associated with the
installation of the COTS equipment, either during normal operation of the equipment or in case of
its failure.
— Based on the identified hazards, some evidence of environmental qualification for the equipment
may be required. This could be achieved either by testing or by providing alternative laboratory
standards to which the equipment has been tested, or industry standards to which the equipment
has been certified. The acceptability of these standards should be agreed with EASA.
— A design solution may be developed in some cases to provide means of compliance that are
alternatives to testing, e.g.:
— hosting of the COTS component in a ‘shelter case’ (an air-tight-sealed housing) with electrical
isolation of all the needed interfaces; or
— a declaration of ‘loose equipment’ that is temporarily brought on board and is permanently
accessible and visible by the crew.
— It should be ensured that the design specifications of the COTS equipment manufacturer are
followed (in terms of the operating environmental conditions, cooling, etc.).
— Configuration control: quality control criteria should be provided for those aspects of the COTS
equipment whose malfunctions may create hazards. If detailed design data is not available for such
aspects, the applicant should propose a process by which the configuration control of the design is
maintained and should ensure that any changes in the design or any non-compliance introduced
during manufacturing are identified. Critical characteristics of COTS equipment may include power,
dimensions, weight, electrical power, software and hardware parts, material flammability
behaviour, etc. This should also encompass subsequent changes to those parts.
The above points should help the installer in the certification of the COTS equipment. RTCA DO-313
Appendix D follows a similar approach and is considered to be an acceptable alternative.
6.7 Approach for General Aviation (GA) aircraft
This section provides guidance for the installation of IFE system equipment in GA aircraft.
The installer may follow the approach described in Sections 6.1 to 6.6, or follow the approach described
below:
— Perform an assessment of the potential hazards associated with the installation of the IFE system
equipment.
— Identify the list of hazards and possible safety issues created through either normal operation of
the IFE system equipment or its failure.
— The hazards and issues described in Section 6 of this AMC may be used as a reference, but the
applicant is not expected to demonstrate the same level of compliance as that required for large
aircraft. Some evidence of environmental qualification (and/or testing) may be needed, but it is

AMC 20-19
expected that in many cases, alternative compliance solutions may be provided. Some examples
are the following:
— specific-installation solutions or the use of mitigations (via limitations and/or placards) may
provide an adequate level of safety and circumvent the need for environmental testing; and
— industry and/or laboratory standards may provide an acceptable alternative.
The acceptability of the above should be agreed with EASA.
— It should be ensured that the design specifications of the IFE system equipment manufacturer are
followed (in terms of the operating environmental conditions, cooling, etc.).
— Configuration control: the configuration of the IFE system equipment should be identified, at least
for those design features whose malfunctions may create hazards.
It is worth mentioning that in many cases, the IFE system equipment installed in GA aircraft is COTS
equipment, thus the described approach largely reflects the approach to COTS equipment in Section 6.6
above.
7 DOCUMENTATION
This section provides guidance on the documentation that should be developed for IFE system
installations.
7.1 Certification documentation
The certification documentation may consist of but it is not limited to:
— equipment specifications,
— the system description,
— analysis reports,
— test reports, and
— a DDP.
It should include references to the standards that are met.
The installer should demonstrate that they have taken proper account of the equipment manufacturer’s
DDP and installation instructions. This demonstration may, in addition, involve the examination and
testing of the equipment. Point 21.A.608 (Subpart O of Annex I (Part 21) to Regulation (EU) No 748/2012)
and AMC 21.A.608 provide guidance on the drafting and formatting of the DDP.
Appropriate documentation should be provided to define the designer’s responsibilities for equipment
installed in non-IFE system components of the cabin (e.g. IFE system equipment installed in seats or
galleys, or in-seat wiring harnesses). A DDP should be provided to confirm that the installation of the IFE
system equipment does not invalidate the approvals of existing equipment (e.g. seat ETSOs, or the
certification of the galley).
Wire routing should be specified in detail to minimise the variability in manufacture, installation and
maintenance in order to avoid the risk of wire chafing and damage.

AMC 20-19
7.2 Operations and training manuals

The design and installation of the IFE system should minimise its impact on the operational procedures.
However, since flight or cabin crew procedures should comply with the applicable airworthiness
provisions, these procedures should be included in the corresponding manufacturer’s documentation to
be provided to operators and, if appropriate, in the AFM.
7.3 Instructions for Continued Airworthiness (ICA)
For IFE system installations on board an aircraft, the installer should draft appropriate ICA and submit
them to EASA. The installer should accomplish this task not only at the aircraft level, but also at the
equipment level.
7.3.1 Equipment level
At the equipment level, the manufacturer should provide the installer with the necessary information for
the safe operation and maintenance of the component. In particular, it should be highlighted whether a
component requires scheduled maintenance or contains life-limited parts or has any other limitation that
affects its continued airworthiness.
Suitable means of providing ICA information at equipment level are the following (examples only):
— operator’s guides,
— CMMs,
— illustrated parts catalogues, or
— dedicated ICA manuals.
The documents that contain the ICA for the component/equipment should be referenced in the
corresponding DDP and cross-referenced in the documentation at the aircraft level.
7.3.2 Aircraft level
At the aircraft level, CS 25.1529, CS 25.1729 (or an equivalent SC if contained in the certification basis)
and Appendix H of CS-25, as applicable to the installation under consideration, determine the format and
the minimum content of the ICA. The ICA for an IFE system may include the following:
— system descriptions and operating instructions such as (non-exhaustive list):
— AFM supplements,
— supplements to the master minimum equipment list (MMEL),
— supplements to the flight crew operations manual (FCOM), and
— supplements to the cabin crew operations manual (CCOM);
— maintenance instructions (including information on testing, inspections, troubleshooting, servicing,
the replacement of parts, lifetime limitations, tooling and software loading) via supplements to the
following (non-exhaustive list):
— the aircraft maintenance manual (AMM),
— the wiring manual,
— the illustrated parts catalogue,

AMC 20-19
— the maintenance planning document, and

— the service manual.
The amount and content of the necessary ICA may vary depending on the kind of installation.
7.3.3 Scheduled maintenance tasks
The installer should draft the ICA by following the method applied during the certification process of the
aircraft, including the development of scheduled maintenance tasks. However, some of these methods
may not properly address the specific operational and technical conditions of the IFE system installations:
— in-service occurrences have shown that failures in or damage to the IFE system installation may
become a potential source of ignition and heat, creating a smoke hazard and/or a fire hazard;
— particular attention should be given to in-seat equipment and wiring that is vulnerable to damage
induced by passengers, servicing personnel, crew, changes to the cabin configuration or
maintenance actions, which therefore may become potential sources of an electrical shock or other
risks due to degraded or damaged electrical insulation; and
— contamination by dust, debris or spilled liquids in the cabin may cause overheating and a risk of
smoke or fire.
These kinds of potential causes of failure, especially if the failure or damage is not easily detectable by the
crew or the maintenance personnel while performing their normal duties, should also be considered when
defining the scheduled maintenance tasks for IFE system installations.
The scheduled maintenance of IFE system installations may include but is not limited to the following
tasks:
— functional checks of latent systems (e.g. the power shutdown function and/or IFE-systemspecific
smoke detection function);
— inspections (e.g. of the condition of system cabling and/or seat-mounted components; the correct
position of physical protection, such as insulation, ducting, covers and/or drip trays);
— discarding/replacement of components (e.g. air filters and/or IFE system batteries); and
— restoration tasks (e.g. the cleaning of cooling vents or filters, the removal of dust and debris).
8 OPERATIONAL PROCEDURES
The regulatory requirements related to air operations are specified in Regulation (EU) No 965/2012 (see
also the related AMC and GM). The operator should ensure that both the flight crew and the cabin crew
are fully familiar with the operation of the IFE system, and that passengers are provided with appropriate
information, including restrictions on the use of the IFE systems in normal, abnormal and emergency
conditions.
[Amdt 20/19]

AMC 20-20A
AMC 20-20A
AMC 20-20A Continuing structural integrity programme

1. PURPOSE
(a) This acceptable means of compliance (AMC) provides guidance to type certificate holders
(TCHs), supplemental type certificate holders (STCHs), repair approval holders, maintenance
organisations, operators and competent authorities for developing continuing structural
integrity programmes to ensure safe operation of ageing aircraft throughout their
operational lives.
This AMC is primarily aimed at large aeroplanes; however, this material is also applicable to
other aircraft types for operators and TCHs wishing to develop robust continuing structural
integrity programmes.
(b) It is particularly important for the TCHs of ageing aircraft to ensure that their continuing
structural integrity programmes remain valid throughout the operational life of the aircraft.
(c) The means of compliance described in this document provides guidance to supplement the
engineering and operational judgement that must form the basis of any compliance findings
relative to continuing structural integrity programmes.
(d) Like all acceptable means of compliance material, this AMC is not in itself mandatory, and
does not constitute a requirement. It describes an acceptable means, but not the only means,
for showing compliance with the requirements. While these guidelines are not mandatory,
they are derived from extensive industry experience in determining compliance with the
relevant requirements.
(e) This AMC also supports compliance with the ageing structural integrity requirements in
Annex I (Part-26) to Regulation (EU) 2015/640, as introduced by Regulation (EU) 2020/1159
(ref. points 26.300 through 26.370 and the associated CS-26 paragraphs) including limits of
validity (LOVs), WFD evaluation, damage tolerance for repairs and modifications, and
processes for ensuring the continued validity of the continuing structural integrity
programme.
2. RELATED REGULATIONS AND DOCUMENTS
(a) Implementing Rules and Certification Specifications:
Point 21.A.61 Instructions for continued airworthiness
Point 21.A.120 Instructions for continued airworthiness
Points 26.300 through 26.334 applicable to DAHs
Point 21.A.433 Repair design
Point 26.370 Rules applicable to operators
Point M.A.302 Maintenance programme
CS 25.571 Damage tolerance and fatigue evaluation of structure

AMC 20-20A
CS 25.1529 Instructions for continued airworthiness

CS 26.300 through 26.370 Means of compliance for Part-26 ageing aeroplane structures
requirements
(b) EASA AMC and FAA Advisory Circulars
AMC 25.571 Damage tolerance and fatigue evaluation of structure
AC 91-81 Management Programs for Airplanes with Demonstrated Risk of
Catastrophic Failure Due to Fatigue, 29 April 2008, FAA
AC 91-56B Continuing Structural Integrity for Airplanes, 7 March 2008, FAA
AC 120-73 Damage Tolerance Assessment of Repairs to Pressurised Fuselages, FAA,
14 December 2000
AC 120-93 Damage Tolerance Inspections for Repairs and Alterations
AC 120-104 Establishing and Implementing Limit of Validity to Prevent Widespread
Fatigue Damage
AC 25.1529-1A Instructions for Continued Airworthiness of Structural Repairs on
Transport Airplanes, FAA, 20 November 2007
(c) Related documents
— ‘Recommendations for Regulatory Action to Prevent Widespread Fatigue Damage in
the Commercial Aeroplane Fleet’, Revision A, dated June 29, 1999 [A report of the
Airworthiness Assurance Working Group for the Aviation Rulemaking Advisory
Committee Transport Aircraft and Engine Issues].
— AAWG Final Report on Continued Airworthiness of Structural Repairs, Dec 1996.
— ATA report 51-93-01 structural maintenance programme guidelines for continuing
airworthiness, May 1993.
— AAWG Report on Structures Task Group Guidelines, Rev 1 June 1996.
— AAWG Report: Recommendations concerning ARAC taskings FR Doc 04-10816 Ref.:
Aging Airplane safety final rule. 14 CFR 121.370a and 129.16.
— Federal Aviation Administration 14 CFR Parts 26, 121, and 129 [Docket No FAA-2005-
21693; Amendment Nos 26–1, 121–337, 129–44] Damage Tolerance Data for Repairs
and Alterations Final Rule.
— Federal Aviation Administration 14 CFR Parts 25, 26, 121, and 129 [Docket No
FAA-2006-24281; Amendment Nos 25–132, 26–5, 121–351, 129–48] Aging Airplane
Program: Widespread Fatigue Damage Final Rule.
3. BACKGROUND
Service experience has shown there is a need to have continually updated knowledge on the
structural integrity of aircraft, especially as they become older, to ensure they continue to meet the
level of safety intended by the certification requirements. The continued structural integrity of
aircraft is of concern because factors such as fatigue cracking and corrosion are time-dependent,

AMC 20-20A
and our knowledge about them can best be assessed based on real-time operational experience
and the use of the most modern tools of analysis and testing.
In April 1988, a high-cycle transport aeroplane en-route from Hilo to Honolulu, Hawaii, suffered
major structural damage to its pressurised fuselage during flight. This accident was attributed in
part to the age of the aeroplane involved. The economic benefit of operating certain older
technology aeroplanes resulted in the operation of many such aeroplanes beyond their previously
expected retirement age. Because of the problems revealed by the accident in Hawaii and the
continued operation of older aircraft, both the competent authorities and industry generally agreed
that increased attention needed to be focused on the ageing fleet and on maintaining its continued
operational safety.
In June 1988, the FAA sponsored a conference on ageing aircraft. As a result of that conference, an
ageing aircraft task force was established in August 1988 as a sub-group of the FAA’s Research,
Engineering, and Development Advisory Committee, representing the interests of the aircraft
operators, aircraft manufacturers, regulatory authorities, and other aviation representatives. The
task force, then known as the Airworthiness Assurance Task Force (AATF), set forth five major
elements of a programme for keeping the ageing fleet safe. For each aeroplane model in the ageing
transport fleet, these elements consisted of the following:
(a) Select service bulletins describing modifications and inspections necessary to maintain
structural integrity;
(b) Develop inspection and prevention programmes to address corrosion;
(c) Develop generic structural maintenance programme guidelines for ageing aeroplanes;
(d) Review and update the supplemental structural inspection documents (SSIDs) which describe
inspection programmes to detect fatigue cracking; and
(e) Assess the damage tolerance of structural repairs.
Subsequent to these five major elements being identified, it was recognised that an additional
factor in the Aloha accident was widespread fatigue cracking. Regulatory and industry experts
agreed that, as the transport aircraft fleet continues to age, eventually widespread fatigue damage
(WFD) is inevitable. Structures Task Groups sponsored by the Task Force were assigned the task of
developing these elements into usable programmes. The Task Force was later re-established as the
AAWG of the ARAC. Although there was JAA membership and European operators and industry
representatives participated in the AAWG, recommendations for action focussed on FAA
operational rules which are not applicable in Europe. It was therefore decided to establish the
EAAWG on this subject to implement ageing aircraft activities in Europe, not only for the initial
‘AATF eleven’ aeroplanes, but also other old aircraft and more recently certified ones. EAAWG
recommendations followed, leading to the development of guidance material for TCHs and
operators, and proposals to develop Sub-part M of JAR OPS. The subsequent establishment of the
Agency and new EU regulations led to the current format of Part-M for continuing airworthiness,
the associated maintenance programme requirements and to the inclusion of ageing aircraft
structures programmes in AMC Part M (M.A.302). AMC 20-20 supported this process and set out
means by which TCHs and operators could develop and implement ageing aircraft structures
programmes.

AMC 20-20A
This AMC supports DAH and operator compliance with the requirements introduced by Commission
Implementing Regulation (EU) 2020/1159 on ageing aeroplane structures, amending Regulation
(EU) 2015/640 (Part-26), and the associated CS-26 specifications. The Regulation includes
requirements for specific DAHs to perform damage tolerance and other evaluations of existing
airframe structure, develop certain data and ICA if they have not already done so, and make it
available to operators. Furthermore, operators, in addition to implementing these new ICA as
envisaged under Part-M, are required by Part-26 to ensure that approved damage-tolerance-based
inspections are obtained and implemented on all repairs and modifications affecting the FCS on
aeroplanes certified for 30 passengers or more or for 7 500 lb or more payload.
Points 26.300 through 26.370 of Part-26 provide requirements for a complete retroactively
applicable continuing structural integrity programme for specific categories of large aeroplanes.
The principal means of compliance with those regulations may be found in CS-26, which, in turn,
refers to this AMC.
4. DEFINITIONS AND ACRONYMS
(a) For the purposes of this AMC, the following definitions apply:
— Airworthiness limitation section (ALS) means a section in the instructions for
continued airworthiness, as required by points 21.A.61, 21.A.107 and 21.A.120A of
Annex I (Part 21) to Regulation (EU) No 748/2012, which contains airworthiness
limitations that set out each mandatory replacement time, inspection interval and
related inspection procedure.
— Baseline structure refers to the structure that is designed under the type certificate
for that aeroplane model (that is, the ‘as delivered aeroplane model configuration’).
— Corrosion prevention and control programme (CPCP) is a document reflecting a
systematic approach to prevent and to control corrosion in an aeroplane’s primary
structure, consisting of basic corrosion tasks, including inspections, areas subject to
those tasks, defined corrosion levels and compliance times (implementation
thresholds and repeat intervals). A baseline CPCP is established by the type certificate
holder, which can be adapted by operators to create a CPCP in their maintenance
programme specific to their operations.
— Damage tolerance (DT) is the attribute of the structure that permits it to retain its
required residual strength without detrimental structural deformation for a period of
use after the structure has sustained a given level of fatigue, corrosion, and accidental
or discrete source damage.
— Design approval holder (DAH) is the holder of any design approval, including type
certificate, supplemental type certificate or earlier equivalent, or repair approval.
— Damage tolerance data is the combination of DTE documentation and DTI.
— Damage tolerance evaluation (DTE) is a process that leads to the determination of the
maintenance actions necessary to detect or preclude fatigue cracking that could
contribute to a catastrophic failure. When applied to repairs and changes, a DTE
includes the evaluation of the repair or change and the fatigue-critical structure
affected by the repair or change.

AMC 20-20A
— Damage tolerance inspection (DTI) is a documented inspection requirement or other

maintenance action developed by holders of design approvals or third parties as a
result of a damage tolerance evaluation. A DTI includes the areas to be inspected, the
inspection method, the inspection procedures (including the sequential inspection
steps and acceptance and rejection criteria), the inspection threshold and any
repetitive intervals associated with those inspections. DTIs may also specify
maintenance actions such as replacement, repair or modification.
— Design service goal (DSG) is the period of time (in flight cycles or flight hours, or both)
established at design and/or certification during which the aeroplane structure is
expected to be reasonably free from significant cracking.
— Existing design changes or repairs are changes and repairs which are to be approved
before the date of entry into force of this rule.
— Fatigue-critical alteration structure (FCAS) is equivalent to fatigue-critical modified
structure.
— Fatigue-critical baseline structure (FCBS) is the baseline structure of an aeroplane that
is classified by the type certificate holder as a fatigue-critical structure.
— Fatigue-critical modified structure (FCMS) means any fatigue-critical structure of an
aeroplane introduced or affected by a change to its type design and that is not already
listed as part of the fatigue-critical baseline structure.
— Fatigue-critical structure (FCS) is a structure of an aeroplane that is susceptible to
fatigue cracking that could lead to a catastrophic failure of the aircraft. For the
purposes of this AMC, FCS refers to the same class of structure that would need to be
assessed for compliance with JAR 25.571 Change 7 or 14CFR § 25.571(a) at
Amendment 25-45, or later. The term ‘FCS’ may refer to fatigue-critical baseline
structure, fatigue-critical modified structure, or both.
— Inspection start point (ISP) is the point in time when special inspections of the fleet
are initiated due to a specific probability of having an MSD/MED condition.
— Future design changes and repairs are changes and repairs which are to be approved
on or after the date of entry into force of this rule.
— Limit of validity (LOV) (of the engineering data that supports the structural
maintenance programme) means, in the context of the engineering data that supports
the structural maintenance programme, a period of time, stated as a number of total
accumulated flight cycles or flight hours or both, during which it is demonstrated that
widespread fatigue damage will not occur in the aeroplane.
— Multiple-element damage (MED) is a source of widespread fatigue damage
characterised by the simultaneous presence of fatigue cracks in similar adjacent
structural elements.
— Multiple-site damage (MSD) is a source of widespread fatigue damage characterised
by the simultaneous presence of fatigue cracks in the same structural element.
— Primary structure is structure that carries flight, ground, crash or pressurisation loads.

AMC 20-20A
— Published repair data are instructions for accomplishing repairs which are published
for general use in structural repair manuals and service bulletins (or equivalent types
of documents).
— Repair assessment guidelines (RAGs) provide a process to establish damage tolerance
inspections for repairs on the fuselage pressure boundary structure.
— Repair assessment programme (RAP) is a programme to incorporate
damage-tolerance-based inspections for repairs to the fuselage pressure boundary
structure (fuselage skin, door skin, and bulkhead webs) into the operator’s
maintenance and/or inspection programme.
— Repair evaluation guidelines (REGs) are established by the type certificate holder and
guide operators to establish damage tolerance inspections for repairs that affect
fatigue-critical structure to ensure the continued structural integrity of all relevant
repairs.
— Structural modification point (SMP) is the point in time when a structural area must
be modified to preclude WFD.
— Widespread fatigue damage (WFD) means the simultaneous presence of cracks at
multiple locations in the structure of an aeroplane that are of such size and number
that the structure will no longer meet the fail-safe strength or residual strength used
for the certification of that structure.
(b) The following list defines the acronyms that are used throughout this AMC:
AAWG Airworthiness Assurance Working Group
AC advisory circular
AD airworthiness directive
ALS airworthiness limitations section
ARAC Aviation Rulemaking Advisory Committee
BZI baseline zonal inspection
CAW continuing airworthiness
CPCP corrosion prevention and control programme
CS certification specification
DAH design approval holder
DSD discrete source damage
DSG design service goal
DT damage tolerance
DTE damage tolerance evaluation
DTI damage tolerance inspection
EAAWG European Ageing Aircraft Working Group
EASA European Union Aviation Safety Agency
ESG extended service goal
FAA Federal Aviation Administration
FAR Federal Aviation Regulation

AMC 20-20A
FCBS fatigue-critical baseline structure

FCS fatigue-critical structure
ICA instructions for continued airworthiness
ISP inspection start point
JAA Joint Aviation Authorities
JAR joint aviation regulation
LOV limit of validity
MED multiple-element damage
MRB Maintenance Review Board
MSD multiple-site damage
MTOM maximum take-off mass
MSG Maintenance Steering Group
NAA national aviation authority
NDI non-destructive inspection
NTSB National Transportation Safety Board
PSE principal structural element
RAP repairs assessment programme
REGs repair evaluation guidelines
SB service bulletin
SMP structural modification point
SRM structural repair manual
SSID supplemental structural inspection document
SSIP supplemental structural inspection programme
STG structural task group
STCH supplemental type certificate holder
TCH type certificate holder
WFD widespread fatigue damage
5. CONTINUING STRUCTURAL INTEGRITY PROGRAMME AND WAY OF WORKING

(a) General
The programmes and processes described in this and the subsequent paragraphs of this AMC
are all part of an acceptable process to provide a continuing structural integrity programme
that precludes unsafe levels of cracking.
DAHs and operators are expected to work together to ensure that their continuing structural
integrity programmes remain valid.
Points 26.300 through 26.309 provide retroactive requirements for TCHs to establish a
continuing structural integrity programme for the type design of large aeroplanes.
Aeroplanes certified in compliance with CS-25 Amendment 19 or later have acceptable
structural maintenance programmes. Nonetheless, in both cases, there is a need to ensure
that the continuing structural integrity programme remains valid throughout the operational
life of the aeroplane.
(b) Maintaining the validity of the continuing structural integrity programme

AMC 20-20A
Point 26.305 requires TCHs to establish a process that ensures that the continuing structural
integrity programme remains valid throughout the operational life of the aeroplane,
considering service experience and current operations. CS 26.305 (a) and (c) describe the
core content of the process required as the means of compliance with point 26.305, and
further details are provided in Appendix 5 to this AMC. The intent is for the TCHs of large
transport aeroplanes to monitor the continued validity of the assumptions upon which the
maintenance programme is based, and to ensure that unsafe levels of fatigue cracking or
other structural deterioration will be precluded in service. It should be noted that this
requirement applies to all structure whose failure could contribute to a catastrophic failure,
and it is not limited to metallic structures or fatigue cracking, but should also encompass
composite and hybrid structures.
Typically, large aeroplanes are utilised in well-understood commercial transport scenarios for
which conservative or more rational and well-bounded assumptions can be made at the time
of certification or when the continuing structural integrity programme is developed. Obvious
changes to usage should be addressed for their impact on fatigue and damage tolerance
when they occur. In particular, aeroplanes used for conducting surveys, VIP operations,
firefighting or other special operations should be considered on a case-by-case basis.
Furthermore, as part of this process, the assumptions made for fatigue, accidental and
environmental damage scenarios during certification should, on a regular basis, be validated
against service experience to see whether they remain applicable.
The monitoring of operational usage is best achieved in cooperation with the operators,
combined with fleet leader sampling inspection programmes. Where data does not
correspond to the original certification assumptions, its potential impact on all ageing
aeroplane structural programmes and CAW in general must be considered. The degree of
impact that a change of usage may have is dependent on the level of conservatism in the
selection of the original usage spectrum. It is recommended to review at regular intervals the
operational usage data for which a change from the original assumptions would have an
impact on the validity of the content of the programme. If this is not done, it might be
necessary to investigate the operational usage on each occasion of a service finding in which
operational usage could be a contributing factor.
(c) Way of working
All the ageing aircraft programme elements discussed in this AMC benefit from cooperation
between operators and TCHs. The use of structural task groups (STGs) has historically proved
very successful in this regard, and is recommended.
On the initiative of the TCH and EASA, an STG may be formed for each aircraft model for
which it is decided to put in place an ageing aircraft programme. The STG shall consist of the
TCH, selected operator members and EASA representative(s). The objective of the STG is to
complete all tasks covered in this AMC in relation to their respective model types, including
the following:
— Develop model specific programmes,
— Define programme implementation,
— Conduct recurrent programme reviews as necessary.

AMC 20-20A
It is recognised that it might not always be possible to form or to maintain an STG, due to a
potential lack of resources within the operators or TCH. Furthermore, for some mature
products, the programmes and their implementation may be sufficiently mature to
determine that an STG is not necessary, e.g. when large numbers of aeroplanes have already
reached their expected retirement age and none are going to be operated beyond that point.
This point could be determined by the LOV, provided that it is not extended. In any case, the
responsibilities for ensuring compliance with the applicable requirements are outlined in
subparagraph (d) of this paragraph.
An acceptable way of working for STGs is described in the ‘Report on Structures Task Group
Guidelines’ that was established by the AAWG with the additional clarifications provided in
the following subparagraphs.
(1) Meeting scheduling
It is the responsibility of the TCH to schedule STG meetings.
(2) Reporting
The STG may make recommendations for actions via the TCH to EASA. Additionally, the
STG should give periodic reports (for information only) to EASA as appropriate with the
objective of maintaining a consistent approach.
(3) Recommendations and decision-making
The decision-making process described in the AAWG Report on Structures Task Group
Guidelines paragraph 7 leads to recommendations for mandatory action from the TCH
to EASA. In addition, it should be noted that EASA is entitled to mandate safety
measures related to ageing aircraft structures, in addition to those recommended by
the STG, if it finds it necessary.
(d) Responsibilities
(1) The TCH is responsible for developing the ageing aircraft structures programme for
each aircraft type, detailing the actions necessary to maintain airworthiness. Other
DAHs should develop programmes or actions appropriate to the modification/repair
for which they hold approval, unless addressed by the TCH. All the continuing
structural integrity programmes, including associated maintenance actions and DTIs,
are changes to the ICA and, therefore, are subject to the Part 21 requirements for their
promulgation. All DAHs will be responsible for monitoring the effectiveness of their
specific programme, and for amending the programme as necessary.
(2) The operator is responsible for incorporating approved DAH actions necessary to
maintain airworthiness into its aircraft-specific maintenance programmes, in
accordance with Part-M (point M.A.302) and point 26.370.
(3) The competent authority of the State of registry, or the continuing airworthiness
management organisation (CAMO) when it holds the approval privilege, is responsible
for the approval of the aircraft maintenance programme.
(4) EASA will approve elements of ageing aircraft structures programmes developed by
DAHs and may issue ADs to support implementation, where necessary, e.g. to
implement applicable inspections and maintenance actions necessary to support the

AMC 20-20A
LOV. However, it is intended that Part-M and, where necessary, Part-26 requirements
will be the usual means of implementation of ageing aircraft programmes in European
registered aircraft. EASA, in conjunction with the DAH, will monitor the overall
effectiveness of ageing aircraft structures programmes.
(e) Continued airworthiness and management of cracks and other damage findings in service
Point 26.305 of Part-26 requires a process to be established that ensures that the continuing
structural integrity programme remains valid throughout the operational life of the
aeroplane, considering service experience and current operations. One of the elements of
this process is the review of new occurrences, existing damage-tolerance-based inspections
and service bulletins (SBs), which is established in order to determine the need for mandatory
changes in cases where inspections alone would not be reliable enough, or to ensure that
unsafe levels of cracking are precluded.
For a new type design, the regulations include the damage tolerance approach for preventing
catastrophic failures due to fatigue. The damage tolerance approach depends on directed
inspection programmes to detect fatigue cracks before they reach their critical sizes.
If an inspection finds cracks in a damage-tolerant fleet, the approval holder, together with
EASA, may determine that a demonstrated risk exists, and require additional airworthiness
actions, including more rigorous inspection requirements or fleet-wide replacement or
modification of the structure.
Cracking is a continued airworthiness issue because cracking usually reduces the strength of
the structure to less than its design ultimate strength level. Service history has shown that
the reliability of directed inspections is never sufficient to detect all cracks. As the number of
crack reports increases, the likelihood that a number of aeroplanes in the fleet have
undetected fatigue cracks also increases. Therefore, for areas where fatigue cracks are
reported, the likelihood increases that a number of aeroplanes in the fleet will have strengths
less than the design ultimate strength level. At some time during operation of the fleet, the
likelihood that the strength of any given structure in a fleet is less than the design ultimate
strength level may become unacceptably high. The loss of design ultimate strength capability
should be a rare event, and EASA rarely knowingly allows the strength of aeroplanes to drop
below the design ultimate strength level with any significant frequency.
Approval holders can use the damage tolerance approach to address an unsafe condition.
However, it should be understood that damage-tolerance-based inspections may not provide
a permanent solution, as explained above, and in cases where cracks are expected to
continue to develop in the fleet, the approval holder should propose, and EASA may require,
the fleet-wide replacement, modification, or removal from service of the structure.
Other than fatigue crack findings, significant environmental and accidental damage findings
should also be taken into account. Initial and critical damage scenarios assumed for
certification should be compared to those being reported and where there are differences,
the potential airworthiness impact should be evaluated. Differences may include the pattern
and extent of cracking, corrosion or accidental damage, the time at which it was discovered
and the rate of growth.
More guidance on the continued airworthiness procedures for airframe structures to ensure
the validity of the continuing structural integrity programme is provided in Appendix 5.

AMC 20-20A
6. DAMAGE-TOLERANCE-BASED INSPECTION PROGRAMME

Aeroplanes certified to JAR 25 Change 10 or later or 14 CFR 25 Amdt 54 or later are provided with
an airworthiness limitations section (ALS) that includes damage-tolerance-based inspections. Many
aeroplanes certified to earlier amendments have also been provided with a DT-based ALS.
Point 26.302 of Part-26 requires TCHs for certain large transport aeroplanes to perform a damage
tolerance evaluation (DTE) and establish the associated inspections and other procedures that
ensure freedom from catastrophic failures due to fatigue throughout the operational life of the
aeroplane. An SSID or ALS developed according to the guidance of this AMC or an SSID mandated
under a current EASA AD will satisfy the requirements of point 26.302 of Part-26. In the absence of
an approved damage-tolerance-based structural maintenance inspection programme, the TCH, in
conjunction with operators, is expected to initiate the development of an SSIP for each aeroplane
model. The role of the operator is principally to comment on the practicality of the inspections and
any other procedures defined by the TCH and to implement them effectively.
The SSID or ALS should include inspection threshold, repeat interval, inspection methods and
procedures. The applicable modification status, associated life limitation and types of operations
for which the SSID is valid should also be identified and stated.
For aeroplanes for which a DTE is necessary in accordance with CS 25.571 or point 26.302 of Part-
26, all inspections and other procedures must be provided that are anticipated to be necessary
throughout the operational life of the aeroplane to prevent catastrophic failures due to fatigue. For
an aircraft maintenance programme subject to an LOV under point 26.303 of Part-26 or CS 25.571,
the DTE need only provide the inspections and other procedures necessary to prevent catastrophic
failures up to the LOV. For other aeroplanes, it is recommended that the ALS includes an LOV or
similar limitation on the applicability of the maintenance programme, otherwise the programme
should be shown to address the maximum potential usage of the aeroplane based on experience
with similar products or a conservative assumption. For an SSIP newly developed to meet point
26.302 of Part-26, the guidance of this AMC applies.
In addition, the inspection access, the type of damage being considered, likely damage sites and
details of the resulting fatigue cracking scenario should be included as necessary to support the
prescribed inspections.
As a result of a periodic review, the TCH should revise the SSID whenever additional information
shows a need. The original SSID will normally be based on predictions or assumptions (from
analyses, tests, and/or service experience) of failure modes, time to initial damage, frequency of
damage, typically detectable damage, and the damage growth period. Consequently, a change in
these factors sufficient to justify a revision would have to be substantiated by test data or additional
service information. Any revision to SSID criteria and the basis for these revisions should be
submitted to EASA for review and approval of both engineering and maintenance aspects.
7. DAMAGE TOLERANCE EVALUATION OF REPAIRS AND MODIFICATIONS
Early fatigue or fail-safe requirements (pre-JAR 25.571 Change 7 and 14 CFR §25.571 Amdt 45) did
not necessarily provide for timely inspection of critical structure so that damaged or failed
components could be dependably identified and repaired or replaced before a hazardous condition
developed. This applies to modifications and repairs as well as baseline structure. Furthermore, it
is known that application of later fatigue and damage tolerance requirements to repairs was not
always fully implemented according to the relevant certification bases.

AMC 20-20A
As such, repairs and modifications that have not been subject to a DTE and provided with any
necessary DTI may have an adverse effect on the FCS and the safety level achieved by the damage-
tolerance-based inspection programme of the baseline structure.
As a result of the above considerations, Part-26 requirements for existing repairs and changes to
ageing aeroplane structure were introduced to include specific requirements applicable to certain
DAHs and operators of large aeroplanes. Some further details and background are provided here,
and Appendix 3 provides additional information on means of compliance with the Part-26
requirements and the associated CS-26 specifications for existing repairs and modifications.
For large aeroplanes with 30 pax or more or having a payload of 3 402 kg (7 500 lb) or more, TCHs
must:
(a) identify and list the FCS according to points 26.306 and 26.307 of Part-26 for FCBS and FCMS
respectively and make the list available to assist operators and STCHs needing to identify
changes that may require DTE and DTI;
(b) perform DTE of changes according to point 26.307 of Part-26 and submit the damage
tolerance data for approval to EASA; and
(c) review published repair data and perform DTE in accordance with point 26.308 of Part-26.
DTIs are ICA and need to be made available to operators according to Part 21. Published repair data
includes structural repair manuals (SRMs) and SBs. The data in published repair documentation that
needs to be updated includes non-reinforcing repairs such as blending out of scratches, etc. that
could be implemented by operators in the future.
For large aeroplanes with 30 pax or more or having a payload of 3 402 kg (7 500 lb) or more, STCHs
must:
(a) identify changes that affect FCBSs and list FCMSs according to point 26.332 of Part-26, and
make lists of FCMSs available to assist operators and STCHs needing to identify changes that
may require DTE and DTI; and
(b) perform DTE of changes and published repairs to those changes according to points 26.333
or 26.334 of Part-26 for changes approved on or after 1 September 2003 or before that date
respectively, and submit the damage tolerance data to EASA for approval.
CS-26 specifies means of compliance for the DTE itself, and Appendix 3 to this AMC provides means
of compliance for the identification of the FCS and implementation of DTI.
The repair evaluation guidelines (REGs) developed by the TCH are intended to assist the operator
in addressing the adverse effects of existing reinforcing repairs on the FCS, including the affected
adjacent structure, based on damage tolerance principles, consistent with the safety level provided
by the SSID or ALS as applied to the baseline structure. In this context, adjacent structure means
structure whose fatigue and damage tolerance behaviour and DTE are affected by the reinforcing
repair. To achieve this, the REGs should be developed by the TCH and implemented by the operator
to ensure that an evaluation is performed of all existing reinforcing repairs to structure that is
susceptible to fatigue cracking and could contribute to a catastrophic failure.
Even the best maintained aircraft will accumulate structural repairs when being operated. The
AAWG conducted two separate surveys of repairs placed on aircraft to collect data. The evaluation
of these surveys revealed that 90 % of all repairs found were on the fuselage, hence these are a

AMC 20-20A
priority and repair assessment programmes (RAPs) have already been developed for the fuselage
pressure shell of many large transport aeroplanes not originally certified to damage tolerance
requirements. 40 % of the repairs were classified as adequate and 60 % of the repairs required
consideration for possible additional supplemental inspection during service. Nonetheless,
following further studies by the AAWG working groups, it was agreed that repairs to all structure
susceptible to fatigue and whose failure could contribute to catastrophic failure should be
considered. (Ref. AAWG Report: Recommendations concerning ARAC taskings FR Doc 04-10816
Ref. Aging Airplane safety final rule. 14 CFR 121.370a and 129.16.)
As aircraft operate into high cycles and high times the ageing repaired structure needs the same
considerations as the original structure in respect of damage tolerance. Existing repairs may not
have been assessed for damage tolerance and appropriate inspections or other actions
implemented. Repairs are to be assessed, replaced if necessary or repeat inspections determined
and carried out as supplemental inspections or within the baseline zonal inspection programme. A
damage-tolerance-based inspection programme for repairs will be required to detect damage
which may develop in a repaired area before that damage degrades the load carrying capability of
the structure to less than the levels required by the applicable airworthiness standards.
Point 26.309 of Part-26 requires TCHs of aeroplanes with TCs issued prior to 11 January 2008, with
30 pax or more or having a payload of 3 402 kg (7 500 lb) or more, to develop REGs and submit
them to EASA for approval.
The REGs should provide data for operators to address existing reinforcing repairs to all structure
that is susceptible to fatigue cracking and could contribute to a catastrophic failure. The REGs may
refer to the RAP, other existing approved data such as the SRMs and SBs or provide specific means
for obtaining data for individual repairs.
This fatigue and damage tolerance evaluation of repairs will establish an appropriate inspection
programme or a replacement schedule if the necessary inspection programme is too demanding or
not possible. Details of the means by which the REGs and the maintenance programme may be
developed are incorporated in Appendix 3 to this AMC.
Point 26.370 of Part-26 directs the operator and organisations responsible for the continuing
airworthiness of certain large aeroplanes to revise their maintenance programmes to address the
potential adverse effects of repairs and modifications on fatigue-critical structures. The basis for
achieving this for existing repairs is the implementation of the REGs supplied by the TCH and, for
modifications, the data supplied by the original DAH or a third party contracted by the operator. All
repairs and changes that affect the FCS and that are approved and implemented after the applicable
date of point 26.370 of Part-26 should be subject to DTE and provided with inspections and other
procedures, as necessary. Further guidance on obtaining DTIs and the implementation of the ICA is
provided in Appendix 3 to this AMC.
8. LIMIT OF VALIDITY OF THE MAINTENANCE PROGRAMME AND WIDESPREAD FATIGUE DAMAGE
EVALUATION
(a) Initial WFD evaluation and LOV
All fatigue and damage tolerance evaluations are finite in scope and also therefore in their
long-term ability to ensure continued airworthiness. The maintenance requirements that
evolve from these evaluations have a finite period of validity defined by the extent of testing,
analysis and service experience that make up the evaluation and the degree of associated

AMC 20-20A
uncertainties. The limit of validity (LOV) of the engineering data that supports the structural
maintenance programme is defined as being not more than the period of time, stated as a
number of total accumulated flight cycles or flight hours or both, for which it has been
demonstrated that widespread fatigue damage (WFD) is unlikely to occur in the aeroplane
structure. To support the establishment of the LOV, the DAH will demonstrate by test
evidence, analysis, and, if available, service experience and teardown inspection results of
high-time aeroplanes, that WFD is unlikely to occur in that aeroplane up to the LOV. The LOV,
in effect, is the operational life of the aeroplane consistent with the evaluations
accomplished and the maintenance actions established to prevent WFD.
Note: Although the LOV is established based on WFD considerations, it is intended that all
maintenance actions required to address fatigue, corrosion, and accidental damage up
to the LOV should be identified in the structural-maintenance programme. All the
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, should be
included in the ALS of the instructions for continued airworthiness (ICA), as required
by CS 25.1529, along with the LOV.
In some cases, the ALS may already contain an LOV which is approved in accordance
with a regulation of another authority. There may also be other potentially more
restrictive limitations on the validity of the maintenance programme. For these cases,
when the TCH needs to publish the LOV as required by point 26.303 of Part-26, this
LOV and its relationship with the existing or superseded limitation should be clearly
described in order that no operator will exceed the most restrictive applicable limit on
the general validity of the maintenance programme.
The likelihood of the occurrence of fatigue damage in an aircraft’s structure increases with
aircraft usage. The design process generally establishes a design service goal (DSG) in terms
of flight cycles/hours for the airframe. It was generally expected when fatigue and fail-safe
rules were first developed that any cracking that occurs on an aircraft operated up to the
DSG would occur in isolation (i.e. local cracking), originating from a single source, such as a
random manufacturing flaw (e.g. a mis-drilled fastener hole) or a localised design detail. It
was considered unlikely that cracks from manufacturing flaws or localised design issues
would interact strongly as they grow. The SSIPs described in paragraph 6 of and Appendix 1
to this AMC were intended to find all forms of fatigue damage before they become critical.
Nonetheless, it has become apparent that as aircraft have approached and exceeded their
DSG, only some SSIPs have correctly addressed WFD as described below.
It should be noted that the majority of aeroplanes in the European fleet are now
damage-tolerance-certified, and that JAR and CS damage tolerance requirements have
always required the consideration of all forms of fatigue damage, including damage that
would now be described as multiple-site damage (MSD) or multiple-element damage (MED).
JAR 25.571 at Change 7 stated:
‘(b) Damage tolerance (fail-safe) evaluation.
The evaluation must include a determination of the probable locations and modes of damage
due to fatigue, corrosion, or accidental damage. The determination must be by analysis
supported by test evidence and (if available) service experience. Damage at multiple sites due

AMC 20-20A
to prior fatigue exposure must be included where the design is such that this type of damage
can be expected to occur.’
AMC 25.571(a), (b) and (e) stated in Section 2.1.1.:
‘d. Provisions to limit the probability of concurrent multiple damage, particularly after long
service, which could conceivably contribute to a common fracture path. The achievement of
this would be facilitated by ensuring sufficient life to crack initiation.
Examples of such multiple damage are:
i. A number of small cracks which might coalesce to form a single long crack;
ii. Failures, or partial failures, in adjacent areas, due to the redistribution of loading
following a failure of a single element; and
iii. Simultaneous failure, or partial failure, of multiple load path discrete elements, working
at similar stress levels.
In practice it may not be possible to guard against the effects of multiple damage and failsafe
substantiation may be valid only up to a particular life which would preclude multiple
damage.’
Nonetheless, it is not clear whether all applicants followed this guidance, hence the
development of the Part-26 ageing aeroplane structure requirements and the revision of
CS 25.571 at Amendment 19 to include specific means to address WFD. The AMC to these
requirements includes the establishment of maintenance actions to modify (or replace)
WFD-susceptible structure prior to the LOV whenever necessary to preclude WFD.
In accordance with point 26.303 of Part-26, TCHs of aeroplanes with MTOMs > 34 019 kg
(75 000 lb) have to establish an LOV and the maintenance actions upon which the LOV is
dependent, for all model variations and derivatives approved under the TC before
26 February 2021, and all structural changes and replacements to the structural
configurations of those aeroplanes that are required by an airworthiness directive (AD)
issued before 26 February 2021. Future changes by the TCH to these aeroplanes should also
be subject to WFD evaluation. For aeroplane structure certified to CS 25.571 Amdt 19 or later
amendment, the fatigue and damage tolerance evaluation requires specific consideration of
WFD, see AMC 25.571 paragraph 10.
For a new DTE performed to comply with Part-26 for existing changes or repairs or for new
changes or repairs, according to CS 25.571 Amdt 18 or earlier, the evaluation should take into
account cracking scenarios that could reasonably be expected to occur in the remaining
operational lifetime of the aeroplane in which the repair or modification is implemented. The
inspections and other procedures established do not have to include modification and
replacement, although the guidance of the applicable ACJ/AMC 25.571 as described above
WFD may originate in two basic forms, either as MSD or as MED. With extended usage,
uniformly loaded structure may develop cracks in adjacent repetitive features such as
fastener holes (MSD), or in adjacent similar structural details (MED). The development of
cracks at multiple locations (both MSD and MED) may also result in strong interactions that
can affect subsequent crack growth, in which case the predictions for local cracking would
no longer apply. An example of this situation may occur at any skin joint where load transfer

AMC 20-20A
occurs. Simultaneous cracking at many fasteners along a common rivet line may reduce the
residual strength of the joint to the less than the required levels before the cracks are
detectable under the maintenance programme established at the time of certification.
Appendix 2 provides guidelines for development of a programme to preclude the occurrence
of WFD. Such a programme must be implemented before analysis, tests, and/or service
experience indicate that WFD may develop in the fleet. The operator’s role is to provide
service experience, to help ensure the practicality of the programme and to ensure it is
implemented effectively.
The proposed LOV and the results of the WFD evaluation should be presented for review and
approval to EASA for the aeroplane model being considered.
Note: The LOV applies to aeroplanes, not to individual parts. Should there be any concerns
about the service life of a removable component containing FCS or principal structural
elements (PSEs), a modification or life limitation arising from the WFD evaluation can
be mandated on that specific component, which would then need to be tracked.
EASA’s review of the WFD evaluation results will include both engineering and maintenance
aspects of the proposal. Per Appendix I to AMC M.A.302, any actions necessary to preclude
WFD, including the LOV, are to be incorporated in the maintenance programmes developed
in compliance with Part-M. Any SBs or other service information publications revised or
issued as a result of in-service MSD/MED findings resulting from implementation of these
programmes may require separate AD action.
In the event an acceptable WFD evaluation cannot be completed on a timely basis, EASA may
impose service life, operational, or inspection limitations to assure structural integrity of the
subject type design.
(b) Revision of WFD evaluation and LOV
New service experience findings, improvements in the prediction methodology, better load
spectrum data, a change in any of the factors upon which the WFD evaluation is based or
economic considerations, may dictate a revision to the evaluation. Accordingly, associated
new recommendations for service action should be developed including a revised LOV, if
appropriate, and submitted to EASA for review and approval of both engineering and
maintenance aspects.
An LOV may be extended under the provisions of Part 21. In such cases, the applicant must
demonstrate that WFD will not occur in the aeroplane up to the proposed extended LOV. The
applicant should consider the age (flight cycles or flight hours or both) of high-time
aeroplanes relative to the existing LOV to determine when to begin developing data to extend
it. Because the data is likely to include additional full-scale fatigue testing, the applicant
should allow sufficient time to complete such testing and to submit the compliance data for
approval. An extended LOV is a major change to the type design of an aeroplane. An extended
LOV may also include specified maintenance actions, which would be part of the new LOV
approval. Extended LOVs, along with any required maintenance actions for the extended
LOV, would be incorporated into the ALS.
Note: Extending an LOV without a physical modification to the aeroplane is not considered a
‘significant’ design change in accordance with point 21.A.101 of Part-21. However, if

AMC 20-20A
extending the LOV requires a physical design change to the aeroplane, the design
change is to be evaluated in accordance with point 21.A.101 of Part-21.
For practical purposes, it is suggested that the SRM should also be reviewed and updated to
facilitate its continued applicability up to the extended LOV. If this is not done, all SRM-based
repairs will require individual approval. The results together with any necessary actions
required to preclude WFD from occurring before the aeroplane reaches the revised LOV
should be presented for review and approval by EASA.
Note: Although the extended LOV is established based on WFD considerations, it is intended
that all maintenance actions required to address fatigue, corrosion, and accidental
damage up to the extended LOV should be identified in the structural-maintenance
programme. 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 extended LOV, should be included in the ALS of the ICA, as required by
CS 25.1529, along with the extended LOV.
9. CORROSION PREVENTION AND CONTROL PROGRAMME
A corrosion prevention and control programme (CPCP) is a systematic approach to prevent and to
control corrosion in the aircraft’s primary structure. The objective of a CPCP is to limit the
deterioration due to corrosion to the level necessary to maintain airworthiness and, where
necessary, to restore the corrosion protection schemes for the structure. A CPCP consists of a basic
corrosion inspection task, task areas, defined corrosion levels, and compliance times
(implementation thresholds and repeat intervals). The CPCP also includes procedures to notify the
competent authority and TCH of the findings and data associated with Level 2 and Level 3 corrosion
and the actions taken to reduce future findings to Level 1 or better. See Appendix 4 for definitions
and further details.
As part of the ICA, the TCH should provide an inspection programme that includes the frequency
and extent of the inspections necessary to provide the continued airworthiness of the aircraft.
Furthermore, the ICA should include the information needed to apply protective treatments to the
structure after inspection. In order for the inspections to be effectively accomplished, the TCH
should provide corrosion removal and cleaning procedures and reference allowable limits (e.g. an
SRM). The TCH should include all of these corrosion-related activities in a manual referred to as the
baseline CPCP. Alternatively, the baseline CPCP may be developed as part of the ICA established by
the MRB (ISC) using existing MSG-3 procedures. This baseline CPCP documentation is intended to
form a basis for operators to derive a systematic and comprehensive CPCP for inclusion in the
operator’s maintenance programme. For operators and owners subject to point 26.370 of Part-26,
the operator’s CPCP must take into account the TCH’s baseline CPCP. The competent authority for
the operator’s CPCP is the authority responsible for their AMP. The TCH is responsible for
monitoring the effectiveness of the baseline CPCP and, if necessary, for recommending changes
based on the operator’s reports of findings. In line with the Part-M requirements, when the TCH
publishes revisions to their baseline CPCP, these should be reviewed and the operator’s programme
adjusted as necessary in order to limit corrosion to Level 1 or better.
The operator should ensure that the CPCP is comprehensive in that it addresses all corrosion likely
to affect primary structure, and is systematic in that:

AMC 20-20A
(a) it provides step-by-step procedures that are applied on a regular basis to each identified task
area or zone, and
(b) these procedures are adjusted when they result in evidence that corrosion is not being
limited to an established acceptable level (Level 1 or better).
Note: For an aeroplane with an ALS, in addition to providing a suitable baseline CPCP in the ICA, it
is appropriate for the TCH to place an entry in the ALS stating that all corrosion should be limited
to Level 1 or better. (This practice is also described in ATA MSG-3.)
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Appendix 1 to AMC 20-20A Guidelines for the development of a

supplementary structural inspection programme
1. GENERAL
1.1 Purpose
This Appendix 1 gives interpretations, guidelines and acceptable means of compliance for the
SSIP actions. Aeroplanes addressed by point 26.302 of Part-26 require damage tolerance
inspections (DTIs) and other procedures to ensure freedom from catastrophic failure due to
fatigue throughout the operational life of the aircraft. Compliance can be demonstrated by
developing an SSIP or DT-based ALS. Other aircraft may benefit from an SSIP, and some TCHs
have already developed programmes for general aviation types that should also be
implemented under Part-M requirements.
1.2 Background
Service experience has demonstrated that there is a need to have continually updated
knowledge concerning the structural integrity of aircraft, especially as they become older, to
ensure they continue to meet the level of safety intended by the certification specifications.
In addition, early fatigue requirements, such as ‘fail safe’ regulations, did not provide for
timely inspection of an aircraft’s critical structure to ensure that damaged or failed
components could be dependably identified and then repaired or replaced before hazardous
conditions developed.
In 1978 the damage tolerance concept was adopted for transport category aeroplanes in the
USA as Amendment 25-45 to 14 CFR 25.571. This amended rule required damage tolerance
analyses as part of the type design of transport category aeroplanes for which application for
type certification was received after the effective date of the amendment. In 1980 the
requirement for damage tolerance analyses was also included in JAR 25.571 Change 7.
One prerequisite for the successful application of the damage tolerance approach for
managing fatigue is that crack growth and residual strength can be anticipated with sufficient
precision to allow inspections to be established that will detect cracking before it reaches a
size that will degrade the strength to less than a specified level. When damage is discovered,
airworthiness is ensured by repair or revised maintenance action. Evidence to date suggests
that when all critical structure is included, fatigue and damage-tolerance-based inspections
and procedures (including modification and replacement when necessary) provide the best
approach to address aircraft fatigue.
Pre-14 CFR Part 25 Amendment 25-45 (JAR-25 Change 7) aeroplanes were built to varying
standards that embodied fatigue and fail-safe requirements. These aeroplanes, as certified,
had no specific mandated requirements to perform inspections for fatigue. Following the
amendment of 14 CFR Part 25 to embody damage tolerance requirements, the FAA
published Advisory Circular 91-56A. That AC was applicable to pre-Amendment 25-45
aeroplanes with a maximum gross weight greater than 75 000 lb (34 019 kg). According to
the AC, the TCH, in conjunction with operators, was expected to initiate development of an
SSIP for each aeroplane model.

AMC 20-20A
AC 91-56A provided guidance material for the development of such programmes based on
damage tolerance principles. Many TCHs of large aeroplanes developed SSIPs for their pre-
Amendment 25-45 aeroplanes. The documents containing the SSIP are designated SSIDs or
SIDs.
The competent authorities have in the past issued a series of ADs requiring compliance with
these SSIPs. Generally, these ADs require the operators to incorporate the SSIPs into their
maintenance programmes. Under Part-M requirements, it is expected that an operator will
automatically incorporate the SSID into their maintenance programme once it is approved
by EASA, unless already mandated by an AD.
For post-Amendment 25-45 aeroplanes (JAR-25 Change 7), it was required that inspections
or other procedures should be developed based on the DTEs required by 14 CFR 25.571, and
included in the maintenance data. In Amendment 25-54 to 14 CFR 25 and change 10 to JAR-
25, it was required to include these inspections and procedures in the ALS of the ICA required
by 25.1529. At the same amendment, 25.1529 was changed to require applicants for type
certificates to prepare ICA in accordance with Appendix H to FAR/JAR-25. Appendix H
requires that the ICA must contain a section titled airworthiness limitations that is segregated
and clearly distinguishable from the rest of the document. This section shall contain the
information concerning inspections and other procedures as required by FAR/JAR/CS 25.571.
The content of the ALS of the ICA is designated by some TCHs as airworthiness limitations
instructions (ALI). Other TCHs have decided to designate the same items as ALI.
Part-M requires the ALS to be incorporated into the operator’s maintenance programme.
2. SUPPLEMENTAL STRUCTURAL INSPECTION PROGRAMME (SSIP)
Increased utilisation, longer operational lives, and the high safety demands imposed on the current
fleet of transport aeroplanes indicate the need for a programme to ensure a high level of structural
integrity for all aeroplanes in the transport fleet.
This AMC is intended to provide guidance to TCHs and other DAHs to develop or review existing
inspection programmes for effectiveness. SSIPs are based on a thorough technical review of the
damage tolerance characteristics of the aircraft structure using the latest techniques and changes
in operational usage. They lead to revised or new inspection requirements primarily for structural
cracking and replacement or modification of structure where inspection is not practical.
Whether the aircraft was originally certified to be damage-tolerant or not, the TCH should review
its operational usage on a regular basis and ensure that it remains in accordance with the
assumptions made at certification or when the SSIP was first developed. Factors such as the
payload, fuel at take-off and landing, flight profile, etc. should be addressed. For large transport
aeroplanes, the requirement of point 26.305 of Part-26 stipulates that a process must be in place
to ensure that the continuing structural integrity programme remains valid, considering service
experience and current operations.
Large transport aeroplanes that were certified according to 14 CFR 25.571 Amendment 25-45 or
JAR 25 Change 7 or later are damage-tolerant. The maintenance instructions and airworthiness
limitations arising from the fatigue and damage tolerance evaluations that have been specified as
mandatory are included in the ALS (and/or ADs). Other maintenance instructions are usually part
of the MRB Report, as required by ATA MSG-3. However, for pre-ATA MSG-3 rev 2 aeroplanes there

AMC 20-20A
are no requirements for regular MRB Report review and for post-ATA MSG-3 rev 2 aeroplanes there
is only a requirement for regular MRB Report review in order to assess whether the CPCP is
effective. Concerning ageing aircraft activities, it is important to regularly review the part of the
MRB Report containing the structural inspections resulting from the fatigue and damage tolerance
analysis for effectiveness.
2.1 Pre-Amendment 25-45 aeroplanes
The TCH is expected to initiate development of an SSIP for each aeroplane model. Such a
programme must be implemented before analysis, test and/or service experience indicate
that a significant increase in inspection and or modification is necessary to maintain
structural integrity of the aeroplane. This should ensure that an acceptable programme is
available to the operators when needed. The programme should include procedures for
obtaining service information, and assessment of service information, available test data, and
new analysis and test data.
An SSID should be developed in accordance with Paragraph 3 of this Appendix 1. The
recommended SSIP, along with the criteria used and the basis for the criteria, should be
submitted by the TCH to EASA for approval. The SSIP should be adequately defined in the
SSID and presented in a manner that is effective. The SSID should include the type of damage
being considered, and likely sites; inspection access, threshold, interval method and
procedures; applicable modification status and/or life limitation; and types of operation for
which the SSID is valid.
The review of the SSID by EASA will include both engineering and maintenance aspects of the
proposal. In the event an acceptable SSID cannot be obtained on a timely basis, the
competent authority may impose service life, operational, or inspection limitations to assure
structural integrity.
The TCH should check the SSID periodically against current service experience. This should
include an evaluation of current methods and findings. Any unexpected defect occurring
should be assessed as part of the continuing assessment of structural integrity to determine
a need for revision to the document.
2.2. Post-Amendment 25-45 aeroplanes
Aeroplanes certified to FAR 25.571 Amendment 25-45, JAR 25.571 Change 7 and CS-25 or
later amendments are damage-tolerant. The airworthiness limitations including the
inspections and procedures established in accordance with FAR/JAR/CS 25.571 shall be
included in the ICA, ref. FAR/JAR/CS 25.1529. Further guidance for the actual contents is
incorporated in FAR/JAR/CS-25 Appendix H.
To maintain the structural integrity of these aeroplanes, it is necessary to follow up the
effectiveness of these inspections and procedures. The DAH should therefore check this
information periodically against current service experience. Any unexpected defect occurring
should be assessed as part of the continuing assessment of structural integrity to determine
a need for revision to this information. The revised data should be developed in accordance
with the same procedures as at type certification giving consideration to any additional test
or service data available and changes to aeroplanes operating patterns.

AMC 20-20A
3. GUIDELINES FOR DEVELOPMENT OF THE SUPPLEMENTAL STRUCTURAL INSPECTION DOCUMENT

This paragraph is based directly on Appendix 1 to FAA AC 91-56B which applies to transport
category aeroplanes that were certified prior to Amendment 25-45 of 14 CFR 25 or equivalent
requirement.
3.1. General
Amendment 25-45 to § 25.571 of 14 CFR Part 25 introduced wording which emphasises
damage-tolerant design. However, the structure to be evaluated, the type of damage
considered (fatigue, corrosion, service, and production damage), and the inspection and/or
modification criteria should, to the extent practicable, be in accordance with the damage
tolerance principles of the current § 25.571 of 14 CFR Part 25 standards. An acceptable
means of compliance can be found in AC 25.571-1C (‘Damage-Tolerance and Fatigue
Evaluation of Structure’, dated April 29, 1998) or later revision.
It is essential to identify the structural parts and components that contribute significantly to
carrying flight, ground, pressure, or control loads, and whose failure could affect the
structural integrity necessary for the continued safe operation of the aeroplane. The damage
tolerance of these parts and components must be established or confirmed. Following the
guidance material of AMC 25.571, it is essential that the inspections provided in the SSIP or
ALS are practical and effective in maintaining airworthiness. Where this is not the case,
modifications or replacements should be considered.
Analyses made in respect of the continuing assessment of structural integrity should be based
on supporting evidence, including test and service data. This supporting evidence should
include consideration of the operating loading spectra, structural loading distributions, and
material behaviour. Appropriate allowance should be made for the scatter in life to crack
initiation and rate of crack propagation in establishing the inspection threshold, inspection
frequency, and, where appropriate, retirement life. Alternatively, an inspection threshold
may be based solely on a statistical assessment of fleet experience, if it can be shown that
equal confidence can be placed in such an approach.
An effective method of evaluating the structural condition of older aeroplanes is selective
inspection with intensive use of non-destructive techniques, and the inspection of individual
aeroplanes, involving partial or complete dismantling (‘teardown’) of available structure.
The effect of repairs and modifications approved by the TCH should be considered. In
addition, it may be necessary to consider the effect of non-TCH repairs and modifications on
individual aircraft. The operator has the responsibility for ensuring notification and
consideration of any such aspects in conjunction with the DAH. Guidance on the EASA’s
requirements for the DT of repairs and modifications is found in Appendix 3 to this AMC, and
further guidance for the WFD evaluation of repairs and modifications is provided in Section
7 of Appendix 2.
3.2. Damage-tolerant structures
The damage tolerance assessment of the aircraft structure should be based on the best
information available. The assessment should include a review of analysis, test data,
operational experience, and any special inspections related to the type design.

AMC 20-20A
A determination should then be made of the site or sites within each structural part or
component considered likely to crack, and the time or number of flights at which this might
occur.
The growth characteristics of damage and interactive effects on adjacent parts in promoting
more rapid or extensive damage should be determined. This determination should be based
on study of those sites that may be subject to the possibility of crack initiation due to fatigue,
corrosion, stress corrosion, disbonding, accidental damage, or manufacturing defects in
those areas shown to be vulnerable by service experience or design judgement. The damage
tolerance certification specification of CS 25.571 requires not only fatigue damage to be
addressed but also accidental and environmental damage. Some types of accidental damage
(e.g. scribe marks) can not be easily addressed by the MSG process and require specific
inspections based on fatigue and damage tolerance analysis and tests. Furthermore, some
applicants may choose to address other types of accidental damage and environmental
damage in the SSID or ALS by modelling the damage as a crack and performing a fatigue and
damage tolerance analysis. The resulting inspection programme may be tailored to look for
the initial type of damage or the resulting fatigue cracking scenario, or both.
The minimum size of damage that is practical to detect and the proposed method of
inspection should be determined. This determination should take into account the number
of flights required for the crack to grow from detectable to the allowable limit, such that the
structure has a residual strength corresponding to the conditions stated under CS 25.571.
Note: In determining the proposed method of inspection, consideration should be given to
visual inspection, non-destructive testing, and analysis of data from built-in load and
defect monitoring devices.
The continuing assessment of structural integrity may involve more extensive damage than
might have been considered in the original fail-safe evaluation of the aircraft, such as:
(a) a number of small adjacent cracks, each of which may be less than the typically
detectable length, developing suddenly into a long crack;
(b) failures or partial failures in other locations following an initial failure due to
redistribution of loading causing a more rapid spread of fatigue; and
(c) concurrent failure or partial failure of multiple load path elements (e.g., lugs, planks,
or crack arrest features) working at similar stress levels.
3.3. Information to be included in the assessment
The continuing assessment of structural integrity for the particular aircraft type should be
based on the principles outlined in paragraph 3.2 of this Appendix. The following information
should be included in the assessment and kept by the TCH in a form acceptable to EASA:
(a) the current operational statistics of the fleet in terms of hours or flights;
(b) the typical operational mission or missions assumed in the assessment;
(c) the structural loading conditions from the chosen missions; and
(d) supporting test evidence and relevant service experience.

AMC 20-20A
In addition to the information specified above, the following should be included for each
critical part or component:
(a) the basis used for evaluating the damage tolerance characteristics of the part or
component;
(b) the site or sites within the part or component where damage could affect the structural
integrity of the aircraft;
(c) the recommended inspection methods for the area;
(d) for damage-tolerant structures, the maximum damage size at which the residual
strength capability can be demonstrated and the critical design loading case for the
latter; and
(e) for damage-tolerant structures, at each damage site the inspection threshold and the
damage growth interval between detectable and critical, including any likely
interaction effect from other damage sites.
Note: Where re-evaluation of fail-safety or damage tolerance of certain parts or components
indicates that these qualities cannot be achieved, or can only be demonstrated using
an inspection procedure whose practicability or reliability may be in doubt,
replacement or modification action may need to be defined.
3.4. Inspection programme
The purpose of a continuing airworthiness assessment in its most basic terms is to adjust the
current maintenance inspection programme, as required, to assure continued safety of the
aircraft type.
In accordance with Paragraphs 1 and 2 of this Appendix, an allowable limit of the size of
damage should be determined for each site such that the structure has a residual strength
for the load conditions specified in CS 25.571. The size of damage that is practical to detect
by the proposed method of inspection should be determined, along with the number of
flights required for the crack to grow from detectable to the allowable limit.
The recommended inspection programme should be determined from the data described
above, giving due consideration to the following:
(a) fleet experience, including all scheduled maintenance checks;
(b) confidence in the proposed inspection technique; and
(c) the joint probability of reaching the load levels described above and the final size of
damage in those instances where probabilistic methods can be used with acceptable
confidence.
Inspection thresholds for supplemental inspections should be established. These inspections
would be supplemental to the normal inspections, including the detailed internal inspections.
(a) For structure with reported cracking, the threshold for inspection should be
determined by analysis of the service data and available test data for each individual
case.

AMC 20-20A
(b) For structure with no reported cracking, it may be acceptable, provided sufficient fleet
experience is available, to determine the inspection threshold on the basis of analysis
of existing fleet data alone. This threshold should be set such as to include the
inspection of a sufficient number of high-time aircraft to develop added confidence in
the integrity of the structure (see Paragraph 1 of this Appendix).
3.5. The supplemental structural inspection document (SSID)
The SSID should contain the recommendations for the inspection procedures and
replacement or modification of parts or components necessary for the continued safe
operation of the aircraft up to the LOV. Where an LOV is not provided as a result of needing
to meet a specific requirement for an LOV, the applicant may establish an LOV or must
consider all the likely fatigue scenarios up to an operational life beyond which it is highly
unlikely that the aircraft will remain in service. This may be either conservatively set based
on experience or provided as a limitation in the ICA/SSID. The document should be prefaced
by the following information:
(a) identification of the variants of the basic aircraft type to which the document relates;
(b) reference to documents giving any existing inspections or modifications of parts or
components;
(c) the types of operations for which the inspection programme are considered valid;
(d) a list of SBs (or other service information publication) revised as a result of the
structural reassessment undertaken to develop the SSID, including a statement that
the operator must account for these SBs;
(e) the type of damage which is being considered (i.e. fatigue, corrosion and/or accidental
damage); and
(f) guidance to the operator on which inspection findings should be reported to the TCH.
The document should contain at least the following information for each critical part or
component (PSE and FCS):
(a) a description of the part or component and any relevant adjacent structure, including
means of access to the part;
(b) relevant service experience;
(c) likely site(s) of damage;
(d) inspection method and procedure, and alternatives;
(e) minimum size of damage considered detectable by the method(s) of inspection;
(f) SBs (or other service information publication) revised or issued as a result of in-service
findings resulting from implementation of the SSID (added as revision to the initial SID);
(g) initial inspection threshold;
(h) repeat inspection interval;
(i) reference to any optional modification or replacement of part or component as
terminating action to inspection;

AMC 20-20A
(j) reference to the mandatory modification or replacement of the part or component at

given life, if fail-safety by inspection is impractical; and
(k) information related to any variations found necessary to ‘safe lives’ already declared.
The SSID should be compared from time to time against current service experience. Any
unexpected defect occurring should be assessed as part of the continuing assessment of
structural integrity to determine the need for revision of the SSID. Future structural SBs
should state their effect on the SSID.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A

programme to preclude the occurrence of widespread fatigue damage
1. INTRODUCTION
The terminology and methodology in this Appendix are based upon material developed by the
AAWG and lessons learned since the first issue of this AMC.
2. DEFINITIONS
Extended service goal (ESG) is an adjustment to the design service goal established by service
experience, analysis, and/or test during which the principal structure will be reasonably free from
significant cracking including WFD.
Monitoring period is the period of time when special inspections of the fleet are initiated due to an
increased risk of MSD/MED (ISP) and ending when the SMP is reached.
Scatter factor is a life reduction factor used in the interpretation of fatigue analysis and fatigue test
results.
Test-to-structure factor is a series of factors used to adjust test results to full-scale structure. These
factors could include, but are not limited to, differences in:
— stress spectrum,
— boundary conditions,
— specimen configuration,
— material differences,
— geometric considerations, and
— environmental effects.
Teardown inspection is the process of disassembling structure and using destructive inspection
techniques or visual (magnifying glass and dye penetrant) or other non-destructive inspection (NDI)
methods (eddy current, ultrasonic) to identify the extent of damage, within a structure, caused by
fatigue, environmental or accidental damage.
WFD (average behaviour) is the point in time when 50 % of the fleet is expected to reach WFD for a
particular detail.
3. GENERAL
The likelihood of the occurrence of fatigue damage in an aircraft’s structure increases with aircraft
usage. The design process generally establishes a design service goal (DSG) in terms of flight
cycles/hours for the airframe. It is expected that any cracking that occurs on an aircraft operated
up to the DSG will occur in isolation (i.e. local cracking), originating from a single source, such as a
random manufacturing flaw (e.g. a mis-drilled fastener hole) or a localised design detail. It is
considered unlikely that cracks from manufacturing flaws or localised design issues will interact
strongly as they grow.
With extended usage, uniformly loaded structure may develop cracks in adjacent fastener holes, or
in adjacent similar structural details. These cracks may or may not interact, and they can have an

AMC 20-20A
adverse effect on the residual strength capability of the structure before the cracks become
detectable. The development of cracks at multiple locations (both MSD and MED) may also result
in strong interactions that can affect subsequent crack growth; in which case, the predictions for
local cracking would no longer apply. An example of this situation may occur at any skin joint where
load transfer occurs. Simultaneous cracking at many fasteners along a common rivet line may
reduce the residual strength of the joint to less than the required levels before the cracks are
detectable under the routine maintenance programme established at the time of certification.
For new type designs, certified to CS-25 Amendment 19, AMC 25.571 provides guidance on how to
establish an LOV. For existing types, for which TCHs need to comply with point 26.303 of Part-26,
CS 26.303 and this AMC apply. The TCH should conduct structural evaluations to determine where
and when MSD/MED may occur. Based on these evaluations, the TCH should provide additional
maintenance instructions for the structure, as appropriate. The maintenance instructions include,
but are not limited to inspections, structural modifications, and limits of validity of the new
maintenance instructions. In most cases, a combination of inspections and/or
modifications/replacements is deemed necessary to achieve the required safety level. Other cases
will require modification or replacement if inspections are not viable.
There is a distinct possibility that there could be a simultaneous occurrence of MSD and MED in a
given structural area. This situation is possible on some details that were equally stressed. If this is
possible, then this scenario should be considered in developing appropriate service actions for
structural areas.
4. STRUCTURAL EVALUATION FOR WFD
4.1 General
The evaluation has three objectives:
(a) Identify fatigue-critical structure that may be susceptible to MSD/MED, see paragraph
4.2;
(b) Predict when it is likely to occur; see paragraph 4.3; and
(c) Establish additional maintenance actions, as necessary, to ensure continued safe
operation of the aircraft; see paragraph 4.4.
4.2 Structure susceptible to MSD/MED
Susceptible structure is defined as that which has the potential to develop MSD/MED. Such
structure typically has the characteristics of multiple similar details operating at similar
stresses where structural capability could be affected by interaction of multiple cracking at a
number of similar details. The following list provides examples of known types of structure
susceptible to MSD/MED. (The list is not exhaustive):
STRUCTURAL AREA SEE FIGURE
Longitudinal Skin Joints, Frames, and Tear Straps (MSD/MED) A2-1
Circumferential Joints and Stringers (MSD/MED) A2-2
Lap joints with Milled, Chem-milled or Bonded Radius (MSD) A2-3
Fuselage Frames (MED) A2-4
Stringer to Frame Attachments (MED) A2-5
Shear Clip End Fasteners on Shear Tied Fuselage Frames (MSD/MED) A2-6

AMC 20-20A
Aft Pressure Dome Outer Ring and Dome Web Splices (MSD/MED) A2-7
Skin Splice at Aft Pressure Bulkhead (MSD) A2-8
Abrupt Changes in Web or Skin Thickness — Pressurised or Un-pressurised A2-9
Structure (MSD/MED)
Window Surround Structure (MSD, MED) A2-10
Over Wing Fuselage Attachments (MED) A2-11
Latches and Hinges of Non-plug Doors (MSD/MED) A2-12
Skin at Runout of Large Doubler (MSD) — Fuselage, Wing or Empennage A2-13
Wing or Empennage Chordwise Splices (MSD/MED) A2-14
Rib to Skin Attachments (MSD/MED) A2-15
Typical Wing and Empennage Construction (MSD/MED) A2-16
Figure A2-1: Longitudinal skin joints, frames, and tear straps (MSD/MED)

AMC 20-20A
Figure A2-2: Circumferential joints and stringers (MSD/MED)
Figure A2-3: Lap joints with milled, chem-milled or bonded radius (MSD)

AMC 20-20A
Figure A2-4: Fuselage frames (MED)
Figure A2-5: Stringer-to-frame attachments (MED)

AMC 20-20A
Skin/Stringer Attachments
Figure A2-6: Shear clip end fasteners on shear tied fuselage frame (MSD/MED)
Figure A2-7: Aft pressure dome outer ring and dome web splices (MSD/MED)

AMC 20-20A
Figure A2-8: Skin splice at aft pressure bulkhead (MSD)
Figure A2-9: Abrupt changes in web or skin thickness — Pressurised or unpressurised structure (MSD/MED)

AMC 20-20A
Figure A2-10: Window surround structure (MSD, MED)
Figure A2-11: Over wing fuselage attachments (MED)

AMC 20-20A
Figure A2-12: Latches and hinges of non-plug doors (MSD/MED)
Figure A2-13: Skin at runout of large doubler (MSD) — Fuselage, wing or empennage

AMC 20-20A
Figure A2-14: Wing or empennage chordwise splices (MSD/MED)
Figure A2-15: Rib-to-skin attachments (MSD/MED)

AMC 20-20A
Figure A2-16: Typical wing and empennage construction (MSD/MED)
4.3 WFD Evaluation

Point 26.300 of Part-26 requires an LOV to be established according to specified timescales
for large transport aeroplanes with MTOWs above 34 901 kg (75 000 lb). For other types, it
is recommended that by the time the highest-time aircraft of a particular model reaches its
DSG, the evaluation for each area susceptible to the development of WFD should be
completed. A typical evaluation process is shown in Figure A2-19 below. This evaluation will
establish the necessary elements to determine a maintenance programme to preclude WFD
in that particular model’s aircraft fleet. These elements are developed for each susceptible
area and include:
4.3.1 Identification of structure potentially susceptible to WFD
Unless already fully addressed in the existing fatigue and damage tolerance evaluation,
the TCH should identify each part of the aircraft’s structure that is potentially
susceptible to WFD for further evaluation. A justification should be given that supports
selection or rejection of each area of the aircraft structure. DAHs for modified or
repaired structure should evaluate their structure and its effect on existing structure.
Typical examples of structure susceptible to WFD are included in paragraph 4.2 of this
Appendix.
4.3.2 Predicting when WFD will occur
(a) Characterisation of events leading to WFD
The fatigue process that leads to WFD is shown in Figure A2-17. This figure is
applicable to both damage that occurs in multiple sites (MSD) and damage that
occurs in similar structures at more than one location (MED). For any susceptible

AMC 20-20A
structural area, it is not a question of whether WFD will occur, but when it will
occur. In Figure A2-17, the ‘when’ is illustrated by the line titled ‘WFD (average
behaviour),’ which is the point when 50 % of the aeroplanes in a fleet would have
experienced WFD in the considered area (note that the probability density
function for flight cycles or flight hours to WFD has been depicted for reference).
The WFD process includes this phase of crack initiation and a crack growth
phase. During the crack initiation phase, which generally spans a long period of
time, there is little or no change in the basic strength capability of the structure.
The actual residual strength curve depicted in Figure A2-17 is flat, and equal to
the strength of the structure in its pristine state. However, at some time after
the first small cracks start to grow, residual strength begins to degrade. Crack
growth continues until the capability of the structure degrades to the point of
the minimum strength required by CS 25.571(b). In this context, the line in
Figure A2-17 called WFD (average behaviour) represents a point when 50 % of the
aeroplanes in a fleet fall below the minimum strength specifications of
CS 25.571(b).
NOTE: No scale implied. Probability density function for

Probability
For definition use only. Function
cycles to WFDfor
Density condition
Cycles to
REQUIRED ACTUAL
RESIDUAL RESIDUAL
STRENGTH STRENGTH
MSD/MED MSD/MED
CRACK CRACK GROWTH
INITIATION
CRACK LENGTH a
cr
WFD WFD
(Average
(average behaviour)
FLIGHT CYCLES Behavior
Figure A2-17: Effect on residual strength of developing WFD
(b) Determination of WFD (average behaviour) in the fleet

The time in terms of flight cycles/hours defining the WFD (average behaviour) in the
fleet should be established for each susceptible structural area. The data to be
assessed in determining the WFD (average behaviour) includes:

AMC 20-20A
— a complete review of the service history of the susceptible areas, to

identify any occurrences of fatigue cracking and the continuing validity of
loads and mission profiles,
— evaluation of the operational statistics of the fleet in terms of flight hours
and landings,
— significant production variants (material, design, assembly method, and
any other change that might affect the fatigue performance of the detail),
— fatigue test evidence including relevant full-scale and component fatigue
and damage tolerance test data (see subparagraph 4.3.9 and Annex 1 for
more details),
— teardown inspections, and
— any fractographic analysis available.
The evaluation of the test results for the reliable prediction of the time to when
WFD might occur in each susceptible area should include appropriate test-to-
structure factors. If full-scale fatigue test evidence is used, Figure A2-20 below
relates how that data might be utilised in determining WFD (average behaviour).
Evaluation may be analytically determined, supported by test and, where
available, service evidence.
Regardless of whether the assessment of WFD (average behaviour) is based on
in-service data, full-scale fatigue test evidence, analyses, or a combination of any
of these, the following should be considered:
4.3.3 Initial crack/damage scenario
This is an estimate of the size and extent of multiple cracking expected at MSD/MED
initiation. This prediction requires empirical data or an assumption of the
crack/damage locations and sequence plus a fatigue evaluation to determine the time
to MSD/MED initiation. Alternatively, analysis can be based on either:
— the distribution of equivalent initial flaws, as determined from the analytical
assessment of flaws found during fatigue test and/or teardown inspections
regressed to zero cycles; or
— a distribution of fatigue damage determined from relevant fatigue testing
and/or service experience.
4.3.4 Final cracking scenario
This is an estimate of the size and extent of multiple cracking that could cause residual
strength to fall to the minimum required level as shown in A2-17. Techniques exist for
3-D elastic-plastic analysis of such problems; however, there are several alternative
test and analysis approaches available that provide an equivalent level of safety. One
such approach is to define the final cracking scenario as a subcritical condition (e.g.
first crack at link-up). The use of a subcritical scenario reduces the complexity of the
analysis and, in many cases, will not greatly reduce the total crack growth time,
because the majority of the time taken to reach the critical condition is generally in the
initiation phase.

AMC 20-20A
4.3.5 Crack growth calculation

Progression of the crack distributions from the initial cracking scenario to the final
cracking scenario should be developed. These curves can be developed:
— analytically, typically based on linear elastic fracture mechanics, or
— empirically, from test or service fractographic data.
4.3.6 Potential for discrete source damage (DSD)
A structure susceptible to fatigue including MSD/MED may also be affected by DSD
due to an uncontained failure of high-energy rotating machinery (i.e. turbine engines).
At this time, there is no specific requirement to address prior fatigue cracking in
combination with DSD for certification. Nonetheless, when assessing in-service
findings of fatigue cracking, the additional threat posed by any potential DSD should
be taken into account when developing the corrective actions and the timescales for
its implementation.
4.3.7 Analysis methodology
Differences between multiple-site damage and multiple-element damage
Details of the approach used to characterise events leading up to WFD may be
different. The differences will largely depend on whether MSD or MED is being
considered. This is especially true for crack interaction.
(a) Crack interaction
MSD has the potential for strong crack interaction, and the effect of multiple
cracks on each other needs to be addressed. MED, in most cases, does not have
the same potential for strong crack interaction. The differences between the
interaction effects for MSD and MED are illustrated in Figure A2-18.
(b) MSD and MED interaction
Some areas of an aeroplane are potentially susceptible to both MSD and MED.
Simultaneous occurrence of MSD and MED is possible, even though it is not
common. A comparison of inspection start points (ISPs) or modification start
points might indicate the possibility of this occurrence. If so, the evaluation
should consider the interaction between MSD and MED.

AMC 20-20A
Single crack N (cycles) Single

N (cycles) Multiple crack
cracks
Multiple
cracks
a (mm) a (mm)
Single crack
Multiple cracks
MSD MED
Figure A2-18: Difference between MSD and MED interaction effects
The report ‘Recommendations for Regulatory Action to Prevent Widespread

Fatigue Damage in the Commercial Aeroplane Fleet’, Revision A, dated June 29,
1999 (a report of the AAWG for the ARAC’s Transport Aircraft and Engine Issues
Group), discusses two Round Robin exercises developed by the TCHs to provide
insight into their respective methodologies. One outcome of the exercises was
an identification of key assumptions or methods that had the greatest impact
on the predicted WFD behaviour. These assumptions were:
— the flaw sizes assumed at initiation of crack growth phase of analysis;
— material properties used (static, fatigue, fracture mechanics);
— ligament failure criteria;
— crack growth equations used;
— statistics used to evaluate the fatigue behaviour of the structure (e.g. time
to crack initiation);
— methods of determining the structural modification point (SMP);
— detectable flaw size assumed;
— initial distribution of flaws; and
— factors used to determine bound behaviour as opposed to mean
behaviour.
(c) MED

AMC 20-20A
When considering MED, where interaction between cracks in different elements

is not a factor, the following should be considered:
(1) In a structure containing large numbers of similar elements, there is not
normally a high probability that, after a crack initiates in an element, a
second crack will initiate in the element right next to it. If this does
happen, however, the consequences to the overall structure may be
severe. This is because having two structural members fail right next to
each other can completely negate any ability of the structure to tolerate
additional damage. Consequently, when performing an evaluation,
applicants should make conservative assumptions and assume failures to
be adjacent to each other.
(2) When an element fails completely, the load that has to be redistributed
onto the non-failed structure can be large and can have a significant
impact on the strength of both the cracked and uncracked structure;
therefore, the effects of load redistribution must be included in the
evaluation.
(d) Establishing maintenance actions
The following parameters are developed from paragraphs 4.3.2 to 4.3.7 above,
and are necessary to establish an MSD/MED maintenance programme for the
area under investigation.
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. The term ‘WFD’ is used, and can be statistically quantified, at the end
of the deterioration process when the structure is no longer able to carry the
residual strength loads. WFD can never be absolutely precluded because there
is always some probability, no matter how small, that it will occur. Therefore,
modifying or replacing structure at a predetermined, analytically-derived time
stated in flight cycles or flight hours, minimises the probability of having WFD in
the fleet. Modification or replacement is the most reliable method for
precluding WFD. The point at which a modification is undertaken is referred to
as the ‘structural modification point (SMP)’ and it is illustrated in Figure 2-1 of
Annex 2. The SMP is generally a fraction of the number representing the point
in time when WFD (average behaviour) will occur, and should result in the same
reliability as a successful two-lifetime fatigue test. This level of reliability for
setting the SMP is acceptable if MSD or MED inspections are shown to be
effective in detecting cracks. If the inspections are effective, they should be
implemented before the SMP. The implementation times for these inspections
are known as the ‘inspection start points (ISPs)’. Repeat inspections are usually
necessary to maintain this effectiveness in detecting cracks. If MSD or MED
inspections are not effective in detecting cracks, then the SMP should be set at
the time of ISP. For the purposes of this AMC, an inspection is effective if, when
performed by properly trained maintenance personnel, it will readily detect the

AMC 20-20A
damage in question11. The SMP should minimise the extent of cracking in the
susceptible structural area in a fleet of affected aeroplanes. In fact, if this point
is appropriately determined, a high percentage of aeroplanes would not have
any MSD or MED by the time the SMP is reached.
Due to the redundant nature of semi-monocoque structures, MED can be
difficult to manage in a fleet environment. This stems from the fact that most
aircraft structures are built-up in nature, and that makes the visual inspection of
the various layers difficult. Also, visual inspections for MED typically rely on
internal inspections, which may not be practical at the frequency necessary to
preclude MED due to the time required to gain access to the structure. However,
these issues are dependent on the specific design involved and the amount of
damage being considered. In order to implement a viable inspection programme
for MED, static stability must be maintained at all times and there should be no
MED concurrent with MSD in a given structural area.
4.3.8 Inspection start point (ISP)
This is the point at which inspection starts if a monitoring period is used. Inspection is
not practical for all applications and cannot replace the SMP. The ISP is determined
through a statistical analysis of crack initiation based on fatigue testing, teardown, or
service experience of similar structural details. It is assumed that the ISP is equivalent
to a lower bound value with a specific probability in the statistical distribution of
cracking events. Alternatively, the ISP may be established by applying appropriate
factors to the average behaviour.
When inspections are determined to be effective, it is necessary to establish when
those inspections should start. This point is illustrated in Figure 2-1. The start point is
determined through a statistical analysis of crack initiation based on fatigue testing,
teardown, or in-service experience of similar structure. The ISP is assumed to be
equivalent to a lower-bound value with a specific probability in the statistical
distribution of cracking events. Alternatively, an ISP may be established by applying
appropriate factors to the number representing WFD (average behaviour). (e.g. for aluminium
alloy structure, dividing the full-scale test result by a factor of 3).
For inspection intervals, see point 4.3.10.
4.3.9 Structural modification point (SMP)
The SMP should be established as a point in time when structures should be modified
or replaced to prevent WFD from occurring. This is typically established by:
— calculating when WFD would first occur in the structure (predicted using the
WFD (average behaviour)),
11 The cracking identified in the FAA Airworthiness Directive (AD) 2002-07-09 is an example of the type of cracking that MSD inspections are
effective in detecting. These cracks grow from the fastener holes in the lower row of the lower skin panel in such a way that the cracking is
readily detectable using NDI methods. The cracking identified in the FAA AD 2002-07-08 is an example of places where MSD inspections are
not effective. These cracks grow in the outer surface and between the fastener holes in the lower row of the lower skin panel in such a way
that the cracking is not readily detectable using NDI methods. Modification is the only option to address this type of cracking.

AMC 20-20A
— setting a time before the predicted occurrence of WFD to perform modifications

or replacements that will prevent it.
The applicant should demonstrate that the proposed SMP established during the
evaluation has the same confidence level as current regulations require for new
certification. In lieu of other acceptable methods, the SMP for aluminium alloy
structures can be established as a point reduced from the WFD (average behaviour), based on
the viability of inspections in the monitoring period. The SMP may be determined by
dividing the number representing the timing when WFD (average behaviour) will occur by a
factor of 2 if there are effective inspections, or by a factor of 3 if inspections are not
effective. For other materials such as high-strength steel alloys, larger scatter factors
may be necessary to account for increased variability in fatigue performance.
An aircraft should not be operated past the SMP unless the structure is modified or
replaced, or unless additional approved data is provided that would extend the SMP.
However, if during the structural evaluation for WFD, a TCH/DAH finds that the flight
cycles and/or flight hours SMP for a particular structural detail have been exceeded by
one or more aircraft in the fleet, the TCH/DAH should expeditiously evaluate selected
high-time aircraft in the fleet to determine their structural condition. From this
evaluation, the TCH/DAH should notify the competent authorities and propose
appropriate service actions.
A DAH may find that the SMP for a particular structural area has been exceeded by one
or more aeroplanes in the fleet. In that case, the DAH should expedite the evaluation
of those high-time aeroplanes to determine their structural condition, notify EASA and
propose appropriate maintenance actions specific to those aeroplanes.
The initial SMP may be adjusted based on the following:
(a) The tasks necessary to extend an SMP may include any or all of the following:
(1) Additional fatigue or residual strength tests, or both, on a full-scale
aeroplane structure or a full-scale component followed by detailed
inspections and analyses.
(2) Fatigue tests of new structure or structure from in-service aeroplanes on
a smaller scale than full component tests (i.e. subcomponent or panel
tests, or both). If a subcomponent test is used, the SMP would be
extended only for that subcomponent.
(3) Teardown inspections (destructive) on structural components that have
been removed from service.
(4) Teardown inspections (non-destructive) accomplished by selected,
limited disassembly and subsequent reassembly of specific areas of high-
time aeroplanes.
(5) Analysis of in-service data (e.g. inspections) from a statistically significant
number of aeroplanes.
(b) If cracks are found in the structural detail for which the evaluation was done
during either the monitoring period or the modification programme, the SMP
should be re-evaluated to ensure that the SMP does in fact provide the required

AMC 20-20A
confidence level. If it is shown that the required confidence level is not being
met, the SMP should be adjusted and the adjustment reflected in the
appropriate SBs to address the condition of the fleet. Additional regulatory
action may be required.
4.3.10Inspection interval and method
An interval should be chosen to provide a sufficient number of inspections
between the ISP and the SMP so that there is high confidence that no MSD/MED
condition will reach the final cracking scenario without detection. The interval
between inspections depends on the detectable crack size, the critical crack
lengths and the probability that the cracks will be detected with the specific
inspection method. Conservative scenarios should be assumed for developing
the inspection interval unless other assumptions can be consistently supported
by test and service experience. If the crack cannot be detected, the SMP must
be re-evaluated to ensure there is a high confidence level that no aircraft will
develop MSD/MED before modification.
4.4 Evaluation of maintenance actions
For all areas that have been identified as susceptible to MSD/MED, the current
maintenance programme should be evaluated to determine whether adequate
structural maintenance and inspection programmes exist to safeguard the structure
against unanticipated cracking or other structural degradation. The evaluation of the
current maintenance programme typically begins with the determination of the SMP
for each area.
Each area should then be reviewed to determine the current maintenance actions and
compare them to the maintenance needs established in this evaluation. Issues to be
considered include the following:
(a) Determine the inspection requirements (method, inspection start point, and
repeat interval) of the inspection for each susceptible area (including that
structure that is expected to arrest cracks) that is necessary to maintain the
required level of safety.
(b) Review the elements of the existing maintenance programmes already in place.
(c) Revise and highlight elements of the maintenance programme necessary to
maintain safety.
For susceptible areas approaching the SMP, where the SMP will not be increased or
for areas that cannot be reliably inspected, a programme should be developed and
documented that provides for replacement or modification of the susceptible
structural area.
4.4.1 Period of WFD evaluation validity
At whatever point the WFD evaluation is made, it should support the LOV of the
maintenance programme. Consistent with the use of test evidence to support
individual SMPs, as described above in paragraph 4.3.9, the LOV of the maintenance
programme should be based on fatigue test evidence. For an existing ageing aircraft
type, the initial WFD evaluation of the complete airframe will typically cover a

AMC 20-20A
significant forward estimation of the projected aircraft usage beyond its DSG, also
known as the ‘proposed ESG’ and is effectively a proposed LOV. Typically, an evaluation
through an additional 25 % of the DSG would provide a realistic forecast, with
reasonable planning time for necessary maintenance action. However, it may be
appropriate to adjust the evaluation validity period depending on issues such as:
(a) the projected useful life of the aircraft at the time of the initial evaluation;
(b) current NDI technology; and
(c) airline advance planning requirements for introduction of new maintenance and
modification programmes, to provide sufficient forward projection to identify
all likely maintenance/modification actions essentially as one package.
Upon completion of the evaluation and publication of the revised maintenance
requirements, the ‘proposed ESG’ becomes the LOV.
Note: This assumes that all other aspects of the maintenance programme that are
required to support the LOV (such as SSID, CPCP, etc.) are in place and have been
evaluated to ensure they too remain valid up to the LOV.

AMC 20-20A
REVIEW STRUCTURAL AREAS POTENTIALLY

SUSCEPTIBLE TO WFD
(See 4.3.1)
FOR EACH AREA, DETERMINE THE WFD

AVERAGE BEHAVIOUR IN THE FLEET
(See 4.3.2 onwards)
IS NATURAL FATIGUE CRACKING LIKELY 1 NO

STOP
WITHIN OPERATIONAL LIFE ²
ESTIMATE ALLOWABLE FATIGUE DAMAGE

SCENARIO FOR LIMIT LOAD (See 4.3.4)
ESTABLISH THE SMP

NO
FATIGUE DAMAGE SCENARIO DETECTABLE PRIOR AND TERMINATING
TO MAXIMUM ALLOWABLE EXTENT UNDER ACTION
LIMIT LOAD (See 4.3.10)
YES
ESTABLISH ISP, INSPECTION INTERVAL

AND METHOD AND
SCHEDULE FOR TERMINATING ACTION
(See 4.3.9//10/11)
NOTES:
1. Fatigue cracking is defined as likely if the factored fatigue life is less than the projected ESG of the
aircraft at time of WFD evaluation.
2. The operational life is the projected ESG of the aircraft at time of WFD Evaluation. (See 4.4.1).
Figure A2-19: Aircraft WDF evaluation process

Easy Access Rules for Acceptable Means of Compliance for SUBPART A — GENERAL
Airworthiness of Products, Parts and Appliances (AMC-20)
AMC 20-20A
FULL SCALE FATIGUE

FULL-SCALE FATIGUE TEST
TEST DATA
DATA
NO1
TEAR DOWN?
TEAR DOWN?
YES
NO MSD/MED FINDINGS
MSD/MED FINDINGS YES
DURING TEST/TEARDOWN?
DURING TEST/TEARDOWN?
DETECTABLE CRACK
DETECTABLE CRACK SIZE
SIZE AT
AT
NO END OF
END OF TEST
TEST BEYOND
BEYOND YES
CRITICAL LENGTH2 AT
CRITICAL LENGTH AT LIMIT
LIMIT
LOAD?
LOAD?
ESTIMATED WFD AVERAGE BEHAVIOUR DETERMINED FROM
TEST LIFE
LIFE plus
plus TEST
TEST LIFE
LIFE Minus
minus
TEST LIFE TEST
TEST LIFE CRACK GROWTH

CRACK LIFE33
GROWTH LIFE CRACK GROWTH
CRACK LIFE33
GROWTH LIFE
NO =SPECIAL
LOV INSPECTIONS
Test Life/2 if all areas
REQUIRED (FAR
inspectable AMDT 96)
25.571, INSPECTION PROGRAMME/
PROGRAMME/
INSPECTION
LOV = Test Life/2 MODIFICATION PROGRAMME
PROGRAMME REQUIRED
REQUIRED (See
(See
MODIFICATION
4.3.7 onward)
4.3.7 onward)

AMC 20-20A
1 ASSUMED STATE AT END OF TEST: Best estimate of non-detected damage from inspection method used at the end of
the test or during teardown.
2 CRITICAL CRACK LENGTH: First link-up of adjacent cracks at limit load (locally) or an adequate level of large damage
capability.
3 CRACK GROWTH LIFE: Difference between assumed or actual state at the end of the test and critical crack length.
Figure A2-20: Use of fatigue test and teardown information to determine WFD average behaviour

AMC 20-20A
5. DOCUMENTATION
Any person seeking approval of an LOV of an aircraft type design should develop a document
containing all the necessary ISPs, inspection procedures, replacement times, SMPs, and any
other maintenance actions necessary to preclude WFD, and to support the LOV. That person
must revise the SSID or ALS as necessary, and/or prepare SBs that contain the aforementioned
maintenance actions. Since WFD is a safety concern for all operators of older aircraft, EASA will
make mandatory the identified inspection and modification programmes. In addition, EASA may
consider separate AD action to address any SBs or other service information publications
revised or issued as a result of in-service MSD/MED findings resulting from implementation of
these programmes.
The following items should be contained in the front of the documentation supporting the LOV:
(a) identification of the variants of the basic aircraft type to which the document relates;
(b) summary of the operational statistics of the fleet in terms of hours and flights;
(c) description of the typical mission, or missions;
(d) the types of operations for which the inspection programme is considered valid;
(e) reference to documents giving any existing inspections, or modification of parts or
components; and
(f) the LOV of the maintenance programme in terms of flight cycles or flight hours or both
as appropriate to accommodate variations in usage.
The document should contain at least the following information for each critical part or
component:
(a) description of the primary structure susceptible to WFD;
(b) details of the monitoring period (ISP, repeat inspection interval, SMP, inspection method
and procedure (including crack size, location and direction) and alternatives) when
applicable;
(c) any optional modification or replacement of the structural element as terminating action
to inspection;
(d) any mandatory modification or replacement of the structural element;
(e) SBs (or other service information publications) revised or issued as a result of in-service
findings resulting from the WFD evaluations (added as a revision to the initial WFD
document); and
(f) guidance to the operator on which inspection findings should be reported to the
TCH/DAH, and appropriate reporting forms and methods of submission.
6. REPORTING REQUIREMENTS
Operators, TCHs and STCHs are required to report in accordance with various regulations (e.g.
point 21.A.3A, and point 145.A.60). The regulations to which this AMC relates do not require
any reporting requirements in addition to the current ones. Due to the potential threat to
structural integrity, the results of inspections must be accurately documented and reported in
a timely manner to preclude the occurrence of WFD. The current system of operator and TCH
communication has been useful in identifying and resolving a number of issues that can be
classified as WFD concerns. MSD/MED has been discovered via fatigue testing and in-service
experience. TCHs have been consistent in disseminating related data to operators to solicit

AMC 20-20A
additional service experience. However, a more thorough means of surveillance and reporting
is essential to preclude WFD.
When damage is found while conducting an approved MSD/MED inspection programme, or at
the SMP where replacement or modification of the structure is occurring, the TCHs, STCHs and
the operators need to ensure that greater emphasis is placed on accurately reporting the
following items:
(a) a description (with a sketch) of the damage, including crack length, orientation, location,
flight cycles/hours, and condition of structure;
(b) results of follow-up inspections by operators that identify similar problems on other
aircraft in the fleet;
(c) findings where inspections accomplished during the repair or replacement/modification
identify additional similar damage sites; and
(d) adjacent repairs.
Operators must report all cases of MSD/MED to the TCH, STCH or the competent authority as
appropriate, irrespective of how frequently such cases occur. Cracked areas from in-service
aircraft (damaged structure) may be needed for detailed examination. Operators are
encouraged to provide fractographic specimens whenever possible. Aeroplanes undergoing
heavy maintenance checks are perhaps the most useful sources for such specimens.
Operators should remain diligent in the reporting of potential MSD/MED concerns not
identified by the TCH/DAH. Indications of a developing MSD/MED problem may include:
(a) damage at multiple locations in similar adjacent details;
(b) repetitive part replacement; or
(c) adjacent repairs.
Documentation will be provided by the TCH and STCH as appropriate to specify the required
reporting format and time frame, supporting the mandatory reporting regulations (e.g. point
21.A.3A of Part 21, point 145.A.60 of Part-145). The data will be reviewed by the TCH or STCH,
operator(s), and EASA to evaluate the nature and magnitude of the problem and to determine
the appropriate corrective action.
7. WFD EVALUATION FOR STRUCTURAL MODIFICATIONS AND REPAIRS
TCHs of aeroplanes subject to the point 26.303 of Part-26 requirements for an LOV should
perform WFD evaluations to assess all the applicable existing structure and the effect of future
changes on the LOV.
The WFD evaluations of this AMC do not apply retroactively to existing STCH’s modifications,
nor to existing repairs. Future changes and repairs need to take into account the applicable
certification basis, and applicants should consider the guidance of the applicable ACJ and AMC
as discussed in paragraph 8 of this AMC. The DTEs for compliance with points 26.307, 26.308,
26.333 and 26.334 of Part-26 do not have to consider WFD (average behaviour), or the related SMP
and ISP.
In cases where a new DTE is performed by DAHs to comply with points 26.333 and 26.334 of
Part-26 for existing changes or for new changes or repairs, according to CS 25.571 Amdt 18 or
earlier amendments, the DTE and development of DTIs should take into account the cracking
scenarios that could reasonably be expected to occur in the remaining operational lifetime of
an aeroplane into which the repair or modification is, or may be, incorporated.

AMC 20-20A
8. RESPONSIBILITY FOR WFD EVALUATION, ESTABLISHING THE LOV AND IMPLEMENTATION OF

THE LOV AND MAINTENANCE ACTIONS
The primary responsibility is with the DAH to perform the analyses and supporting tests.
However, it is expected that if extensive maintenance actions are necessary, the practicality of
their implementation will be evaluated in a cooperative effort between the operators and
TCHs/DAHs, with participation of EASA.
The TCH is responsible for proposing and submitting an LOV in the ALS for approval.
Note: In some cases, the ALS may already contain an LOV which is approved in accordance with
a regulation of another authority. There may also be other potentially more restrictive
limitations on the validity of maintenance programmes. For these cases, when the TCH needs
to publish the LOV as required by point 26.303 of Part-26, this LOV and its relationship with the
existing or superseded limitation should be clearly described so that no operator will exceed
the most restrictive applicable limit on the general validity of the maintenance programme.
The operator is responsible for implementing the LOV in their maintenance programme.
Note: The LOV does not supersede or allow operations beyond any lower limitation applicable
to the individual aeroplane and the components controlled by the maintenance programme.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 1 to Appendix 2 to AMC 20-20A Full-scale fatigue test

evidence
Contents
(a) Overview
(b) Full-scale fatigue test evidence
(c) Key elements of a full-scale fatigue test programme
(1) Article
(2) Test set-up and loading
(i) Test set-up
(ii) Test loading
(3) Test duration
(i) New type certificates and derivatives
(ii) Repairs and type design changes
(4) Post-test evaluation
(i) Residual strength tests
(ii) Teardown inspections
(d) Scope of full-scale fatigue test article
(1) New type designs
(2) Derivative models
(3) Type design changes — SBs
(4) Type design changes — STCs
(5) Major repairs
(e) Use of existing full-scale fatigue test data
(f) Use of in-service data
(a) Overview
CS 25.571(b) Amendment 19 specifies that special consideration for WFD must be included in
the fatigue and damage tolerance evaluation where the design is such that this type of damage
could occur. CS 25.571(b) Amendment 19 specifies the effectiveness of the provisions to
preclude the possibility of WFD occurring within the limits of validity of the maintenance
programme to be demonstrated with sufficient full-scale fatigue test evidence. The
determination of what constitutes ‘sufficient full-scale test evidence’ requires a considerable
amount of engineering judgement and is a matter that should be discussed and agreed to
between an applicant and EASA early in the planning stage of a certification project. Sufficient
test evidence is also necessary to support compliance with CS 26.303 and the most
straightforward means of compliance is to utilise existing full-scale test evidence.

AMC 20-20A
(b) Full-scale fatigue test evidence

In general, sufficient full-scale fatigue test evidence consists of full-scale fatigue testing to at
least twice the LOV, followed by specific inspections and analyses to determine that WFD has
not occurred. The following factors should be considered in determining the sufficiency of the
evidence:
Factor 1: The comparability of the load spectrum between the test and the projected usage of
the aeroplane.
Factor 2: The comparability of the airframe materials, design and build standards between the
test article and the certified aeroplane.
Factor 3: The extent of post-test teardown inspection, residual strength testing and analysis for
determining whether widespread fatigue cracking has occurred.
Factor 4: The duration of the fatigue testing.
Factor 5: The size and complexity of a design or build standard change. This factor applies to
design changes made to a model that has already been certified and for which full-scale fatigue
test evidence for the original structure should have already been determined to be sufficient.
Small, simple design changes, comparable to the original structure, could be analytically
determined to be equivalent to the original structure in their propensity for WFD. In such cases,
additional full-scale fatigue test evidence should not be necessary.
Factor 6: In the case of major changes and STCs, the age of an aeroplane being modified. This
factor applies to aeroplanes that have already accumulated a portion of their LOV prior to being
modified. An applicant should demonstrate freedom from WFD up to the LOV in place for the
original aeroplane and may take into account the age of the aeroplane being modified.
(c) Key elements of a full-scale fatigue test programme
The following guidance addresses key elements of a test programme that is intended to
generate the data necessary to support compliance, and it can also be used to evaluate and
interpret existing full-scale test data for the purposes of supporting compliance with point
26.303 of Part-26.
(1) Article. The test article should be representative of the structure of the aeroplane to be
evaluated (i.e. ideally a production-standard article). The 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;
— the use of faying surface sealant;
— assembly processes and sequences; and
— the influence of secondary structure (e.g. loads induced due to proximity to the
structure under evaluation).
(2) Test set-up and loading. The test set-up and loading should result in a realistic simulation
of the expected operational loads.

AMC 20-20A
(i) Test set-up. The test set-up dictates how loads are introduced into the structure
and reacted. Every effort should be made to introduce and react loads as
realistically as possible. When a compromise is 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.
(ii) Loading spectrum. The test loading spectrum should include loads from all
damaging sources (e.g. cabin pressurisation, manoeuvres, gusts, engine thrust,
control surface deflections, and landing impacts) that are significant for the
structure being evaluated. Consideration should also be given to temperature and
other environmental effects that may affect internal loads. A supporting rationale
should be provided when a load source is not represented in a sequence.
Additionally, differences between the test sequence and the expected operational
sequence should be justified. For example, it is standard practice to eliminate low
loads that are considered to be non-damaging and to clip high infrequent loads
that may non-conservatively bias the outcome, but care should be taken in both
cases so that the test results are representative.
(3) Test duration. For any WFD-susceptible area, the average time in flight cycles and/or
hours to develop WFD should first be determined. This is referred to as the
WFD (average behaviour) for the subject area. The area should be modified or replaced at one
third of this time unless inspection for MSD/MED is practical. If inspection is practical,
that inspection should start at one third of the WFD (average behaviour), with
modification/replacement at one half of that time. It is standard practice to interpret the
non-factored fatigue life of one specimen as the average life. It follows that if one
full-scale fatigue test article survives a test duration of X time without an occurrence of
WFD, it can be conservatively assumed that the WFD (average behaviour) of all susceptible areas
is equal to X. Based on this, and assuming that the susceptible areas are impractical to
inspect for MSD/MED, the replacement or modification should be implemented at X/3.
For areas where MSD/MED inspections are practical, replacement/modification could be
deferred until X/2, but MSD/MED inspections would have to start at X/3. The procedure
should be kept in mind when deciding what the test duration will be.
(4) Post-test evaluation. One of the primary objectives of the full-scale fatigue test is to
generate the data needed to determine the absolute WFD (average behaviour) for each
susceptible area, or to establish a lower bound. Recall that the definition of
WFD (average behaviour) 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 to less than the
residual strength requirements of CS 25.571(b). Some work is required at the end of the
test to determine the strength capability of the structure, either directly or indirectly.
(i) Residual strength tests. One acceptable 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 CS 25.571(b). If the test article sustains the loads, it can
be concluded that the point of WFD has yet to be reached for any of the susceptible
areas. However, because fatigue cracks 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 accomplishing additional
work (e.g. teardown inspection). Additionally, metallic test articles may be
non-conservatively compromised relative to their future fatigue performance if
static loads in excess of representative operational loads are applied. Residual

AMC 20-20A
strength testing could preclude the possibility of using an article for additional
fatigue testing.
(ii) Teardown inspections. The residual strength capability may be evaluated indirectly
by performing teardown inspections to quantify the size of any MSD/MED cracks
that might be present, or to establish a lower bound on crack size based on the
capability of the inspection method. Once this is done, the residual strength
capability can be estimated analytically. Depending on the results, crack growth
analyses may also be required to project backwards or forwards in time to estimate
the WFD (average behaviour) for an area. As a minimum, teardown inspection methods
should be capable of detecting the minimum size of MSD or MED cracking that
would result in a WFD condition (i.e. residual strength degraded to less than the
level specified in CS 25.571(b)). Ideally, it is recommended that inspection methods
should be used that are capable of detecting MSD/MED cracking before it degrades
the strength to less than the required level. Effective teardown inspections that are
required to demonstrate freedom from WFD typically require significant resources.
They typically require disassembly (e.g. fastener removal) and destruction of the
test article. All areas that are or may be susceptible to WFD should be identified
and examined.
(d) Scope of full-scale fatigue test article
The following examples offer some guidance on the types of data sets that might constitute
‘sufficient evidence’ for some kinds of certification projects. The scope of the test specimen and
the duration of the test are considered.
(1) New type designs
Normally, this type of project would necessitate its own full-scale fatigue test of the
complete airframe to represent the new structure and its loading environment.
Nevertheless, prior full-scale fatigue test evidence from earlier tests performed by the
applicant, or others, may also be used, and could supplement additional tests on the new
model. Ultimately, the evidence needs to be sufficient to conclude with confidence that,
within the LOV of the airframe, WFD will not occur. Factors 1 to 4 should be considered
in determining the sufficiency of the evidence.
A test duration of a minimum of twice the LOV for the aeroplane model would normally
be necessary if the loading spectrum is realistic, the design and construction for the test
article principal structure are the same as for the certified aeroplane, and the post-test
teardown is exhaustive. If conformance to Factors 1 through 3 is less than ideal, a
significantly longer test duration would be needed to conclude with confidence that WFD
will not occur within the LOV. Moreover, no amount of fatigue testing will suffice if
conformance to Factors 1 through 3 above is not reasonable. Consideration should also
be given to the possible future need for life extension or product development, such as
potential weight increases, etc.
(2) Derivative models
The default position would be to test the entire airframe. However, it may be possible to
reliably determine the occurrence of WFD for all or part of the derivative model from the
data that the applicant generated or assembled during the original certification project.
Nevertheless, the evidence needs to be sufficient to allow confidence in the calculations
which show that WFD will not occur within the LOV of the aeroplane. Factors 1 through
5 should be considered in determining the sufficiency of the evidence for derivative
models. For example, a change in the structural design concept, a change in the

AMC 20-20A
aerodynamic contours, or a modification of a structure that has a complex internal load

distribution might well make analytical extrapolation from the existing full-scale fatigue
test evidence very uncertain. Such changes might well necessitate full-scale fatigue
testing of the actual derivative principal structure. On the other hand, a typical derivative
often involves extending the fuselage by inserting ‘fuselage plugs’ that consist of a copy
of the typical semi-monocoque construction for that model, with slightly modified
material gauges. Normally this type of project would not necessitate its own full-scale
fatigue test, particularly if very similar load paths and operating stress levels are retained.
(3) Type design changes — SBs
Normally, this type of project would not necessitate its own full-scale fatigue test because
the applicant would have generated, or assembled, sufficient full-scale fatigue test
evidence during the original certification project that could be applied to the change.
Nevertheless, as cited in the previous example, the evidence needs to be sufficient to
allow confidence in the calculations which show that WFD will not occur within the LOV
of the aeroplane. In addition, Factor 5, ‘The size and complexity of a design change’,
(4) Type design changes — STCs
(i) Sufficient full-scale test evidence for structures certified under an STC may
necessitate additional full-scale fatigue testing, although the extent of the design
change may be small enough to use Factor 5 to establish the sufficiency of the
existing full-scale fatigue test evidence. The applicant for an STC may not have
access to the original equipment manufacturer (OEM)’s full-scale fatigue test data.
For aeroplane types for which an LOV has been published, the STC applicant may
assume that the basic structure was free from WFD up to the LOV, unless EASA has
taken AD action, or intends to take action (by a proposed AD) to alleviate a WFD
condition, or inspections or modifications exist in the ALS relating to WFD
conditions. For the purpose of the STC applicant’s demonstration that WFD will not
occur on its modification (or the underlying original structure) within the LOV, it
may be assumed that the model types, to which the LOV is applicable, have
received at least two full LOVs of fatigue testing, under realistic loads, and have
received thorough post-test inspections that did not detect any WFD, or the ALS
includes from the outset details of the modifications required to address WFD that
will need specific consideration by the STC applicant. With this knowledge, and
Factors 1 through 5, the STC applicant may be able to demonstrate that WFD will
not occur on its modification (or the underlying original structure) within the LOV.
If, however, the modification significantly affects the distribution of stress in the
underlying structure, or significantly alters loads in other parts of the aeroplane, or
significantly alters the intended mission of the aeroplane, or if the modification is
significantly different in its structural concept from the certified aeroplane being
modified, additional representative fatigue test evidence would be necessary.
(ii) In addition, Factor 6 ‘The age of the aeroplane being modified’ comes into play for
modifications made to older aeroplanes. The STC applicant should demonstrate
freedom from WFD up to the LOV of the aeroplane being modified. For example,
an applicant for an STC to an aeroplane that has reached an age equivalent to 75 %
of its LOV should demonstrate that the modified aeroplane will be free from WFD
for at least the remaining 25 % of the LOV. Although an applicant could attempt to
demonstrate freedom from WFD for a longer period, this may not be possible
unless the OEM cooperates by providing data for the basic structure. A short DSG

AMC 20-20A
for the modification could simplify the demonstration of freedom from WFD for
the STC applicant. Nevertheless, the applicant should also be aware that the LOV
of the aeroplane is not a fixed life; it may be extended as a result of a structural
re-evaluation and service action plan, such as those developed for certain models
under the FAA’s ‘Aging Aircraft Program’. Unless the modifier also re-evaluates its
STC modification, the shorter goal for the modification could impede extending the
LOV of the modified aeroplanes.
(5) Major repairs. New repairs (for which the applicable certification basis requires WFD
evaluation) that differ from the repairs contained in the OEM’s SRM, but that are
equivalent in design from such repairs, and that meet CS-25 specifications in other
respects, would not necessitate full-scale fatigue testing to support freedom from WFD
up to the LOV. Major repair solutions (that may be susceptible to WFD) which utilise
design concepts (e.g. new materials, other production processes, new design details)
different from the previously approved repair data may need further testing.
(e) Use of existing full-scale fatigue test data
In some cases, especially for establishing an LOV in accordance with point 26.303 of Part-26, or
for derivative models and type design changes accomplished by the TCH, there may be existing
full-scale fatigue test data that may be used to support compliance and mitigate the need to
perform additional testing.
Any physical differences between the structure originally tested and the structure being
considered that could affect its fatigue behaviour must be identified and reconciled. Differences
that should be addressed include, but are not limited to, differences in any of the physical
attributes listed under point (c)(1) of this Annex and differences in operational loading. Typical
developments that affect the applicability of the original LOV demonstration data are the:
— gross weight (e.g. if it increases),
— cabin pressurisation (e.g. a change in the maximum cabin or operating altitude), or
— flight segment parameters.
The older the test data, the harder it may be to demonstrate that it is sufficient. Often test
articles were not conformed, neither were test plans or reports submitted to EASA as part of
the compliance data package. The rigour of loading sequences has varied significantly over the
years, and from OEM to OEM. Additionally, testing philosophies and protocols were not
standardised. For example, post-test evaluations, if any, varied significantly and in some cases
consisted of nothing more than limited visual inspections. However, there may be acceptable
data from the early full-scale fatigue tests that the applicant proposes to use to support
compliance. In order to use such data, the configuration of the test article and the loading must
be verified, and the issue of the residual strength capability of the article (or teardown data) at
the end of the test must be addressed.
(f) Use of in-service data
There may be in-service data that can be used to support WFD evaluations. Examples of such
data are as follows:
— Documented positive findings of MSD/MED cracks that include the location, size and the
time in service of the affected aeroplane, along with a credible record of how the aircraft
had been operated since the original delivery.
— Documented negative findings from in-service inspections for MSD/MED cracks on a
statistically significant number of aeroplanes, with the time in service of each aircraft,

AMC 20-20A
and a credible record of how each aircraft had been operated since the original delivery.
For this data to be useful, the inspection methods used should have been capable of
detecting MSD/MED crack sizes equal to or smaller than those sizes that could reduce the
strength of the structure to less than the residual strength levels specified in CS 25.571(b).
— Documented findings from the destructive teardown inspection of structures from
in-service aircraft. This might be structures (e.g. fuselage splices) removed from the
aircraft that were subsequently returned to service, or from retired aircraft. It would also
be necessary to have a credible record of the operational loading experienced by the
subject structure up to the time it was taken out of service.
Prior to using in-service data, any physical or loading differences that exist between the
structure of the in-service or retired aeroplanes and the structure being certified should be
identified and reconciled as discussed above.
[Amdt 20/20]

AMC 20-20A
Annex 2 to Appendix 2 to AMC 20-20A Example of how to establish

an LOV
This Annex provides a simplified example of how to establish an LOV for a specified aeroplane
structural configuration. The process for establishing an LOV involves four steps:
Step 1. Identifying a candidate LOV for the aeroplane structural configuration.
Step 2. Identifying WFD-susceptible structure. For this evaluation, it was determined that the
aeroplane structural configuration had six areas with WFD-susceptible structures.
Step 3. Performing a WFD evaluation for each of the six areas of WFD-susceptible structure to
determine whether there are inspection start points and structural modification points for the
candidate LOV identified. This allows the evaluation of the candidate LOV.
Figure 2-1, shown below, shows the WFD behaviour for one WFD-susceptible area. The figure also
shows three different candidate LOVs. Candidate LOV1 is at a point that occurs significantly before the
WFD average behaviour line. This LOV will not require any maintenance actions. Candidate LOV2
occurs before the WFD average behaviour line, but closer to it. As a result, inspection will need to start
before the LOV. Although candidate LOV3 occurs before the WFD average behaviour line, with this
LOV, the probability of WFD in the fleet is unacceptable, and inspection and subsequent modification
or replacement is required before the aeroplane reaches LOV3. Note that for LOV2 and LOV3, if
inspections were determined to be unreliable, then the SMP would occur at the point on the chart
where the ISP is. Using this example, this decision-making process needs to be repeated for all six
WFD-susceptible areas.
Applicants should evaluate the candidate LOVs and the results of WFD evaluations for each susceptible
area.

AMC 20-20A
Candidate Candidate Candidate

LOV 1 LOV 2 LOV 3
Residual strength
Crack length
ISP SMP
WFD
Flight cycles/hours (average behaviour)
Figure 2-1: Comparison of WFD-susceptible structure to aircraft LOV
Step 4. Finalising the LOV. Once all the susceptible areas have been evaluated, the final step is to
determine where to establish the LOV that will be proposed for compliance. Figure 2-2 shows the
results of the WFD evaluation of the six WFD-susceptible areas. As it is shown, there are inspections
and modifications or replacements that should be performed over time to preclude WFD. Any LOV
can be valid as long as it is demonstrated that, based on its inherent fatigue characteristics and any
required maintenance actions, the aeroplane model will be free from WFD up to the LOV. The example
in Figure 2-2 includes three LOVs that could be proposed for compliance.
— LOV1: Maintenance actions are not required to address WFD.
— LOV2: Inspection and modification or replacement of area four are required to address WFD.
— LOV3: The DAH may propose an LOV that is greater than LOV2. However, as shown in Figure 2-2,
that would result in more maintenance actions than identified for LOV2. Operators would be
required to perform maintenance actions in four out of the six WFD-susceptible areas. Areas 1,
2 and 4 would have to be inspected prior to the LOV. Areas 3 and 5 are free from WFD
maintenance actions. Area 4 would be required to be inspected and modified, and then the
modification would be required to be inspected prior to the LOV. Area 6 would require
modification prior to reaching the LOV. Some of the maintenance actions required for the LOV
may have already been issued in an SB and mandated by an AD. For the rest, ADs will need to
be issued.

AMC 20-20A
Figure 2-2: Aeroplane maintenance actions
[Amdt 20/20]

AMC 20-20A
Appendix 3 to AMC 20-20A Guidelines for establishing instructions

for continued airworthiness of structural repairs and modifications
1. INTRODUCTION
With an SSID, CPCP, mandatory modifications and an LOV in place, an individual aircraft may
still not meet the intended level of airworthiness for ageing aircraft structures. Repairs and
modifications to aircraft structure also warrant investigation. It is recommended that for large
transport aeroplanes, all repairs and modifications that affect the FCS should be assessed using
some form of damage-tolerance-based evaluation. A regulatory requirement for damage
tolerance was not applied to aeroplane design types certified before 1978, and even after this
time, the implementation of DTE on repairs and modifications was not consistent. Therefore,
the damage tolerance characteristics of repairs and modifications may vary widely and are
largely unknown. In view of these concerns, it is necessary to perform an assessment of the
repairs and modifications on certain aircraft in service to establish their damage tolerance
characteristics. Further information on the background to the need for
damage-tolerance-based inspection programmes for repairs is provided in Annex 6 to this
Appendix.
Repairs and modifications to aeroplanes certified to JAR 25 Change 7 or 14 CFR 25
Amendment 45 or later must comply with the fatigue and damage tolerance requirements of
their certification basis. In addition, points 26.307, 26.308, 26.309, 26.332 to 26.334 and 26.370
of Part-26 define additional requirements for certain repairs and modifications that must be
addressed using the damage tolerance methodology.
In cases where a new DTE is performed by DAHs to comply with points 26.333 and 26.334 of
Part-26 for existing changes or for new changes or repairs, according to CS 25.571 Amendment
18 or earlier amendments, the DTE and development of DTI should take into account the
cracking scenarios that could reasonably be expected to occur in the remaining operational
lifetime of the aeroplane into which the repair or modification can be incorporated.
2. DEFINITIONS
See paragraph 4 of this AMC.
3. ESTABLISHMENT OF A DAMAGE-TOLERANCE-BASED INSPECTION PROGRAMME FOR REPAIRS
AFFECTING FCS
3.1 Overview of the TCH tasks for repairs that may affect the FCBS
(a) Identify the affected aircraft model, models, aircraft serial numbers, and DSG
stated as a number of flight cycles, flight hours, or both.
(b) Identify the certification level.
(c) Identify and develop a list of FCBS.
(d) Submit the list of FCBS to EASA for approval, and make it available to operators and
STCHs.
(e) Review and update published repair data as necessary.
(f) Submit any new or updated published repair data to EASA for approval (or approve
the data in accordance with Subpart M of Part 21), and make it available to
operators.

AMC 20-20A
(g) Develop REGs and submit them to EASA for approval, and make the approved REGs
available to operators.
3.2. Certification level
In order to understand what data is required, the TCH should identify the amendment
level of the original aircraft certification relative to CS 25.571. The amendment level is
useful in identifying what DT data may be available and what standard should be used for
developing new DT data. The two relevant aircraft groups are:
Group A Aircraft certified to CAR 4b or 14 CFR § 25.571, prior to Amendment 25-45 or
JAR 25 Change 7 or equivalent. These aircraft were not evaluated for damage
tolerance as part of the original type certification. Unless previously
accomplished, existing and future repairs to FCBS will need DT data to be
developed.
Group B Aircraft certified to JAR 25 Change 7 or 14 CFR § 25.571, Amendment 25-45 or
later. These aircraft were evaluated for damage tolerance as part of the
original type certification. As noted in the introduction, some of these repairs
may not have repair data that includes appropriate DTI and the TCH and
operators may need to identify and perform a DTE of these repairs and
develop DTIs.
3.3. Identifying fatigue-critical baseline structure (FCBS)
TC holders should identify and make available to operators a list of baseline structure that
is susceptible to fatigue cracking that could contribute to a catastrophic failure. The term
‘baseline’ refers to the structure that is designed under the original type certificate or
amended type certificate for that aircraft model (that is, the ‘as delivered aircraft model
configuration’). Guidance for identifying this structure can be found in CS-25 AMC 25.571.
This structure is referred to in this AMC as ‘fatigue-critical baseline structure.’ The
purpose of requiring identification and listing of FCS is to provide operators with a tool
that will help in evaluating existing and future repairs or modifications. In this context,
FCS is any structure that is susceptible to fatigue that could contribute to a catastrophic
failure, and should be subject to a DTE. The DTE would determine if DTIs need to be
established for the repaired or modified structure. For the purpose of this AMC, structure
that is modified after aircraft delivery from the TCH is not considered to be ‘baseline’
structure.
CS 25.571(a) states ‘An evaluation of the strength, detail design, and fabrication must
show that catastrophic failure due to fatigue environmental and accidental damage, will
be avoided throughout the operational life of the aeroplane. This evaluation must be
conducted … for each part of the structure which could contribute to a catastrophic
failure (such as wing, empennage, control surfaces, fuselage, engine mounts, and their
related primary attachments) …’. When identifying FCBS, it is not sufficient to consider
only that structure identified in the SSID or ALS. Some SSIDs or ALSs might only include
supplemental inspections of the most highly stressed elements of the FCBS. An SSID or
ALS often refers to this structure as a PSE. If repaired, other areas of structure not
identified as a PSE in the SSID or ALS may require supplemental inspections. The term PSE
has, at times, been interpreted narrowly by industry. The narrow application of the term
PSE could incorrectly limit the scope of the structure that would be considered relative
to fatigue if repairs or modifications exist or are made subsequently. The relationship
between PSE and FCS could vary significantly depending on the TCH’s working definition
of PSE. In addition, there may be structure whose failure would be catastrophic, but due

AMC 20-20A
to low operational loads on the part, the part will not experience fatigue cracking.
However, if the subject part is repaired or modified, the stresses in the part may be
increased to a level where it is now susceptible to fatigue cracking. These types of parts
should be considered as FCS.
TCHs should develop the list of FCBS and it should include the locations of the FCS and a
diagram showing the extent of the FCS. TCHs should make the list available to STCHs and
to operators.
Note: Typically, for the purposes of compliance with Part-26 related to FCS, it is not
expected that composite structures will be identified as FCS; however, metallic
repairs/changes to composites may be FCSs. If composite structures on a type design are
found to be susceptible to fatigue cracking, this should be discussed with EASA under the
CAW procedures. With the increase in the use of composites, EASA will monitor the
adequacy of existing structural integrity programmes for composite structures, including
repairs.
3.4. Certification standard applied when performing a DTE
For Group A aircraft, the TCH should use the requirements of JAR 25.571 Change 7 or
14 CFR § 25.571, at Amendment 25-45, as a minimum standard. For Group B aircraft, the
TCH should use the requirements that correspond to the original certification basis as a
minimum standard. For each repair requiring a DTE, the DAH should apply not less than
the minimum standard when developing new or revised DT data. The certification
standard applied by the TCH in performing a DTE for repairs should be identified in the
Part-26 compliance documentation submitted to EASA, and applicable Part-26
paragraphs clearly referenced in the approved documentation provided to the operator.
3.5. Performing a DTE on a repair that affects FCBS
When performing a DTE on a repair that affects the FCBS, the DTE would apply to the
affected FCBS and repair. This may consist of an individual analysis or the application of
a DT-based process such as RAGs that would be used by an operator. The result of the
DTE should lead to developing DTIs that address any adverse effects the repair may have
on the FCBS. If the DTE results determine that DTIs are not required to ensure the
continued airworthiness of the affected FCBS, the TCH should note that in the DTE
documentation.
The term ‘adverse effects’ refers to a degradation in the fatigue life or inspectability of
the affected FCBS. Degradation in fatigue life (earlier occurrence of critical fatigue
cracking) may result from an increase in internal loading, while degradation of
inspectability may result from physical changes made to the structure. The DTE should be
performed within a time frame that ensures the continued airworthiness of the affected
FCBS.
3.6. Review of published repair data
Published repair data are generally applicable instructions for accomplishing repairs, such
as those contained in SRMs and SBs. TCHs should review their existing repair data and
identify each repair that affects the FCBS. For each such repair, unless previously
accomplished, the TCH must perform a DTE and develop any necessary DTI for the
affected FCBS and repair data. For some repairs, the results of the DTE will conclude that
no new DTI will be required for the affected FCBS or repair. For these cases, the TCH
should provide a means that informs the operator that a DTE was performed for the
subject repair. This may be accomplished, for example, by providing a statement in a

AMC 20-20A
document, such as an SRM, stating that all repairs contained in this manual have had a
DTE performed. This should preclude operators from questioning those repairs that do
not have DTIs. TCHs should provide a list of their published repair data to operators and
a statement that a DTE has been performed on this data. The following examples of
published repair data developed by the TCH should be reviewed and included in this list:
(a) SRMs,
(b) SBs,
(c) documents containing AD-mandated repairs, and
(d) other documents available to operators (e.g. some sections of aircraft
maintenance manuals and component maintenance manuals) that may contain
approved repair data.
3.7. Developing DT data for existing published repair data
3.7.1. SRMs
The TCH should review the repair data contained in each SRM and identify repairs
that affect FCBS. For these repairs, the TCH will need to determine if the SRM needs
revising to provide adequate DTI. In determining the extent to which an SRM may
need to be revised for compliance, consider the following:
(a) Whether the existing SRM contains an adequate description of DTIs for the
specific model.
(b) Whether normal maintenance procedures (e.g. the inspection threshold
and/or existing normal maintenance inspections) are adequate to ensure
the continued airworthiness (inspectability) is equal to the unrepaired
surrounding structure.
(c) Whether SRM Chapter 51 standard repairs have a DTE.
(d) Whether all SRM-specific repairs affecting FCBS have had a DTE performed.
(e) Whether there is any guidance on proximity of repairs.
(f) Whether existing superseded repairs are addressed and how a DTE will be
performed for repairs that are likely to be superseded in the future and how
any DTI will be made available.
3.7.2. SBs
The TCH should review the repair data contained in its SBs (See Annex 4) and
identify those repairs that affect FCBS. For those repairs, the TCH should then
determine if a new DTE will need to be performed. This review may be done in
conjunction with the review of SBs for modifications that affect FCBS.
3.7.3. ADs
The TCH should review ADs that provide maintenance instructions to repair FCBS
and determine if the instructions include any necessary DT data. While
maintenance instructions supporting ADs are typically contained in SBs, other
means of documentation may be used.
3.7.4. Other forms of data transmission
In addition to SRMs, SBs, and documentation for ADs, the TCH should review any
other documents (e.g. aircraft maintenance manuals and component maintenance

AMC 20-20A
manuals) that contain approved repair data. Individual repair data not contained
in the above documents will be identified and DT data obtained through the REGs
process.
3.8. Developing DT data for future published repair data
Following the completion of the review and revision of existing published data, any
subsequent repair data proposed for publication should also be subject to DTE and DTI
provided.
3.9. Approval of DT data developed for published repair data
For existing published repair data that requires new DT data for repairs affecting the
FCBS, the TCH should submit the revised documentation to EASA for approval unless
otherwise agreed in the compliance plan approved in accordance with point 26.301 of
Part-26. For instance, it may be agreed that the data can be approved according to an
existing or a modified process utilising the Part 21 DOA privileges for repair approval of
the TCH. The DT data for future published repair data may be approved according to
existing processes.
3.10. Documentation of DT data developed for published repair data
TCHs should include the means used to document any new DTI developed for published
repair data. For example, in lieu of revising individual SBs, the TCH may choose to
establish a collector document that would contain new DTI developed and approved for
specific repairs contained in various SBs.
3.11. Existing repairs
TCHs should develop processes that will enable operators to identify and obtain DTI for
existing repairs on their aircraft that affect FCBS. Collectively, these processes are
referred to as the REGs and are addressed in subparagraph 3.13.
According to point 26.309 of Part-26, REGs are required for aircraft for which the TC was
issued prior to 11 January 2008. Derivatives of aircraft for which the original TC was issued
prior to 11 January 2008 where only part of the structure is certified to CS-25 Amdt 1 or
later should have REGs that address the whole structure, due to the risk that subsequent
repairs may have been implemented without adequate knowledge of the applicability of
the certification basis to the various areas of the structure.
3.12. Future repairs
Future repairs to FCS must have a DTE performed in accordance with Part 21 and the
applicable certification basis. This includes blend-outs, trim-outs, etc., that are beyond
published limits. For new repairs, the applicant may, in conjunction with an operator, use
the three-stage approval process provided in Annex 1 to this Appendix. This process
involves incremental approval of certain engineering data to allow an operator to return
its aircraft to service before all DT data is developed and approved. The applicant should
document this process and the operator should reference it in their maintenance
programme if it is intended to apply it.
3.13. Repair evaluation guidelines
REGs provide instructions to the operator on how to survey aircraft, how to obtain DTI,
and an implementation schedule that provides timelines for these actions. Effective REGs
may require that certain DT data be developed by the TCH and made available to
operators. Updated SRMs and SBs, together with the existing, expanded, or new RAG

AMC 20-20A
documents, form the core of the information that will need to be made available to the
operator to support this process. In developing REGs the TCH will need to determine what
DT data is currently available for repairs and what new DT data will need to be developed
to support operator compliance. REGs should include:
(a) a process for conducting surveys of affected aircraft that will enable identification
and documentation of all existing reinforcing repairs that affect FCBS;
(b) a process for obtaining DTI for repairs affecting FCBS that are identified during an
aircraft survey; and
(c) an implementation schedule that provides timelines for:
(1) conducting aircraft surveys,
(2) obtaining DTI, and
(3) incorporating DTI into the operator’s maintenance programme.
3.13.1. Implementation schedule
(a) The schedule provided in this Section is applicable to REGs produced in
compliance with point 26.309 of Part-26. In cases where REGs are deemed
necessary, the TCH should propose a schedule for approval by EASA that
takes into account the distribution of the fleet relative to ¾ DSG, the extent
of the work involved, and the airworthiness risk. Aircraft fleets approaching
or exceeding their DSGs should be given priority in the implementation
schedule.
(b) Survey schedule for EASA-approved REGs applicable to aircraft maintained
under Part-M
The following basis for accomplishing the aircraft repair assessment survey
is approved by EASA and may be used by operators maintaining aircraft
according to the Part-M and Part-26 requirements:
The repair survey, the first step of the repair assessment, must be carried
out at the earliest convenient opportunity (e.g. the next heavy maintenance
check). In addition, the implementation of the surveys across the fleet must
be achieved without exceeding the DSG or a period of 7 years following the
approval by EASA of these REGs, whichever occurs later. By adhering to
these timescales, the REGs are acceptable to EASA for use by operators
needing to demonstrate compliance with point 26.370(a)(ii) of Part-26.
To ensure that the TCH can support the operators’ requests for data
following the survey, operators should not defer the implementation of the
programme across their fleet until the end of the allowed time period.
(c) Obtaining DTIs and incorporation of DTIs into the maintenance programme
must be completed as follows:
For existing, non-published repairs and deviations from published repairs
identified in the survey, if the REGs direct operators to contact the TCH to
obtain DTIs, the TCH should approve the DTIs within 12 months after
identification, unless the TCH uses another process agreed by EASA. To
facilitate this, the operator should provide the TCH with that request and the
associated information within 3 months from the identification.

AMC 20-20A
For repairs covered by the TCH’s published repair data, operators should
obtain and incorporate into their maintenance programmes DTIs for existing
repairs within 6 months after accomplishing the aeroplane survey. For
non-published repairs found during the survey, the incorporation should be
completed no later than 6 months after the approval of the data (see
Annex 2 to this Appendix for the DTI assessment process).
3.13.2. Developing a process for conducting surveys of affected aircraft
The TCH should develop a process for use by operators to conduct aircraft surveys.
These aircraft surveys are conducted by operators to identify and document
repairs and repairs to modifications that may be installed on their aircraft. Surveys
are intended to help the operators determine which repairs may need a DTE in
order to establish the need for DTI. Identification of repairs that need DTI should
encompass only existing reinforcing repairs i.e. those repairs that reinforce and
restore the strength of the FCBS. This typically excludes maintenance actions such
as blend-outs, plug rivets, trim-outs, etc. The process the TCH develops to conduct
surveys should include:
(a) a survey schedule;
(b) areas and access provisions for the survey;
(c) a procedure for repair data collection that includes:
(1) repair dimensions,
(2) repair material,
(3) repair fastener type,
(4) repair location,
(5) repair proximity to other repairs,
(6) repairs covered by published repair data, and
(7) repairs requiring DTI;
(d) a means to determine whether a repair affects FCBS or not.
3.13.3. Developing a process to obtain DT data for repairs
(a) The TCH must develop a process that operators can use to obtain DTIs that
address the adverse effects that repairs may have on FCBS. In developing
this process, TCHs will need to identify all applicable DTIs they have
developed that are available to operators. This may include updated SRMs
and SBs, existing RAGs, expanded or new RAGs, and other sources of DTIs
developed by the TCH. For certain repairs, the process may instruct the
operators to obtain direct support from the TCH. In this case, the TCH
evaluates the operator’s request and makes available the DTI for a specific
repair or group of repairs, as needed. These may include operator or
third-party developed/approved repairs, and repairs that deviate from
approved published repair data.
(b) The process should state that existing repairs that already have DTIs
developed and in place in the maintenance programme require no further
action. For existing repairs identified during an individual aircraft survey that

AMC 20-20A
need DTIs established, the process may direct the operators to obtain the
required DTIs from the following sources:
(1) TCH-published service information such as DT-based SRMs, SBs, or
other documents containing applicable DT data for repairs.
(2) Existing approved RAG documents (developed for compliance with
SFAR § 121.107).
(3) Expanded or newly developed RAG documents. In order to expedite
the process for an operator to obtain the necessary DTI to address the
adverse affects that repairs may have on FCBS, the TCH may
determine that the existing RAG document should be expanded to
address other FCBS of the aircraft’s pressure boundary. In addition,
for aircraft that do not currently have a RAG, the TCH may determine
that in order to fully support operators in obtaining DTIs, a new RAG
document may need to be developed. General guidance for
developing this material can be found in Annex 2 below, which is
similar to FAA AC 120-73, Damage Tolerance Assessment of Repairs to
Pressurised Fuselages.
(4) Procedures developed to enable operators to establish DTIs without
having to contact the TCH for direct support. These procedures may
be similar in concept to the RAG documents.
(5) Direct support from the TCH for certain repairs. The operator directly
solicits DTIs from a TCH for certain individual repairs as those repairs
are identified during the survey.
3.14 Repairs to removable structural components
FCS may include structure on removable structural parts or assemblies that can be
exchanged from one aircraft to another, such as door assemblies and flight control
surfaces. In principle, the DT data development and implementation process also applies
to repairs to FCS on removable components. During their life history, however, these
parts may not have had their flight times recorded on an individual component level
because they have been removed and reinstalled on different aircraft multiple times.
These actions may make it impossible to determine the component’s age or total flight
hours or total flight cycles. In these situations, guidance for developing and implementing
DT data for existing and new repairs is provided in Annex 3 to this Appendix. Additional
guidance to assist in controlling and/or tracking certain maintenance requirements on
removable structure components might be found in A4A Spec 1201 ‘Removable Structural
Components Industry Guidelines’.
3.15 Training
The complexity of the repair assessment and evaluation may require adequate training
for proper implementation. In that case, it is necessary that each TCH consider providing
training for all operators of the aircraft considered by this AMC
1
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AMC 20-20A
4. MODIFICATIONS AND REPAIRS TO MODIFICATIONS (COMPLIANCE WITH POINTS 26.307,

26.308 AND 26.332 TO 26.334 OF PART-26)
4.1. TCH and STCH tasks — Modifications and repairs to modifications
The following is an overview of the TCH and STCH tasks necessary for modifications that
affect FCBS. This overview also includes TCH and STCH tasks necessary for repairs that
may affect any FCS of the subject modifications. These tasks are applicable to those
modifications that have been developed by the TCH or STCH.
(a) Establish a list of modifications that may affect FCBS. From that list establish a list
of modifications that may contain FCS.
(b) In consultation with operators, determine which aircraft have the modification(s)
installed.
(c) STCHs should obtain a list of FCBS from the TCH for the aircraft models identified
above.
(d) STCHs should identify:
— modifications that affect FCBS, or
— modifications that contain FCS.
(e) Determine if DT data exists for the identified modifications.
(f) Develop additional DT data, if necessary.
(g) Establish an implementation schedule for DTI for modifications.
(h) Review existing DT data for published repairs made to modifications that affect
FCBS.
(i) Develop additional DT data for published repairs made to modifications that affect
FCBS.
(j) Establish an implementation schedule for DTI for published repairs made to
modifications.
(k) Prepare documentation, submit it to EASA for approval, and make it available to
operators.
4.2. Specific modifications to be considered
The TCH should consider modifications and any STCs they own for modifications that fall
into any of the categories listed in Annex 5 to this Appendix. STCHs should do the same
for their STC modifications. For modifications that are not developed by a TCH or STCH,
the operator should consider whether the modification falls into any of the categories
listed in Annex 5 to this Appendix.
4.3. Modifications and published repairs affecting those modifications that need DT data
Using the guidance provided in AMC 25.571 and the detailed knowledge of the
modification and its effect on the FCBS, the TCH or STCH, or in certain cases the operator,
should consider the following situations in determining what DT data needs to be
developed.
4.3.1. Modifications that affect FCBS
Any modification identified in Annex 5 that is installed on FCBS should be evaluated
regardless of the size or complexity of the modification. In addition, any

AMC 20-20A
modification which indirectly affects FCBS (e.g. modifications which change the
fatigue loads environment, or affect the inspectability of the structure, etc.) must
also have a DTE performed to assess its impact.
4.3.2. Modifications that contain new FCS
For any modification identified in Annex 5 to this Appendix that affects FCBS, the
TCH or STCH should identify any FCS of the modification. Any modification that
contains new FCS should be evaluated regardless of the size or complexity of the
modification. Examples of this type of modification may be a modification that
adds new structural splices, or increases the operational loads causing existing
structure to become fatigue critical. If a modification does not affect FCBS, then it
can be assumed that this modification does not contain FCS.
4.3.3 Published repairs affecting modifications to FCS
Published repair data are generally applicable instructions for accomplishing
repairs, such as those contained in SRMs and SBs. TCHs and STCHs should review
their existing repair data and identify each repair that affects FCMS. The following
examples of published repair data developed by the TCHs and STCHs should be
reviewed and included in this list:
(a) SRMs,
(b) SBs,
(c) documents containing AD-mandated repairs, and
(d) other documents available to operators (e.g. some sections of aircraft
maintenance manuals and component maintenance manuals) that may
contain approved repair data.
4.4. Reviewing existing DT data for modifications that affect FCBS
Based on the CS 25.571 certification amendment level and other existing rules, the
modification’s approval documentation may already provide appropriate DT data.
The TCH or STCH should identify modifications that have existing approved DT data.
Acceptable DT data contains a statement of DTE accomplishment and are approved.
Confirmation that approved DT data exists should be provided to the operators.
Modifications that have been developed by a TCH may affect FCBS. These include design
changes and in some cases STCs. These changes to type design also require review for
appropriate DT data.
4.5. Developing additional DT data for modifications that affect FCBS
DT data may be submitted for approval and published as follows:
(a) STC modifications: Additional DT data for existing modifications may be approved
as a change to an existing STC by the STCH and published, for example, as a
supplement to the ALS. Alternatively, an application can be made to EASA in order
for the data to be submitted to EASA in the form of a specific Part-26 compliance
document, and the resulting approved DTI made available to operators.
(b) TC holder modifications: Additional DT data for existing modifications may be
published in the form of a revised ALS, an SSID and TCH service information.

AMC 20-20A
Note: The TCH and STCH should submit data to EASA that describes and supports
the means used to determine whether a modification affects FCBS, and the means
used for establishing FCS of a modification.
(c) Modifications not developed by a TCH or STCH: For modifications identified in
Annex 5 to this Appendix that affect FCBS and were not developed by a TCH or
STCH, the operator is responsible for obtaining DT data for those modifications.
Operators may establish agreements with DAHs for those existing individual
modifications that do not have DT data or other procedures implemented. In
cooperation with the operator, the DAH should establish DT data according to an
implementation plan approved by the competent authority with respect to the
maintenance programme. Part-26 and CS-26 provide critical timelines for this
activity.
(d) In cases where the threshold inspection of the DTI is likely to have been or soon
will be exceeded by the fleet leaders, an implementation schedule will be needed.
Typically, the proposed grace period should not exceed 24 months.
The approval of the DT data will be according to a process agreed by EASA.
The process for operators to obtain the data and the implementation schedule
should follow that given in paragraph 6.
4.6. Developing additional DT data for published repairs that affect FCMS
For each such repair, unless previously accomplished, the TCH or other DAH must
perform a DTE and develop any necessary DTI for the affected FCBS, and repair data. For
some repairs, the results of the DTE will conclude that no new DTI will be required for the
affected FCBS or repair. For these cases, the TCH or other DAH should provide a means
that informs the operator that a DTE was performed for the subject repair. This may be
accomplished, for example, by providing a statement in a document, such as an SRM,
stating that ‘all the repairs contained in this manual have had a DTE performed’. This is
intended to assist operators in showing compliance with point 26.370 of Part-26 and
prevent them from questioning those repairs that do not have DTIs. TCHs and other DAHs
should provide a list of their published repair data to operators, and a statement that a
DTE has been performed on this data.
5. DEVELOPMENT OF TCH AND STCH DOCUMENTATION AND EASA APPROVAL
TCH, STCHs, operators and the airworthiness authorities should work together to develop
model-specific documentation with oversight provided by those authorities and assistance from
the ARAC AAWG. It is anticipated that TCHs will utilise structural task groups (STGs) to support
their development of model-specific documents. EASA will approve the TCH or STCH
submissions of the REGs and any other associated documentation required by Part-26. In order
to facilitate operators’ compliance with Part-26, the DAHs may find it helpful to consolidate
their compliance data in as few documents as possible, or provide a guide to all the relevant
DT data in a separate communication to operators.
6. OPERATOR TASKS — REPAIRS, MODIFICATIONS AND REPAIRS TO MODIFICATIONS IN
SUPPORT OF COMPLIANCE WITH POINT 26.370 OF PART-26 AND CS 26.370
This paragraph provides guidance to operators for developing a means for addressing the
adverse effects that repairs and modifications may have on FCS. The guidance supports
operators that need to comply with point 26.370 of Part-26, and explains how operators can
develop an implementation plan to obtain and implement all the applicable DT data for

AMC 20-20A
modifications and repairs when using CS 26.370 as a means of compliance. The plan will contain
processes and timelines for operators to use, for obtaining and incorporating into their
maintenance programme, DTIs that address the adverse effects of repairs and modifications.
Operators will need to determine how they will obtain the information necessary to develop
the plan by considering the following conditions:
(a) The operator processes ensure that DT data for repairs and modifications affecting FCBS
have been developed and all the applicable DTIs have been incorporated into the
operator’s maintenance programme. If an operator is able to demonstrate that these
processes have been in place and followed throughout the operational life of the aircraft
for all repairs and modifications affecting FCBS, then no further action is required for
existing repairs and modifications
(b) The TCH or STCH or other DAH exists and will make the DTIs available to the operator
automatically or upon request according to points 26.333 and 36.334 of Part-26
respectively.
(c) DTIs already exist and are available.
(d) DTIs are not available from the TCH or STCH or other DAH;
(e) DTIs are not available for modifications developed by organisations other than TCH or
STC holders (e.g. major changes approved under FAA Form 337, accepted under the
EU-USA bilateral agreement, but that were approved before 14 CFR Part-26 became
applicable).
Figure A3-1 below outlines an overview of developing a means of compliance for
modifications to be addressed by STCHs/TCHs and operators in order to comply with
points 26.306 to 26.309, 26.332 to 26.334 and 26.370 of Part-26.

AMC 20-20A
TCH tasks Operator tasks

• Identify affected aeroplanes • Identify applicable modifications that
• Identify FCBS exist in the operator’s fleet that have
• Identify certification amendment level been embodied in or affect FCBS.
• The operator should identify and
contact the TCH and STCHs for
applicable modifications and request
TCH and STCH tasks — Modifications
DT data for the modifications, unless
• Review EASA approved modification data
it is already available.
and identify modifications that may
affect FCBS.
• Verify applicability of modifications. Do
they:
o affect FCBS?
o create new FCS?
TCH or No Modifications
STCH No
supported by
support? existing
DT data?
Operator establishes
Yes schedule for
obtaining DT data for
Develop the approval by Yes
needed DT data competent authority
TCH or STCH provides
evidence to EASA according
Establish DT data to compliance plan.
implementation
schedule
Complete EASA
documentation
Approval of
document(s)
DAH makes DT
data available to Operator
operator
Figure A3-1: Developing a means of compliance for modifications

AMC 20-20A
6.1. Contents of the maintenance programme

(a) The operator’s maintenance programme should contain or refer to an
implementation plan that ensures that:
(1) all new repairs and modifications that affect FCBS will have DT data and DTI
or other procedures implemented;
(2) all existing repairs and modifications to FCBS have been or will be evaluated
for damage tolerance and have DTI or other procedures implemented. In the
context of this implementation plan, there should be a process that:
(i) reviews operator processes to determine if DT data for repairs and
modifications affecting FCBS have been developed and incorporated
into the operator’s maintenance programme for the operational life
of the aircraft. If an operator is able to demonstrate that these
processes ensure that DT data is developed for all repairs and
modifications affecting FCBS, then no further action is required for
existing repairs and modifications.
(ii) identifies or surveys existing repairs (using the applicable REGs or
survey parameters from Annex 2 to this Appendix) and modifications
that affect FCBS and obtain and implement DTI for those repairs and
modifications. This should include an implementation schedule that
provides timing for incorporation of the DT data into the operator’s
maintenance programme, within the time frame given in the
applicable TCH or STCH’s approved documentation.
(b) Figure A3-2 below outlines one possible means that an operator can use to develop
an implementation plan for aircraft in their fleet.

AMC 20-20A
STCH: Approved documentation for

modifications and repairs
as embodied in specific aircraft serial numbers Operator’s plan for revision of the maintenance
programme
— DTE processes from compliance document(s)
— DTI from compliance document(s)
— Repair survey plan for existing repairs
Operator: Approved documentation for
— Means of identifying through reviewing records
modifications and repairs other than those
or surveying to determine modifications
provided by STCH and TCH
embodied in aircraft
embodied in specific aircraft serial numbers
— Implementation schedule
• aircraft surveys
• repairs
• modifications
• repairs to modifications
TCH:
Approved documentation for repairs and
modifications
for a particular aircraft model
Competent authority approval

of maintenance programme
Figure A3-2: Operator’s maintenance programme approval process

AMC 20-20A
6.1.1. Implementation plan for repairs

Except as described in CS 26.370, the maintenance programme should include a
repair survey schedule to identify repairs that may need DT data developed. The
TCH’s REGs may be used as a basis for this plan. (See Paragraph 3.13 above and
Annex 2 for further information)
6.1.2. Implementation plan and actions for modifications
(a) Points 26.307, 26.308, 26.333 and 26.334 of Part-26 require DAHs to develop
DTI for existing modifications (design changes) within a certain timescale.
CS 26.370 provides means of compliance to operators on how to revise the
maintenance programme by including an implementation plan to show how
approved DTI data will be obtained and used to address the potential
adverse effects of repairs and modifications to FCS and submit it for approval
to the competent authority. To show compliance with CS 26.370, operators
are first requested to develop a list of modifications affecting FCBS through
a review of the aircraft records. The operator will need to show to their
competent authority that the aircraft records are a reliable means for
identifying modifications that affect FCBS. The aircraft records, in
conjunction with data provided by the DAH, may also be sufficient to help
identify whether DTI exists for all modifications. However, for some older
aircraft, a review of records alone may not always be adequate to identify
all the modifications that have an adverse effect on FCBS, or be sufficient to
establish whether a DTE has been accomplished and DTI is complete,
without requesting such information from the DAH. Physical inspection of
the aircraft may help establish the scope of the modification if it is unclear
from the records. Finally, the aircraft survey for repairs may also identify
modifications affecting FCS, which should then be evaluated and DTI
obtained as necessary in accordance with CS 26.370(h).
(b) To support identification of modifications that need to be addressed,
operators should — concurrently with the TCH and STCHs’ tasks — identify
the TCH or STC or other approval holder-developed modifications that exist
in their aircraft fleets. To support compliance with point 26.370 of Part-26
as envisaged in CS 26.370, operators should perform the following tasks:
(1) From the review of records, compile a listing of all TCH and
STCH-developed modifications that are currently installed on their
fleet.
(2) Delete from the listing those modifications that do not affect FCBS.
Documents from the TCH may be used to identify the FCBS.
Note: In order to ensure timely compliance with point 26.370 of
Part-26, operators should begin developing the list of
modifications that affect FCBS, for each affected aircraft in the
fleet, as soon as the TCHs make their FCBS listing available.
(3) The modifications that affect FCBS must be reviewed to determine
whether:
(i) DT data already exists in the maintenance programme, or is
available and is complete; or
(ii) DT data needs to be developed.

AMC 20-20A
(4) For DT data that is complete, the operator should incorporate it into
the maintenance programme and implement it according to the
schedule provided in 6.1.3 or as otherwise agreed by the competent
authority. Note: Complete DTI for STCs approved after
1 September 2003 should be available to operators not later than
30 months after the date of applicability of point 26.370 of Part-26
following approval by EASA unless the STCH no longer exists.
(5) For DT data that is not available or is incomplete 30 months after the
date of applicability of point 26.370 of Part-26, the operator should
ensure that the plan developed according to CS 26.370 will address
each affected modification.
(6) Where DT data is not available or is incomplete, the operator should
notify both the STCH or a third party that DT data for the modification
is required.
(7) Establish whether the STCH or a third party will provide the data.
Note: For modifications addressed by point 26.334 of Part-26 (for
change approvals issued before 1 September 2003), the DAH does not
need to develop the DT data until requested by an operator and has
24 months from that date to submit the data for approval. It is
therefore envisaged that DTI for these modifications will be addressed
in accordance with paragraph (8) and the timescales of 26.370 (h).
Whatever the approval date of the change, the operator is responsible
for obtaining the DTI from the approval holder once it becomes
available. It is therefore recommended that the operator contacts the
approval holder or a third party as soon as possible after identifying a
modification that affects FCBS to establish when the DTI will become
available.
(8) For those modifications where the DTI will not be incorporated into
the maintenance programme within 36 months from the date of
applicability of point 26.370(a)(ii) of Part-26, the operator’s DT data
implementation plan should contain the following information:
(i) a description of the modification;
(ii) the affected aircraft and the affected FCS;
(iii) the DSG of the affected aircraft;
(iv) a list of the FCS introduced by the modification (if it exists);
(v) the CS 25.571 certification level for determining the DT data;
(vi) a plan for obtaining DT data for each modification (e.g. reliance
on the existing STCH or a formal contract with a
Part 21-Subpart J-approved third party) to produce DT data
within a specified compliance time in accordance with
CS 26.370;
(vii) a DT data implementation schedule for incorporating the DT
data into the maintenance programme once it is received;

AMC 20-20A
(viii) a means of ensuring that the aircraft will not be operated

beyond the time limit established for obtaining DT data.
(9) For modifications that are found during the aircraft survey for repairs,
the operator should ensure that DT data is obtained and submitted to
EASA for approval. Once approved, the operator should incorporate
the DTIs into its maintenance programme no later than 12 months
from the date when the modification was identified.
6.1.3. Implementation of DTI
Operators should accomplish the first inspection of a change according to the
approved DTI implementation schedule. If the age of the modification is unknown,
the operator should use the aircraft age in total flight cycles or total flight hours,
as applicable. Where there is any doubt about the applicability of the programme
data or the timescales provided in the DAH documentation, EASA should be
consulted by the operators and competent authorities concerned.
7. ROLE OF THE COMPETENT AUTHORITY
The competent authority’s role is to verify that the AMP is in compliance with point 26.370 of
Part-26 and ensure that their aircraft continuing airworthiness monitoring survey programme
takes into account the risks associated with potential non-compliance of operators’ or owners’
AMPs with the requirements of point 26.370 of Part-26. (Ref. Part-M requirements for the
Competent Authority (M.B.301 and 303)).
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 1 to Appendix 3 to AMC 20-20 Approval process for new

repairs
The approval process for new repairs may use a three-stage approach, as now commonly used in the
aviation industry.
DT data includes inspection requirements, such as the inspection threshold, inspection method, and
inspection repetitive interval, or may specify a time limit when a repair or modification needs to be
replaced or modified. The required data may be submitted all at once, prior to the aircraft’ s return to
service, or it may be submitted in stages. The following three-stage approval process is available,
which involves incremental approval of engineering data to allow an aircraft to return to service
before all the engineering data previously described is submitted. The three stages are described as
follows:
(a) The first stage is the approval of the static strength data and the schedule for submission of the
DT data. This approval is required prior to returning an aircraft to service.
(b) The second stage is approval of the DT data. Sufficient data to substantiate continued safe
operation should be submitted no later than 12 months after the aircraft was returned to
service, unless a temporary limitation was substantiated by sufficient fatigue and damage
tolerance evaluation data and approved at the first stage of approval, in which case the second
stage DT data should be approved before the temporary limit is reached. At the second stage,
the DT data need only contain the threshold when inspections are required to begin as long as
a process is in place to develop the required inspection method and repetitive intervals before
the threshold is reached. In this case, the submission and approval of the remaining DT data
may be deferred to the third stage. The approved threshold acts as a limitation on the repair
data.
(c) The third stage is approval of the inspection method and the repetitive intervals. This final
element of the repair certification data in compliance with CS 25.571 should be submitted and
approved prior to the inspection threshold being reached.
The applicant should inform the operator if this process is being used, and of the expected timelines
for the delivery of the data. To follow the three-stage process, the DAHs subject to Part 21 will need
to establish procedures to be accepted by EASA under their design organisation approvals.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 2 to Appendix 3 to AMC 20-20A Assessment of existing

repairs
A DTI assessment process consists of an aircraft repair survey, identification and disposition of repairs
requiring immediate action and development of damage-tolerance-based inspections, as described
below:
1. AIRCRAFT REPAIR SURVEY
A survey will be used to identify existing repairs and repair configurations on all FCS and provide
a means to categorise those repairs. The survey would apply to all affected aircraft in an
operator’s fleet, as defined in the maintenance programme, using the process contained in the
REGs or similar documents. The procedure to identify repairs that require DTE should be
developed and documented using CS 25.571 and AMC 25.571 (dependent on aircraft
certification level), together with additional guidance specific to repairs, such as:
(a) Size of the repair;
(b) Repair configuration:
(1) SRM standards,
(2) other;
(c) Proximity to other repairs; and
(d) Potential effect on FCS:
(1) inspectability (access and method),
(2) load distribution.
See Paragraph 4 of this Annex for more details.
2. IDENTIFICATION AND DISPOSITION OF REPAIRS REQUIRING IMMEDIATE ACTION
Certain repairs may not meet the minimum requirements because of cracking, corrosion, dents,
or inadequate design. The operator should use the guidance provided in the compliance
document to identify these repairs and, once they are identified, take appropriate corrective
action. In some cases, modifications may need to be made before further flights. The operator
should consider establishing a fleet campaign if similar repairs may have been installed on other
aircraft.
3. DAMAGE TOLERANCE INSPECTION DEVELOPMENT
This includes the development of the appropriate maintenance plan for the repair under
consideration. During this step determine the inspection method, threshold, and repeat
interval. Determine this information from existing guidance information as documented in the
RAG (see Paragraph 4), the REGs or from the results of an individual DTE performed using the
guidance in AMC 25.571. Then determine the feasibility of an inspection programme to
maintain continued airworthiness. If the inspection programme is practical, incorporate the DTI
into the individual aircraft maintenance programme. If the inspection is either impractical or
impossible, incorporate a replacement time for the repair into the individual aircraft
maintenance programme. The three-stage approach discussed in Annex 1 to this Appendix may
be used, if appropriate.

AMC 20-20A
4. REPAIR ASSESSMENT GUIDELINES

4.1. Criteria to assist in developing the repair assessment guidelines
The following criteria are those developed for the fuselage pressure boundary, similar to
those found in FAA AC 120-73 and previous JAA and EASA documentation. DAHs may find
it appropriate to develop similar practices for other types of aircraft and areas of the
structure.
The purpose is to develop repair assessment guidelines requiring specific maintenance
programmes, if necessary, to maintain the damage tolerance integrity of the repaired
airframe. The following criteria have been developed to assist in the development of that
guidance material:
(a) Specific repair size limits for which no assessment is necessary may be selected for
each model of aircraft and structural location. This will enable to minimise the
burden on the operator while ensuring that the aircraft’s baseline inspection
programme remains valid.
(b) Repairs that are not in accordance with SRM must be reviewed and may require
further action.
(c) Repairs must be reviewed where the repair has been installed in accordance with
SRM data that has been superseded or rendered inactive by new damage-tolerant
designs.
(d) Repairs in close proximity to other repairs or modifications require review to
determine their impact on the continued airworthiness of the aircraft.
(e) Repairs that exhibit structural distress should be replaced before further flights.
4.2. Repair assessment methodology
The next step is to develop a repair assessment methodology that is effective in
evaluating the continued airworthiness of existing repairs for the fuselage pressure
boundary. Older aircraft models may have many structural repairs, so the efficiency of
the assessment procedure is an important consideration. In the past, evaluation of
repairs for damage tolerance would require direct assistance from the DAH. Considering
that each repair design is different, that each aircraft model is different, that each area
of the aircraft is subjected to a different loading environment, and that the number of
engineers qualified to perform a damage tolerance assessment is small, the size of an
assessment task conducted in that way would be unmanageable. Therefore, a new
approach has been developed as an alternative.
Since repair assessment results will depend on the model-specific structure and loading
environment, the DAHs should create an assessment methodology for the types of
repairs expected to be found on each affected aircraft model. Since the records on most
of these repairs are not readily available, locating the repairs will necessitate surveying
the structure of each aircraft. A survey form is created by the DAH that may be used to
record key repair design features needed to accomplish a repair assessment. Airline
personnel not trained as damage tolerance specialists can use this form to document the
configuration of each observed repair.
Some DAHs have developed simplified methods using the information from the survey
form as input data, to determine the damage tolerance characteristics of the surveyed
repairs. Although the repair assessments should be performed by well-trained personnel
familiar with the model-specific repair assessment guidelines, these methods enable

AMC 20-20A
appropriate staff, not trained as damage tolerance specialists, to perform the repair
assessment without the assistance of the TCH. This methodology should be generated by
the aircraft TCH. Model-specific repair assessment guidelines will be prepared by the
TCHs.
From the information on the survey form, it is also possible to classify repairs into one of
three categories:
Category A: A permanent repair for which the baseline zonal inspection (BZI) (typical
maintenance inspection intervals assumed to be performed by most
operators) is adequate to ensure continued airworthiness.
Category B: A permanent repair that requires supplemental inspections to ensure
continued airworthiness.
Category C: A temporary repair that will need to be reworked or replaced prior to an
established time limit. Supplemental inspections may be necessary to
ensure continued airworthiness prior to this limit.
When the LOV of the maintenance programme is extended, the initial categorisation of
repairs may need a review by the applicant for the LOV extension, and the operator may
need to ensure that these remain valid up to the new LOV.
4.3. Repair assessment process
There are two principal techniques that can be used to accomplish the repair assessment.
The first technique involves a three-stage procedure. This technique could be well-suited
for operators of small fleets. The second technique involves the incorporation of the
repair assessment guidelines as part of an operator’s routine maintenance programme.
This approach could be well-suited for operators of large fleets and would evaluate
repairs at predetermined planned maintenance visits as part of the maintenance
programme.
The first technique generally involves the execution of the following three stages (see
Figure A3(2)-1):
Stage 1: Data collection
This stage specifies what structure should be assessed for repairs and collects data for
further analysis. If a repair is on a structure in an area of concern, the analysis continues,
otherwise the repair does not require classification per this programme.
Repair assessment guidelines for each model will provide a list of structure for which
repair assessments are required. Some DAHs have reduced this list by determining the
inspection requirements for critical details. If the requirements are equal to normal
maintenance checks (e.g. BZI checks), those details may be excluded from this list.
Repair details are collected for further analysis in Stage 2. Repairs that do not meet the
minimum design requirements or are significantly degraded are immediately identified,
and corrective actions must be taken before further flights.
Stage 2: Repair categorisation
The repair categorisation is accomplished by using the data gathered in Stage 1 to answer
simple questions regarding structural characteristics.
If the maintenance programme is at least as rigorous as the BZI identified in the TCH’s
model-specific repair assessment guidelines, well-designed repairs in good condition

AMC 20-20A
meeting size and proximity requirements are Category A. Simple condition and design
criteria questions are provided in Stage 2 to define the lower bounds of Category B and
C repairs. The process continues for Category B and C repairs.
STAGE 1
AREA/COMPONENT
LOCATION
AREA WITH NO AREA WITH NEED

NEED FOR FOR EVALUATION
EVALUATION
STAGE 2
REPAIR
CATEGORISATION
CATEGORY A CATEGORY B CATEGORY C
STAGE 3
INSPECTION/REPLACEMENT
REQUIREMENTS
INSPECTIONS APPLY GUIDELINES IN REPAIR GUIDELINES CANNOT BE

REQUIREMENTS DOCUMENT TO DETERMINE APPLIED. SEND DETAILS TO
DEFINED IN SRM INSPECTION REQUIREMENTS MANUFACTURER FOR
ASSESSMENT
Figure A3(2)-1: Repair assessment stages
Stage 3: Determination of structural maintenance requirements

The specific supplemental inspection and/or replacement requirements for Category B
and C repairs are determined in this stage. Inspection requirements for the repair are
determined by calculation or by using predetermined values provided by the DAH, or
other values obtained using an EASA-approved method.

AMC 20-20A
In evaluating the first supplemental inspection, Stage 3 will define the inspection
threshold in flight cycles measured from the time of the repair installation. If the time of
the repair installation is unknown and the aircraft has exceeded the assessment
implementation times or has exceeded the time for first inspection, the first inspection
should occur by the next ‘C-check’ interval, or equivalent cycle limit after the repair data
is gathered (Stage 1).
The operator may choose to accomplish all three stages at once, or just Stage 1. In the
latter case, the operator would be required to adhere to the schedule specified in the
EASA-approved model-specific repair assessment guidelines for completion of Stages 2
and 3. Incorporating the maintenance requirements for Category B and C repairs into an
operator’s individual aircraft maintenance or inspection programme completes the repair
assessment process for the first technique.
The second technique would involve setting up a repair maintenance programme to
evaluate all the applicable structures as detailed in paragraph 1 at each predetermined
maintenance visit to confirm that they are permanent. This technique would require the
operator to choose an inspection method and interval in accordance with the
EASA-approved repair assessment guidelines. The repairs whose inspection requirements
are fulfilled by the chosen inspection method and interval would be inspected in
accordance with the approved maintenance programme. Any repair that is not
permanent, or whose inspection requirements are not fulfilled by the chosen inspection
method and interval, would either be:
(a) upgraded to allow utilisation of the chosen inspection method and interval; or
(b) individually tracked to account for the repair’s unique inspection method and
interval requirements.
This process is then repeated at the chosen inspection interval.
Repairs added between the predetermined maintenance visits, including interim repairs
installed at remote locations, would be required either to have a threshold greater than
the length of the predetermined maintenance visit or to be tracked individually to
account for the repair’s unique inspection method and interval requirements. This would
ensure the airworthiness of the structure until the next predetermined maintenance visit,
at which time the repair would be evaluated as part of the repair maintenance
programme.
5. MAINTENANCE PROGRAMME CHANGES
When a maintenance or inspection programme interval is revised, the operator should evaluate
the impact of the change on the repair assessment programme. If the revised maintenance or
inspection programme intervals are greater than those in the BZI, the previous classification of
Category A repairs may become invalid. The operator may need to obtain approval of an
alternative inspection method, upgrade the repair to allow utilisation of the chosen inspection
method and interval, or re-categorise some repairs and establish unique supplemental
inspection methods and intervals for specific repairs. Operators using the ‘second technique’ of
conducting repetitive repair assessments at predetermined maintenance visits would evaluate
whether the change to the predetermined maintenance visit continues to fulfil the repair
inspection requirements.
6. SRM UPDATE
The general section of each SRM will contain brief descriptions of damage tolerance
considerations, categories of repairs, description of BZIs, and the repair assessment logic

AMC 20-20A
diagram. In updating each SRM, existing location-specific repairs should be labelled with
appropriate repair category identification (A, B or C), and specific inspection requirements for
B and C repairs should also be provided as applicable. SRM descriptions of generic repairs will
also contain repair category considerations regarding size, zone, and proximity. Detailed
information for the determination of inspection requirements will have to be provided for each
model. Repairs which were installed in accordance with a previous revision of the SRM, but
which have now been superseded by a new damage-tolerant design, will require review. Such
repairs may be reclassified to Category B or C, requiring additional inspections and/or rework.
7. STRUCTURE MODIFIED BY AN STC
The current repair assessment guidelines provided by the TCH are not always applicable to
structure modified by an STC. Nonetheless, it is expected that all the structure modified by an
STC should be evaluated by the operator and, if possible, in conjunction with the STCH.
Point 26.370 of Part-26 requires the operator to amend their maintenance programme to
address all such repairs, and a conservative extension of the TCH’s REGs to all STCs containing
FCS can be envisaged to ensure that all repairs to FCS are identified. Subsequently, each repair
can be subjected to a DTE, and DTI be provided with the support of a DAH. The STCH should
conduct specific damage tolerance assessments of known published repairs (SRM, SBs, etc.) and
provide appropriate instructions to the operator.
It is expected that the STCH will assist the operators by preparing the required documents. If
the STCH is no longer in business, or is otherwise unable to provide assistance, the operator
would have to acquire the EASA-approved guidelines independently. Ultimately, the operator
remains responsible for the continued safe operation of the aircraft.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 3 to Appendix 3 to AMC 20-20A Repairs and modifications to

removable structural components
1. DETERMINING THE AGE OF A REMOVABLE STRUCTURAL COMPONENT

Determining the actual component’s age or assigning a conservative age provides flexibility and
reduces operator burden when implementing DT data for repairs and modifications to
structural components. In some cases, the actual component’s age may be determined from
records. If the actual age cannot be determined this way, the component’s age may be
conservatively assigned using one of the following fleet leader concepts, depending upon the
origin of the component:
(a) If component times are not available, but records indicate that no part changes have
occurred, aircraft flight cycles or flight hours can be used.
(b) If no records are available, and the parts could have been switched from one or more
older aircraft under the same maintenance programme, it should be assumed that the
time on any component is equal to the oldest aircraft in the programme. If this is
unknown, the time should be assumed to be equal to the same model aircraft that is the
oldest or has the most flight cycles or flight hours in the world fleet.
(c) A manufacturing date marked on a component may also be used to help establish the
component’s age in flight cycles or flight hours. This can be done by using the above
reasoning and comparing it to aircraft in the affected fleet with the same or older
manufacturing date.
If none of these options can be used to determine or assign a component age or total number
of flight cycles or flight hours, a conservative implementation schedule can be established by
using the guidelines applied in paragraph 3 of this Appendix, for the initial inspection, if required
by the DT data.
2. TRACKING
An effective control or tracking system should be established for removable structural
components that are identified as FCBS or that contain FCS. This will help ensure compliance
with the maintenance programme’s requirements specific to repairs and modifications installed
on an affected removable structural component. Paragraph 4 of this Appendix provides options
that could be used to alleviate some of the burden associated with tracking all repairs to
affected removable structural components.
3. DEVELOPING AND IMPLEMENTING DT DATA
(a) Repairs
Accomplish the initial repair assessment of the affected structural component at the
same time as the aircraft level repair survey for the aircraft on which the component is
installed. Develop the DT data according to the process given in Annex 2 and incorporate
DTI into the maintenance programme.
(b) Modifications
Accomplish the initial modification assessment of the affected structural component at
the same time as the aircraft level modification assessment for the aircraft on which the
component is installed. Develop DT data and incorporate the DTI into the maintenance
programme.

AMC 20-20A
If the actual age of the repairs or modifications installation, or the total number of flight
cycles or flight hours is known, use that information to establish when the initial
inspection of the component should be performed. Repeat the inspection at the intervals
provided by the TCH or STCH for the repair or modification against the component.
If the actual age of the repairs or modifications installation, or the total number of flight
cycles or flight hours is unknown, but the component’s age or total number of flight cycles
or flight hours is known, or can be assigned conservatively, use the component’s age, or
the total number of flight cycles or flight hours to establish when the initial inspection of
the component should be performed. Repeat the inspection at the intervals provided by
the TCH or STCH for the repairs and modifications against the component.
As an option, accomplish the initial inspection on the affected component at the next
C-check (or equivalent interval) following the repair assessment. Repeat the inspection
at the intervals provided by the TCH or STCH for the repairs and modifications against the
component.
4. EXISTING REPAIRS AND MODIFICATIONS — COMPONENTS RETRIEVED FROM STORAGE
(a) If the time on the component (in flight cycles or flight hours) is known, or can be
conservatively assigned, perform the following:
(1) survey the component;
(2) dispose repairs and modifications;
(3) implement any DTI in accordance with the approved schedule;
(4) accomplish the initial inspection using the actual age of the repairs or
modifications, or the total number of flight cycles or flight hours, if known. If the
age of the repairs or modifications is not known, use the component’s age. Repeat
the inspection at the intervals given for the repairs or modifications against the
component.
(b) If the time on the component (in flight cycles or flight hours) is unknown and cannot be
conservatively assigned, perform the initial repair or modification assessment of the
affected component prior to installation, and perform the following actions:
(1) develop DT data according to the process given in paragraph 3 or 4 of Appendix 3
to this AMC as applicable;
(2) incorporate any DTI into the maintenance programme;
(3) accomplish the first inspection on the affected component at the next C-check (or
equivalent interval) following the repair or modification assessment;
(4) repeat the inspection at the intervals given for the repair or modification against
the component.
5. IMPLEMENTATION OPTIONS TO HELP REDUCE TRACKING BURDEN
The following implementation techniques could be used to alleviate some of the burden
associated with tracking repairs to affected removable structural components. These
techniques, if used, would need to be included in the maintenance programme and may require
additional EASA approval and TCH or STCH input for DTI.
(a) Upgrading existing repairs
As an option, existing repairs may be removed and replaced with new parts of the same
design revised as necessary to support the new installation. This practice would permit

AMC 20-20A
the DTI requirements of the repair to be set to zero and to re-establish an initial tracking
point for the repair. Normally, this would be done at or before the survey for maximum
benefit. The initial and repetitive inspections for the upgraded repair would then be
accomplished at the intervals given for the repair against the component.
A repair could also be upgraded to one whose inspection requirements and methods are
already fulfilled by an operator’s maintenance or inspection programme. That repair
would then be repetitively inspected at each routine inspection interval applicable to the
repair. Specific tracking would not be required because that area of the aircraft would
have already been normally inspected on each aircraft in the fleet as part of the existing
approved maintenance programme. If the operator’s programme intervals were
changed, the effect on requirements for specific tracking would have to be re-evaluated.
(b) Special initial and/or routine inspections
As an option, existing repairs may have special initial inspections accomplished during the
component survey. This initial inspection establishes an initial tracking point for the
repair. Following this initial inspection, the DTI requirements (e.g. repetitive inspections)
of the repair would be implemented.
In addition, special routine inspections could be defined for typical repairs that could be
applied at a normal interval. In this case, an operator could check the affected
components on each aircraft for this type of a repair at the defined interval. If the repair
is found, the special inspection would be applied to ensure its airworthiness until the next
scheduled check. This alleviates the need to specifically track affected components for
every repair, especially typical ones.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 4 to Appendix 3 to AMC 20-20A Service bulletin review

process
Guidelines for following the service bulletin (SB) flow chart

Note: While it is believed that this guidance is fairly comprehensive, it may not address every possible
situation. It is therefore incumbent on the user to use good judgement and rationale when making
any determination.
Screening SBs to determine which ones require DT data is primarily a TCH responsibility.
The result of this screening is a list of SBs which require special directed inspections to ensure
continued airworthiness. SBs included in the list will be grouped into Type I and Type II SBs. Type I SBs
have existing DT data and Type II SBs require developing DT data. The list is not comprehensive and
will not include all the SBs associated with an aircraft. The list does not need to include those SBs
where the inspection programme developed for the repair assessment programme has been
determined to be sufficient to meet the damage tolerance requirements for the FCBS that is affected
by the SB.
To ensure compliance with Part-26, any DTI identified in the existing programme that is required to
continue to be implemented to satisfy point 26.370 should be identified as such in the ICA.
Query 1 Does the SB address a structural repair or a modification to FCS?
Historically, any SB, service letter or other document that lists ATA Chapters 51 through 57
could provide repair or modification instructions that may require DT data. In addition,
certain repairs or modifications accomplished under other ATA chapters may affect FCS.
The first step in the screening process is to identify all such service instructions and develop
a list of candidates for review (Q2).
Query 2 Does the service instruction specify either a repair or modification that creates or affects
FCS?
If it does, then the service instruction requires further review (Q3). If it does not, then the
service instruction does not require further review.
Query 3 Is the service instruction mandated?
SBs and other service instructions that are mandated by an AD have requirements to ensure
inspection findings (e.g., detected cracks or other structural damage/degradation) are
addressed in an approved manner. If the TCH can demonstrate that it applies a process for
developing inspection programmes for mandated SBs using DT data and/or service-based
inspection results, and for continuously reviewing the SBs for their adequacy to detect
cracks in a timely manner, the mandated SBs should then be considered as compliant with
the intent of this process. Otherwise, the TCH will need to demonstrate that the inspection
programme in the mandated SB has been developed using DT data and/or appropriate
service-based inspection results. The outcome of Query 3 branches to two unrelated boxes
(Q4: if mandated by an AD, or Q7: if not mandated by an AD).
Query 4 Does the SB or service instruction contain terminating action?
Query 3 established that the inspection programme for the baseline configuration is
acceptable.
Query 5 Does the terminating action have DT data?

AMC 20-20A
If the terminating action has a documented continuing airworthiness inspection

programme based on damage tolerance principles, then no further review is required. The
SB should be documented in the list. If the terminating action does not have DT data, or
the status of the inspection programme cannot be verified, then further review is necessary
(Q6).
Query 6 Does the SB address a safe-life part?
If it does, no further action is required. Otherwise, damage-tolerance-based inspections
will need to be developed and provided to the operators. The SB should be included in the
list along with where to find the required continued airworthiness inspection programme.
Query 7 In Query 3 a structural SB that was mandated by AD was identified.
Query 7 asks if a one-time inspection is required to satisfy the intent of the requirement. If
it does, it is deemed that this is being done to verify that a condition does not exist and, on
finding that condition, correct that condition to baseline configuration. As such, normal
SSID programmes would then be expected to cover any required continued airworthiness
inspections. If a repair is necessary, it is further assumed that this was done by reference
to the SRM or other suitable means. No further action is required if this is the case and, if
a repair was necessary, other means exist to determine the required DT data. If no
inspections or multiple inspections are required, additional evaluation is required (Q8).
Query 8 Is this a major structural design change (e.g. modification)?
This is a TCH decision that is part of the original certification process and is not a
major/minor repair decision. If it is not a major design change, then proceed to Q10; if not,
proceed to Q9.
Query 9 Does the change require NDIs to verify the integrity of the structure or are normal routine
maintenance inspections sufficient?
This is a subjective question and may require re-evaluating the change and determining
where specific fatigue cracking might be expected. If normal maintenance inspections are
adequate, no further action is required. Otherwise, proceed to Q10.
Query 10: Does the SB contain DT data for both the baseline and modified aircraft configurations?
If so, the SB is satisfactory. Otherwise, damage-tolerance-based inspections will need to be
developed and provided to the operators. The SB should be documented in the list along
with where to find the required continued airworthiness inspection programme.
SB screening procedure
1. The TCH will perform the screening and the Structures Task Group will validate the results.
2. A list of all SBs requiring action will be included in the TCH compliance document. Those not
requiring action will not be included in the list.
3. SBs included in the list will fall into one of two general types:
Type I — SBs which have existing DT data.
Type II — SBs that require developing DT data.
4. TCH actions:
Type I — No action required.
Type II — Develop DT data and make it available to operators.

AMC 20-20A
5. Operator actions (apply to both SB types):

— Review SB incorporation on a tail number basis.
— For incorporated SBs that rely on BZI (i.e. no special inspections required based on DTE
performed), reconcile any maintenance planning document structural inspection
escalations.
— For incorporated SBs that require DTI, verify that DTI has been included in the operations
specification and include it if it is missing.
Figure A3(4)-1: SB flow chart
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 5 to Appendix 3 to AMC 20-20A List of major changes and

STCs that may adversely affect fatigue-critical structure
(1) Passenger-to-freighter conversions (including addition of main deck cargo doors).

(2) Gross weight increases (increased operating weights, increased zero fuel weights, increased
landing weights, and increased maximum take-off weights).
(3) Installation of fuselage cut-outs (passenger entry doors, emergency exit doors or crew escape
hatches, fuselage access doors, and cabin window relocations).
(4) Complete re-engine or pylon modifications.
(5) Engine hush kits.
(6) Wing modifications such as installing winglets or changes in flight control settings (flap droop),
and modification of wing trailing edge structure.
(7) Modified skin splices.
(8) Antenna installations.
(9) Any modification that affects several stringer or frame bays.
(10) Any modification that covers structure requiring periodic inspection by the operator’s
maintenance programme.
(11) Any modification that results in operational mission change that significantly changes the
manufacturer’s load or stress spectrum (e.g. passenger-to-freighter conversion).
(12) Any modification that changes areas of the fuselage that prevents external visual inspection
(e.g. installation of a large external fuselage doubler that results in hiding details beneath it).
(13) In general, attachment of interior monuments to FCS. Interior monuments include large items
of mass such as galleys, closets, and lavatories.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Annex 6 to Appendix 3 to AMC 20-20A Background to the need for

damage-tolerance-based inspection programmes for repairs
Repairs are a concern on older aircraft because of the possibility that they may develop, cause, or
obscure metal fatigue, corrosion, or other damage during service. This damage might occur within the
repair itself or in the adjacent structure, and might ultimately lead to structural failure.
In general, repairs present a more challenging problem to solve than the original structure because
they are unique and tailored in design to correct particular damage to the original structure. While
the performance of the original structure may be predicted from tests and from experience on other
aircraft in service, the behaviour of a repair and its effect on the fatigue characteristics of the original
structure are generally known to a lesser extent than for the basic unrepaired structure.
Repairs may be of concern as time in service increases for the following reasons:
As aircraft age, both the number and age of the existing repairs increase. Along with this increase is
the possibility of unforeseen repair interaction, failure, or other damage occurring in the repaired
area. The continued operational safety of these aircraft depends primarily on a satisfactory
maintenance programme (with inspections conducted at the right time, in the right place, using the
most appropriate technique, or in some cases, replacement of the repair). To develop this programme,
a DTE of repairs to aircraft structure is essential. The longer an aircraft is in service, the more important
this evaluation and a subsequent inspection programme become.
The practice of repair justification has evolved gradually over the last 20 years. Some repairs described
in the aircraft manufacturers’ SRMs were not designed in accordance with fatigue and damage
tolerance principles (Ref. AAWG Report: Recommendations concerning ARAC taskings FR
Doc 04-10816; Aging Aircraft Safety Final Rule. 14 CFR 121.370a and 129.16.). Repairs accomplished
in accordance with the information contained in the early versions of the SRMs may require additional
inspections if evaluated using the fatigue and damage tolerance methodology.
Damage tolerance is a structural design and inspection methodology used to maintain safety by
considering the possibility of metal fatigue or other structural damage (i.e. safety is maintained by
adequate structural inspection until the damage is repaired). One prerequisite for the successful
application of the damage tolerance approach for managing fatigue is that crack growth and residual
strength can be anticipated with sufficient precision to allow inspections to be established that will
detect cracking before it reaches a size that will degrade the strength to less than a specified level. A
DTE entails the prediction of sites where fatigue cracks are most likely to initiate in the aircraft’s
structure, the prediction of the crack path and rates of growth under repeated aircraft structural
loading, the prediction of the size of the damage at which strength limits are exceeded, and an analysis
of the potential opportunities for inspection of the damage as it progresses. This information is used
to establish an inspection programme for the structure that will be able to detect cracking that may
develop before it could contribute to a catastrophic failure.
The evidence to date is that when all the critical structure is included, damage-tolerance-based
inspections and procedures, including modification and replacement, provide the best assurance of
continued structural integrity that is currently available. In order to apply this concept to existing
transport aeroplanes, the competent authorities have issued a series of ADs requiring compliance with
the first supplemental inspection programmes resulting from the application of this concept to
existing aeroplanes. Generally, these ADs require that operators incorporate SSIDs into their
maintenance programmes for the affected aeroplanes. These documents were derived from damage
tolerance assessments of the originally certified type designs for these aeroplanes. For this reason,
the majority of ADs written for the SSIP did not attempt to address the issues related to the damage

AMC 20-20A
tolerance of repairs that had been made to the aeroplanes. The objective of repair assessment and
repair evaluation guidelines is to provide the same level of assurance for areas of the structure that
have been repaired as that achieved by the SSIP for the baseline structure as originally certified.
[AMC 20/20]

AMC 20-20A

corrosion prevention control programme
1. GENERAL
The TCH should develop a baseline CPCP, which should be reviewed by EASA. The baseline CPCP
is intended to facilitate the development of a CPCP by an operator for their maintenance
programme.
The operator should include a CPCP in the maintenance programme, and where a TCH baseline
CPCP exists, it should be taken into account in the development of the operator’s CPCP. The
operator should show that the CPCP is comprehensive in that it addresses all the corrosion likely
to affect primary structure, and is systematic in that:
(a) it provides step-by-step procedures that are applied on a regular basis to each identified
task area or zone, and
(b) these procedures are adjusted when they result in evidence that corrosion is not being
controlled to an established acceptable level (Level 1 or better).
1.1 Purpose
This Appendix gives guidance to operators and DAHs who are developing and
implementing a CPCP for aeroplanes maintained in accordance with an aircraft
maintenance programme developed in compliance with point M.A.302 of Part-M.
CPCPs have been developed by the DAH with the assistance of aircraft operators and
competent authorities. They relied heavily on service experience to establish CPCP
implementation thresholds and repeat intervals. Since that time a logical evaluation
process has been developed to ensure environmental damage is considered in the
evaluation of aircraft structure. This process is identified in ATA MSG-3 Scheduled
maintenance development document, which introduced the CPCP concept in revision 2,
circa 1993.
1.2 Approval
Approval of a TCH CPCP may either be through the MRB (ISC) using existing procedures
for EASA MRBR approval, or directly by EASA if no EASA-approved MRBR exists for the
type. Provided that the operator has an NAA-approved aircraft maintenance programme
(AMP) that controls corrosion to Level 1 or better, the operator need not follow exactly
the programme offered by the TCH. However, revisions to the TCH’s approved
programme should be considered by the operator for incorporation in the operator’s MP
under the Part-M requirements.
2. DEFINITIONS
— Allowable Limit: this is the amount of material (usually expressed in the thickness of the
material) that may be removed or blended out without affecting the ultimate design
strength capability of the structural member. Allowable limits may be established by the
TCH/DAH. EASA may also establish allowable limits. The DAH normally publishes
allowable limits in the SRM or in SBs. Note: This revision of the AMC amends the definition
of corrosion levels such that the concept of local and widespread corrosion is no longer
specified. Nonetheless, when deriving allowable limits for the structure and the adjacent
structure, the full extent of the damage and material removed in the finding and the
previous findings affecting the same areas must be taken into account. Applicable fatigue

AMC 20-20A
and damage tolerance requirements must be taken into account when establishing the
allowable limits.
— Baseline CPCP: this is a CPCP developed for a specific model aeroplane. The TCH typically
develops the baseline CPCP (see TCH-developed baseline CPCP below). It contains the
corrosion inspection tasks, an implementation threshold, and a repeat interval for task
accomplishment in each area or zone.
— Basic task(s): this is a specific and fundamental set of work elements that should be
performed repetitively in all task areas or zones to successfully control corrosion. The
contents of the basic task may vary depending upon the specific requirements in an
aeroplane area or zone. The basic task is developed to protect the primary structure of
the aeroplane.
— Corrosion prevention and control programme (CPCP): this is a comprehensive and
systematic approach to controlling corrosion in such a way that the load carrying
capability of an aircraft structure is not degraded to less than a level necessary to
maintain airworthiness. It is based upon the baseline CPCP described above. A CPCP
consists of a basic corrosion inspection task, task areas, defined corrosion levels, and
compliance times (implementation thresholds and repeat intervals).
The CPCP also includes procedures to notify the competent authority of the findings and
data associated with Level 2 and Level 3 corrosion and the actions taken to reduce future
findings to Level 1.
— Implementation threshold (IT): this is the aircraft age associated with the first time the
basic corrosion inspection task should be accomplished in an area or zone.
— Level 1 corrosion is:
Damage occurring between successive inspections that is within the allowable damage
limits; or
Damage occurring between successive inspections that does not require structural
reinforcement, replacement or new damage-tolerance-based inspections; or
Corrosion occurring between successive inspections that exceeds the allowable limits but
can be attributed to an event not typical of operator usage of other aircraft in the same
fleet; or
Light corrosion occurring repeatedly between inspections that eventually requires
structural reinforcement, replacement, or new damage-tolerance-based inspections.
— Level 2 corrosion is any corrosion finding that exceeds Level 1, requiring a review of the
operator’s CPCP effectiveness, but that is not determined to be Level 3.
The operator is responsible for making the initial determination of the corrosion level,
and this may subsequently be adjusted based on consultation with the DAH.
A finding of Level 2 corrosion requires repair, reinforcement, or complete or partial
replacement of the applicable structure, or revised fatigue and damage tolerance
inspections.
Note: A statement of fact in previously mandated CPCPs states: corrosion findings that
were discovered during the corrosion inspection task accomplished at the
implementation threshold, and which require repair, reinforcement, or complete or
partial replacement of the applicable structure, should not be used as an indicator of the
effectiveness of the operator’s CPCP. The argument is that an operator’s corrosion

AMC 20-20A
programme effectiveness can only be determined after a repeat inspection has been
performed in a given inspection task area. This argument is valid for aircraft with
mandated CPCPs introduced after the aircraft has been in service for a number of years
without a CPCP. This argument, however, is not valid for aircraft that have been
maintained since entry into service using a CPCP that takes into account the TCH baseline
CPCP and environmental deterioration (ED) programme. Consequently, corrosion
findings exceeding Level 1 found on the corrosion inspection task implementation
threshold may indicate that the threshold has been set too high and action should be
taken to adjust the implementation threshold.
— Level 3 corrosion is that corrosion occurring during the first or subsequent
accomplishments of an inspection task that the operator or subsequently the TCH or
competent authority determines to be an urgent airworthiness concern.
Note: If Level 3 corrosion is determined at the implementation threshold or any repeat
inspection, then it should be reported. Any corrosion that is more than the maximum
acceptable to the DAH or EASA must be reported in accordance with the current
regulations. This determination should be conducted jointly with the DAH.
— Light corrosion is corrosion damage so slight that removal and blend-out over multiple
repeat intervals may be accomplished before material loss exceeds the allowable limit.
— Local corrosion. Generally, local corrosion is corrosion of a skin or web (wing, fuselage,
empennage or strut) that does not exceed one frame, stringer, or stiffener bay. Local
corrosion is typically limited to a single frame, chord, stringer or stiffener, or corrosion of
more than one frame, chord, stringer or stiffener where no corrosion exists on two
adjacent members on each side of the corroded member.
— Operator-developed programme. In order to operate an aeroplane in compliance with
the maintenance programme of Part-M and Part-26, an operator should include in their
maintenance or inspection programme an approved CPCP. An operator may adopt the
baseline CPCP provided by the DAH or they may choose to develop their own CPCP, or
may be required to if none is available from the DAH. In developing their own CPCP, an
operator may join with other operators and develop a baseline CPCP similar to a
TCH-developed baseline CPCP for use by all operators in the group. The advantages of an
operator-developed baseline CPCP are that it provides a common basis for all operators
in the group to develop their CPCP and it provides a broader experience base for
development of the corrosion inspection tasks and identification of the task areas.
— Repeat Interval (RI): this is the calendar time between the accomplishment of successive
corrosion inspection tasks for a task area or zone.
— Task area: this is a region of aircraft structure to which one or more corrosion inspection
tasks are assigned. The task area may also be referred to as a zone.
— TCH-developed baseline CPCP. The baseline CPCP may be developed as an integral part
of the ICA or in a stand-alone section or manual. The TCH should provide an inspection
programme that includes the frequency and extent of inspections necessary to ensure
the continued airworthiness of the aircraft. Furthermore, the programme should include
the information needed to apply protective treatments to the structure after inspection.
In order for the inspections to be effectively accomplished, the TCH should include, in the
ICA, corrosion removal and cleaning procedures and reference allowable limits. The
baseline CPCP is intended to facilitate the operator’s development of a CPCP for their
maintenance programme.

AMC 20-20A
— Urgent airworthiness concern: this is damage that could jeopardise continued safe
operation of any aircraft. An urgent airworthiness concern typically requires correction
before the next flight and expeditious action to inspect the other aircraft in the operator’s
fleet.
— Widespread corrosion: this is corrosion of two or more adjacent skin or web bays (a web
bay is defined by frame, stringer or stiffener spacing). Or widespread corrosion is
corrosion of two or more adjacent frames, chords, stringers, or stiffeners. Or widespread
corrosion is corrosion of a frame, chord, stringer, or stiffener and an adjacent skin or web
bay.
— Zone. See ‘Task area’.
3. DEVELOPMENT OF A BASELINE CPCP
3.1. Baseline CPCP
The objective of a baseline CPCP is to establish requirements for control of corrosion of
aircraft structure to Level 1 or better for the operational life of the aircraft. The baseline
CPCP should include the basic task, implementation thresholds, and repeat intervals. The
baseline CPCP should also include procedures to notify the competent authority of the
findings and data associated with Level 2 and Level 3 corrosion and the actions taken to
reduce future findings to Level 1.
3.1.1. Baseline CPCP considerations
To establish an effective baseline CPCP, consideration of the following is necessary:
(a) the flight and maintenance history of the aircraft model and perhaps similar
models;
(b) the corrosion properties of the materials used in the aircraft structure;
(c) the protective treatments used;
(d) the general practice applied during construction and maintenance; and
(e) local and widespread corrosion* (see Figure A4-1).
* Note: In some existing CPCPs, the concept of local and widespread corrosion is
directly related to the corrosion level definitions, and for those programmes, those
definitions remain applicable. The alignment of a programme with the corrosion
level definitions of this amendment of the AMC may require a reassessment of the
allowable limits and the way they are presented in the applicable ICA. This is
because the assumptions made to determine the allowable limits may not have
taken into account the fatigue and damage tolerance requirements that are now
applicable through retroactive rulemaking and the updated certification basis. In
addition, programmes that addressed widespread corrosion within the allowable
limits as Level 2 corrosion may have addressed the derivation of the allowable
limits without assuming that the maximum material loss would occur over the
whole area.
When determining the detail of the corrosion inspection tasks, the implementation
threshold and the repeat interval, a realistic operational environment should be
considered. Technical representatives of both the TCH and the operators should
participate in evaluating the service history and operational environment for the
aircraft model. For new aircraft models and for aircraft models that have been in

AMC 20-20A
operation for only a short time, technical representatives of operators of similar

aircraft models should be invited to participate.
Figure A4-1
3.1.2. TCH-developed baseline CPCP

During the design development process, the TCH should provide a baseline CPCP
as part of the ICA. The TCH initially evaluates the service history of corrosion
available for aircraft of similar design used in the same operational environment.
Where no similar design with service experience exists, those structural features
concerned should be assessed using the environmental damage approach of ATA
MSG-3. The TCH develops a preliminary baseline CPCP based on this evaluation.
The TCH then convenes a working group consisting of operator technical

AMC 20-20A
representatives and representatives of the participating competent authorities.

The working group reviews the preliminary baseline CPCP to assure that the tasks,
implementation thresholds and repeat intervals are practical and assure the
continued airworthiness of the aircraft. Once the working group review is
complete, the TCH incorporates the baseline CPCP into the ICA (see Figure A4-2).
The TCH evaluates

corrosion service history
The TCH convenes a working group

and establishes a baseline
programme
The TCH incorporates baseline

programme into the instructions
for continued airworthiness
Figure A4-2: TCH-developed baseline CPCP
3.1.3 Operator-developed CPCP

Exceptionally, there may be instances where the TCH does not provide a baseline
CPCP. In such instances, an operator may develop their CPCP without using a
baseline CPCP, as long as the operator-developed CPCP is consistent with the
requirements. It would be beneficial for an operator developing its own CPCP to
consult other operators of the same or similar aircraft models in order to broaden
the service experience available for use in preparing their programme. When a
TCH-prepared baseline CPCP is unavailable, a group of operators may prepare a
baseline CPCP from which each operator in the group will develop their CPCP.
(a) Operator-developed baseline CPCP
An operator-developed baseline CPCP should particularly focus on the areas
of the aircraft prone to corrosion, such as:
(i) exhaust trail areas,
(ii) battery compartments and battery vent openings,
(iii) areas surrounding lavatories, buffets and galleys,
(iv) bilges,
(v) fuselage internal lower structure,
(vi) wheel wells and landing gear,

AMC 20-20A
(vii) external skin areas,

(viii) water entrapment areas,
(ix) engine frontal areas and cooling air vents,
(x) electronic or avionics compartments, and
(xi) flight control cavities open during take-off and landing.
Note: CPCPs for large transport aeroplanes were developed based on a triad
amongst the Airworthiness Authorities, DAHs, and the operators for the
particular aeroplane model. If operator(s) were to develop a CPCP, they may
want to follow the example of the large transports.
The lead operator

evaluates corrosion
service history
Are multiple
operators No
involved?
Yes
Convene working
group and establish
baseline programme
Publish baseline The operator develops

programme CPCP
Figure A4-3: Operator-developed baseline CPCP
(b) Individual operator-developed CPCP

An operator may develop their CPCP without reference to a baseline CPCP
only when a baseline CPCP does not exist. The CPCP should be consistent
with the requirements of the applicable operating rules. Any operator who
develops their own CPCP without a baseline CPCP, should review all available
corrosion-related service data on the individual aircraft model and similar
design details in similar aircraft models when the operator’s data and the
service difficulty report data show no entries.

AMC 20-20A
3.1.4. Continuous analysis and surveillance

The operator’s continuous analysis and surveillance system should contain
procedures to review corrosion inspection task findings and establish corrosion
levels. These procedures should provide criteria for determining if findings that
exceed allowable limits are an isolated incident not typical of the operator’s fleet.
The operator’s programme should also provide for notifying the competent
authority whenever a determination of Level 2 or Level 3 corrosion is made. Due
to the potential urgent airworthiness concern associated with a Level 3 finding, the
operator’s procedures should provide for notification as soon as possible but no
later than 3 calendar days after the Level 3 determination has been made.
3.2. Baseline CPCP documentation
The baseline CPCP documentation should include instructions to implement the baseline
CPCP. It may be in a printed form or other form acceptable to the competent authority.
It should also be in a form that is easy to revise. The date of the last revision should be
entered on each page. The baseline CPCP documentation should be clearly identified as
a baseline CPCP. The aircraft make, model and the person who prepared the
documentation should also be identified.
3.2.1. Purpose and background
This section of the documentation should state the purpose of the baseline CPCP,
which is to establish minimum requirements for preventing and controlling
corrosion that may jeopardise continuing airworthiness of the aircraft model fleet.
The section should further state that an operator should include an effective CPCP
in their maintenance or inspection programme.
3.2.2. Introduction
The introduction should include a general statement that corrosion becomes more
widespread as aircraft age and that it is more likely to occur in conjunction with
other damage such as fatigue cracking. The introduction should also indicate that
it is not the intent of a CPCP to establish rigid requirements to eliminate all
corrosion in the fleet, but to control corrosion at or below levels that do not
jeopardise continued airworthiness. However, due to the unpredictability of
corrosion, it must be removed and the structure repaired and corrosion prevention
treatment reapplied.
3.2.3. Programme application
For a programme to be fully effective, it is essential that a corrosion inspection task
be applied to all areas where corrosion may affect primary structure. This section
should recommend that priority for implementing the CPCP be given to older
aeroplanes and to areas requiring significant changes to previous maintenance
procedures in order to meet corrosion prevention and control requirements. This
section should allow an operator to continue its current corrosion control
procedures in a given task area or zone where there is documentation to show that
corrosion is being consistently controlled to Level 1.
3.2.4. Baseline CPCP
This section should fully describe the baseline CPCP. It should include the basic
task, corrosion inspection task areas, implementation thresholds, and repeat
intervals.

AMC 20-20A
3.2.5. Reporting system

Procedures to report findings of Level 2 and Level 3 corrosion as necessary to the
TCH and the competent authority should be clearly established in this section. The
TCH should indicate any specific requirement they have for reporting on corrosion
levels that may be needed to revise the baseline CPCP. The information on Level 2
corrosion may be needed in a form acceptable to the competent authority
responsible for approval of any revision to the maintenance programme resulting
from a Level 2 finding. The timing of reporting should take into account the
processes for the periodic review (see 3.2.6). All Level 2 and Level 3 findings should
be reported in accordance with any applicable AD, operator’s service difficulty
reporting procedures or reporting required by other competent authorities.
Procedures for alerting the competent authority of Level 3 findings should be
established that expedite such reporting. This report to the competent authority
shall be made after the determination of the corrosion level.
3.2.6 Periodic review
This section should establish a period for the TCH (or lead operator) and
participating operators to meet with EASA and review the reported Level 2 and
Level 3 findings. The purpose of this review is to assess the baseline CPCP and make
adjustments if necessary. This may be accomplished through maintenance
programme reviews conducted via the Maintenance Programme Industry Steering
Committees (MRB Structures Working Group or equivalent meetings) for the
model.
3.2.7. Corrosion-related airworthiness directives
This section should include a list of all ADs that contain requirements related to
known corrosion-related problems. This section should state that these ADs are in
addition to and take precedence over the operator’s CPCP.
3.2.8. Development of the baseline CPCP
This section should identify the actions taken in preparing the baseline CPCP. It
should include a description of the participants, the documents (e.g. SBs, service
letters, ADs, service difficulty reports, accident and incident reports) reviewed, and
the methodology for selecting and categorising the corrosion-prone areas to be
included in the baseline CPCP. The selection criteria for corrosion-prone areas
should be based on areas having similar corrosion exposure characteristics and
inspection access requirements. Some corrosion-prone areas that should be
considered are the main wing box, the fuselage crown, the bilge, areas under
lavatories and galleys, etc. This section should state that the implementation
threshold was selected to represent the typical aircraft age beyond which an
effective corrosion inspection task should be implemented for a given task area.
3.2.9. Procedures for recording corrosion inspection findings
EASA has not imposed a requirement for additional record-keeping for an
operator’s CPCP. However, the operator should maintain adequate records to
substantiate any proposed programme adjustments. For example, an operator
should maintain records to enable the operator to determine the amount of
damage that has occurred during the repeat interval for each corrosion inspection
task. Such data should be maintained for multiple repeat intervals in order to
determine whether the damage remains constant or is increasing or decreasing.

AMC 20-20A
Such records are necessary when an operator is seeking approval for interval
extension (escalation) or task reduction.
3.2.10. Glossary
This section should define all terms specifically used in the baseline CPCP
documentation.
3.2.11. Application of the basic task
This section should describe in detail the basic task. It should provide procedures
describing how to accomplish the following actions:
(a) Removal of all systems equipment and interior furnishings to allow access to
the area.
(b) Cleaning of the area as required.
(c) Visual inspection of all task areas and zones listed in the baseline CPCP.
(d) Removal of all corrosion, damage evaluation, and repair of structure as
necessary.
(e) Unblocking holes and gaps that may hinder drainage.
(f) Application of corrosion protective compounds.
(g) Reinstallation of dry insulation blankets, if applicable.
3.2.12. Determination of corrosion levels based on findings
This section should describe how the corrosion level definitions are used in
evaluating the corrosion findings and assigning a corrosion level. This section
should also instruct the operator to consult the DAH or the competent authority
for advice in determining corrosion levels.
3.2.13. Typical actions following determination of corrosion levels
This section should establish criteria for evaluating whether or not Level 2 or
Level 3 corrosion is occurring on other aircraft in the operator’s fleet. Criteria to be
considered include: cause of the corrosion problem, past maintenance history,
operating environment, production build standard, years in service, and
inspectability of the corroded area. These and any other identified criteria should
be used in identifying those aircraft that should be included in a fleet campaign.
The results of the fleet campaign should be used to determine necessary
adjustments in the operator’s CPCP. The following instructions should also be
included in this section:
(a) If corrosion exceeding the allowable limit is found during accomplishment of
the corrosion inspection task implementation threshold for a task area, it
may be necessary to adjust the CPCP. (See ‘NOTE’ under ‘Level 2 corrosion’
definition)
(b) A single isolated occurrence of corrosion between successive inspections
that exceeds Level 1 does not necessarily warrant a change in the operator’s
CPCP. If the operator experiences multiple occurrences of Level 2 or Level 3
corrosion for a specific task area, then the operator should implement a
change to the CPCP.

AMC 20-20A
(c) The operator should not defer maintenance actions for Level 2 and Level 3
corrosion. These maintenance actions should be accomplished in
accordance with the operator’s maintenance manual.
(d) The operator may implement changes such as the following to improve the
effectiveness of the programme:
(1) reduction of the repeat interval,
(2) multiple applications of corrosion treatments,
(3) additional drainage provisions,
(4) incorporation of DAHs service information, such as SBs and service
letters.
3.2.14. Programme implementation
This section should state that each task is to be implemented on each aircraft when
the aircraft reaches the age represented by the implementation threshold for the
task. It should also describe procedures to be used for establishing a schedule for
implementation where the aircraft age exceeds the implementation threshold for
individual tasks. Finally, it should state that once a task is implemented in an area,
subsequent tasks are to be accomplished at the repeat interval in that task area.
4. DEVELOPMENT OF OPERATORS PROGRAMME
4.1. Baseline CPCP available
If a baseline CPCP is available, the operator should use it as a basis for developing their
CPCP. In addition to adopting the basic task, task areas, implementation thresholds and
repeat intervals of the baseline CPCP, the operator should make provisions for:
(a) aeroplanes that have exceeded the implementation threshold for certain tasks,
(b) aeroplanes being removed from storage,
(c) unanticipated scheduling adjustments,
(d) corrosion findings made during non-CPCP inspections,
(e) adding newly acquired aircraft, and
(f) modifications, configuration changes, and operating environment.
4.1.1. Provisions for aircraft that have exceeded the implementation threshold
The operator’s CPCP must establish a schedule for accomplishing all corrosion
inspection tasks in task areas where the aircraft age has exceeded the
implementation threshold (see main text of AMC paragraph 12).
4.1.2. Aeroplanes being removed from storage
Corrosion inspection task intervals are established based on elapsed calendar time.
Elapsed calendar time includes time out of service. The operator’s CPCP should
provide procedures for establishing a schedule for accomplishment of corrosion
inspection tasks that have accrued during the storage period.
The schedule should result in accomplishment of all accrued corrosion inspection
tasks before the aircraft is placed in service.

AMC 20-20A
4.1.3. Unanticipated scheduling adjustments

The operator’s CPCP should include provisions for adjustment of the repeat
interval for unanticipated schedule changes. Such provisions should not exceed
10 % of the repeat interval. The CPCP should include provisions for notifying the
competent authority when an unanticipated scheduling adjustment is made.
4.1.4. Corrosion findings made during non-CPCP inspections
Corrosion findings that exceed allowable limits may be found during any scheduled
or unscheduled maintenance or inspection activities. These findings may be
indicative of an ineffective CPCP. The operator should make provision in their CPCP
to evaluate these findings and adjust their CPCP accordingly.
4.1.5. Adding newly acquired aircraft
Before adding any aircraft to the fleet, the operator should establish a schedule for
accomplishing all corrosion inspection tasks in all task areas that are due. This
schedule should be established as follows:
(a) For aircraft that have previously operated under an approved maintenance
programme, the initial corrosion inspection task for the new operator must
be accomplished in accordance with the previous operator’s schedule or in
accordance with the new operator’s schedule, whichever would result in the
earliest accomplishment of the corrosion inspection task.
(b) For aircraft that have not previously been operated under an approved
maintenance programme, each initial corrosion task inspection must be
accomplished either before the aircraft is added to the operator’s fleet, or
in accordance with the schedule approved by the competent authority. After
each corrosion inspection task has been performed once, the subsequent
corrosion task inspections should be accomplished in accordance with the
new operator’s schedule.
4.1.6. Modifications, configuration changes and operating environment
The operator must ensure that their CPCP takes account of any modifications,
configurations changes and the operating environment applicable to them, that
were not addressed in the baseline CPCP documentation.
4.2. Baseline CPCP not available
If there is no baseline CPCP available for the operator to use in developing their CPCP, the
operator should develop their CPCP using the provisions listed in Paragraph 3 of this
Appendix for a baseline CPCP as well as the provisions listed in subparagraphs 4.1.1
through 4.1.6 of this paragraph.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-20A
Appendix 5 to AMC 20-20A Guidelines for ensuring the validity of

continuing structural integrity programmes
1. GENERAL
Point 26.305 of Part-26 requires a process that ensures that the continuing structural integrity
programme remains valid throughout the operational life of the aircraft, considering service
experience and current operations. The intent is for the TCHs of large transport aeroplanes to
review the validity of the certification assumptions upon which the maintenance programme is
based and to ensure that unsafe levels of fatigue cracking or other damage will be minimised in
service. This Appendix provides guidance as to what the processes should include.
This Appendix also provides interpretation, guidelines and EASA accepted means of compliance
for the review of structural SBs including a procedure for selection, assessment and related
recommended corrective action for ageing aircraft structures.
2. CONTENT OF PROCESSES FOR COMPLIANCE WITH POINT 26.305 of PART-26
CS 26.305 establishes compliance on the basis of sub-paragraphs (a) to (g), reproduced below,
and consideration of the criteria of sub-paragraph (h):
(a) a process exists, and a report that describes the process and how it is implemented is
submitted to EASA; and
(b) the process is either continuous with each service finding or is a regular review following
a number of findings, or a combination of both; and
(c) the process includes a plan to audit and report to EASA the effectiveness of the continuing
structural integrity programme, including the continuing validity of the assumptions upon
which it is based, prior to reaching any significant point in the life of the aircraft; and
(d) the process includes criteria for summarising findings of fatigue environmental or
accidental damage and their causes and recording them in a way that allows any potential
interaction to be evaluated; and
(e) the process includes criteria to assess and record the relevance of each potential
contributing factor to the finding, including operational usage, fatigue load spectra,
environmental conditions, material properties, manufacturing processes and the fatigue
and damage tolerance analysis methodology and its implementation; and
(f) the process includes criteria for establishing and revising sampling programmes to
supplement the inspections and other procedures established in compliance with the
applicable fatigue and damage tolerance requirements; and
(g) the process includes criteria for establishing when structure should be modified or the
inspection programme revised in the light of in-service damage findings.
(h) Sunset criteria: The extent to which the above elements of the process require definition
may be tailored to the size of the fleet and its expected useful remaining life (e.g. if less
than 10 % of the fleet remains in operation worldwide at the date of applicability of
point 26.305 and there is significant experience of aircraft reaching the maximum
expected operating life, then additional criteria beyond the existing processes may be
agreed to be unnecessary).

AMC 20-20A
It should be noted that point 26.305 of Part-26 applies to all structure whose failure could
contribute to a catastrophic failure, and is not limited to metallic structures and fatigue cracking,
but should also encompass composite and hybrid structures.
The reporting of findings that could be relevant to the continuing structural integrity of the
aeroplane should be facilitated by providing clear instructions and easy-to-use reporting means
to operators that encourage and facilitate both their support and that of the customer support
staff in identifying developing risks.
The intent of the audit and the associated report is to provide the TCH and EASA with a series
of properly planned opportunities to assess the continuing structural integrity programme for
significant systemic shortcomings and take timely action in advance of potential unsafe
conditions. The audit should consider each of the parts of the continuing structural integrity
programme and any links between them or with programmes for other types. In the context of
this requirement, the audit should address all structures, not only metallic structures.
The audit report should summarise the processes and their evolutions. The report should
describe any measures taken in the audit that are beyond the basic processes described in the
original summary report in compliance with point 26.305 of Part-26 (e.g. additional field
inspections or tear down inspections of fleet leading aircraft in terms of age and usage). The
report should summarise the status of each part of the continuing structural integrity
programme, the findings of the audit and proposals for the actions to be taken.
The audit should provide evidence that the processes required by point 26.305 of Part-26 have
been properly implemented, such that:
— reported service findings have been recorded and summarised in a way that allows
causes, trends and actions to be reviewed;
— service findings are evaluated for consistency with the assumptions on which the
programme is based;
— the continuing structural integrity programme remains effective (e.g. changes have been
made to the programme in response to findings, and few emergency or short-term
airworthiness actions have been necessary);
— a comparison of the loading, operational usage, fatigue methodology, design tools, and
test evidence with that upon which the programme is based, shows that the programme
remains valid;
— causal analysis results have been reviewed and evaluated for evidence of repetitive
themes for which no specific action has been taken; and
— the fleet leader sampling programme has been implemented, and any findings resulting
from it have been properly dispositioned.
The audit report should record how any deviations from the applicable processes, identified
during the audit, have been or will be addressed.
Significant points in the aircraft life that should be considered in the audit plan include: points
at which a common threshold exist for multiple damage-tolerance-based inspections, half-DSG,
DSG, LOV, etc. In order to plan for a timely assessment that will allow proactive revision of the
maintenance programme, the audit should take place several years before reaching the
significant point.
Assumptions made at certification and subsequently regarding key operating variable
parameters such as weight, fuel, payload, mission length, etc., should be evaluated on a regular

AMC 20-20A
basis or each time a finding indicates that the assumptions may be compromised, resulting in
an adverse effect on the fatigue analysis and inspection programme.
One way to ensure confidence in the maintenance programme is by establishing a fleet leader
sampling programme encompassing various operators and operations in different
environments. This may, for example, be developed in coordination with the MRB and requires
the cooperation of the leading operators. The sampling programme need not address all
potential damage locations, and should focus on the most critical that would provide early
indications of potentially erroneous assumptions. Sampling may also be beneficial where new
materials or methods of construction have been introduced, especially when the extent of
testing may have been limited at certification, e.g. for areas of hybrid structure where the
temperature differential was not part of the full-scale fatigue test. The sampling programme
may also impose more intrusive or detailed inspections and analyses of samples taken from the
structure (for composites or other materials subject to environmental degradation).
The details of the sampling programme requirements and the associated reporting
requirements should be established in coordination with the operators. The ICA, in compliance
with Appendix H to CS-25, may need to be supplemented with this information to support the
core compliance elements of the continuing structural integrity programme generated through
compliance with CS 25.571.
The process for establishing when a structure should be modified or the inspection programme
revised in the light of in-service damage findings should include special consideration of:
— damage detected and reported before the inspection threshold; and
— damage that is generally being found at or near to the critical crack size; and
— changing damage configurations for which the reasons are not fully understood; and
— new damage scenarios reported under existing inspection or repair procedures that could
otherwise be considered to be addressed, and overlooked.
The objectives of modifying structures are to provide a reasonably high probability that the
ultimate load capability will be retained over long periods of the aircraft’s life, and to
significantly reduce the potential for interaction with new cracking that may develop later in
the aircraft’s life.
The following guidance regarding the SB review process is retained from the original issue of
this AMC for general guidance on the subject, and the criteria for bulletin selection provide
useful additional factors for establishing when structures should be modified or the inspection
programme revised.
3. SB REVIEW PROCESS
SBs issued early in the life of an aircraft fleet may utilise inspections (in some cases
non-mandatory inspections) alone to maintain structural integrity. Inspections may be
adequate at this early stage, when cracking is possible, but not highly likely. However, as aircraft
age, the probability of fatigue cracking becomes more likely. During this later period, it is not
prudent to rely only on inspections alone because there are more opportunities for cracks to be
missed, and cracks may no longer occur in isolation. It is then prudent to reduce reliance strictly
on inspections, with their inherent human factors limitations, and to incorporate modifications
to the structure to eliminate the source of the cracking. In some cases, reliance on an inspection
programme, in lieu of modification, may be acceptable through the increased use of mandatory
versus non-mandatory inspections.

AMC 20-20A
The TCH, in conjunction with the operators, is expected to initiate a review of all structurally
related inspection and modification SBs and determine which require further actions to ensure
continued airworthiness, including mandatory modification action or enforcement of special
repetitive inspections.
Any aircraft primary structural components that would require frequent repeat inspections, or
where the inspection is difficult to perform, taking into account the potential airworthiness
concern, should be reviewed to preclude the human factors issues associated with repetitive
inspections.
The SB review is an iterative process consisting of the following items:
(a) The TCH or the TCH in conjunction with the operators at a preliminary STG meeting
should review all the issued structural inspection and modification SBs to select candidate
bulletins, using the following four criteria:
(i) There is a high probability that structural cracking exists.
Related to the number and type of finding in service and from fatigue testing.
A ‘no finding’ result should be associated with the number of performed
inspections.
The type of finding should include an analysis of its criticality.
(ii) Potential structural airworthiness concern
The structural airworthiness of the aircraft is dependent on repeat inspections to
verify its structural condition, and therefore on the reliability of the inspections.
A short repeat inspection interval (e.g. a short time for a crack to grow from a
detectable crack to a critical length divided by a factor) will lead to increased
workloads for inspectors and a possible increased risk of them missing damage.
Special attention should be paid to any single inspection tasks involving multiple
repeat actions needed to verify the structural condition that may increase the risk
of the inspectors missing damage (e.g. lap splice inspections).
(iii) Damage is difficult to detect during routine maintenance (i.e. there are few
additional opportunities for detection beyond the specific requirement of the SB).
(Of particular concern is damage that is found when it is well-developed and closer
to being critical, rather than damage which is in the early stages with several
further opportunities available for detection before it becomes critical.)
The areas to be inspected are difficult to access.
NDI methods are proving unsuitable.
The human factors associated with the inspection technique are so adverse that
the detection of cracks may not be sufficiently dependable to assure safety.
(iv) There is adjacent structural damage or the potential for it.
Particular attention should be paid to areas susceptible to WFD and also to
potential interaction between corrosion and fatigue cracking, e.g. between
fastener damage (due to stress corrosion or other factors) and fatigue cracking.
It is recommended to consider the potential interaction of modifications or repairs
usually implemented in the areas concerned to check whether the inspections are
still reliable or not (operator’s input).

AMC 20-20A
(b) The TCH and operator members will be requested to submit information on their
individual fleet experience related to candidate SBs. This information will be collected
and evaluated by the TCH. The summarised results will then be reviewed in detail at an
STG meeting (see point (c) below).
(c) The final selection of SBs for recommendation of the appropriate corrective action to
assure structural continued airworthiness, taking into account the in-service experience,
will be made during an STG meeting by the voting members of the STG, either by
consensus or majority vote, depending on the preference of the individual STGs.
(d) An assessment will be made by the TCH as to whether or not any subsequent revisions to
SBs affect the decisions previously made. Any subsequent revisions to the SBs previously
chosen by the STG for mandatory inspection or incorporation of modification action that
would affect the previous STG recommended action should be submitted to the STG for
review.
(e) The TCH should review all new structural SBs periodically to select further candidate
bulletins. The TCH should schedule a meeting of the STG to address the candidates.
Operator members and the competent authority will be advised of the selected
candidates and provided with the opportunity to submit additional candidates.
The SB selection, review, assessment and recommendation process within the Structural Task
Group (STG) is summarised in Figure A5-1. For the first SB review within an STG meeting, all the
inspection SBs should be selected. Moreover, some specific modification SBs not linked to an
inspection SB may also be selected for review.
The information input by operators should address the points as detailed in Figure A5-2. This
information should be collected and analysed by the TCH for the STG meeting.
If, for a given selected SB, there is not sufficient in-service data available before the STG meeting
that would enable a recommendation to be made, its review may be deferred until enough data
is available. The TCH should then check periodically until the data becomes available.
The operators and EASA should be advised by the TCH of the SB selection list and be given the
opportunity to submit additional SBs. For this purpose, the TCH should give the operators
enough information in advance (e.g. 2 months) for them to be able to properly consider the
proposed selection and to gather data.
When an SB is selected, it is recommended to also select, in the same package, inspection SBs
that interact with it and all the related modification SBs. The main criteria for selecting SBs are
defined in the following subparagraphs.
4. STG MEETING, SB REVIEW AND RECOMMENDATIONS
It is recommended to review at the same time all SBs that can interact, the so-called SB package,
in the selection process. The meeting should start with an STG agreement on the selected SB
list and on those deferred. At the meeting the TCH should present their analysis of each SB
utilising the collection of operator input data. The STG should then collectively review the
ratings (Figure A5-2) against each criterion to reach a consensus recommendation. Such an STG
recommendation for a selected SB shall consider the following options:
(a) to mandate a structural modification at a given threshold,
(b) to mandate the selected inspection SB,
(c) to revise the modification or repair actions,
(d) to revise other SB(s) in the same area concerned by damages,

AMC 20-20A
(e) to review the inspection method and related inspection intervals,

(f) to review ALI/MRBR or other maintenance instructions,
(g) to defer the review to the next STG and request operators’ reports on findings for a
specific SB or request an inspection sampling on the oldest aircraft.
STG recommendations for mandatory action are the responsibility of the TCH to forward to
EASA for appropriate action. Other STG recommendations is information provided to the STG
members. It is their own responsibility to carry them out within the appropriate framework.

AMC 20-20A
Figure A5-1: SB selection process and SB review

AMC 20-20A
IN-SERVICE DATA/SECTION 1
NAME OF THE OPERATOR:
_________________________________________________________________________________________
AIRCRAFT MODEL/SERIES:
_________________________________________________________________________________________
SERVICE BULLETIN (SB) NUMBER:

_________________________________________________________________________________________
TITLE:____________________________________________________________________________________
RELATED INSPECTION/MODIFICATION SB:

1/_______________________________________________________________________________________
2/_______________________________________________________________________________________
3/_______________________________________________________________________________________
SB MANDATED?  YES  NO
IF NOT, IS THE SB IMPLEMENTED IN THE MAINTENANCE PROGRAMME?  YES  NO
NUMBER OF AIRCRAFT TO WHICH THE SB APPLIES (INCLUDING ALL AIRCRAFT IN THE SB EFFECTIVITY):
_________________________________________________________________________________________
NUMBER OF AIRCRAFT EXCEEDING THE SB INSPECTION THRESHOLD (IF APPLICABLE):

_________________________________________________________________________________________
NUMBER OF AIRCRAFT INSPECTED PER SB (IF APPLICABLE)?

_________________________________________________________________________________________
SPECIFY TYPE OF INSPECTION USED:

_________________________________________________________________________________________
NUMBER OF AIRCRAFT WITH REPORTED FINDINGS:

_________________________________________________________________________________________
TYPE OF FINDINGS:
NUMBER OF FINDINGS DUE TO INSPECTIONS OTHER THAN THE ONE PRESCRIBED IN THE SB (IF APPLICABLE):
_________________________________________________________________________________________
SPECIFY TYPE OF INSPECTION USED:
_________________________________________________________________________________________
NUMBER OF AIRCRAFT EXCEEDING THE SB TERMINATING MODIFICATION THRESHOLD (IF APPLICABLE):

_________________________________________________________________________________________
NUMBER OF AIRCRAFT IN WHICH THE TERMINATING MODIFICATION HAS BEEN ACCOMPLISHED (IF
APPLICABLE):
_________________________________________________________________________________________
NEED THIS SB (OR RELATED SB) BE IMPROVED?  YES  NO
COMMENTS: ______________________________________________________________________________
_________________________________________________________________________________________

AMC 20-20A
IN-SERVICE DATA/SECTION 2
(A) (B) (C) (D) (E)

CRITERIA INSPECTABILITY FREQUENCY FREQUENCY OF SEVERITY ADJACENT
ACCESS REPETITIVE DEFECTS RATING STRUCTURE
INSPECTION DAMAGE
RATING
FIGURE A5-2: Operators fleet experience
(A) INSPECTABILITY/ACCESS RATING

OK  Inspection carried out with little or no difficulty.
Acceptable  Inspection carried out with some difficulty.
Difficulty  Inspection carried out with significant difficulty.
Note: Rating should consider difficulty of access as well as inspection technique and size of
inspection area.
(B) FREQUENCY OF REPETITIVE INSPECTIONS RATING
OK  Greater than 6 years.
Acceptable  Between 2 and 6 years.
Difficulty  Less than 2 years.
(C) FREQUENCY OF DEFECTS NOTED RATING = % OF THOSE AEROPLANES BEYOND THRESHOLD ON
WHICH DEFECTS HAVE BEEN FOUND
OK  No defect noted.
Acceptable  Defects noted but not of a significant amount (less than 10 %).
Difficulty  Substantial defects noted (greater than 10 %).
(D) FINDING SEVERITY RATING
OK  Airworthiness not affected.
Acceptable  Damage not of immediate concern, but could progress or cause secondary
damage.
Difficulty  Airworthiness affected. Damage requires immediate repair.
(E) ADJACENT STRUCTURE DAMAGE RATING (MULTIPLE-SITE DAMAGE, MULTIPLE-ELEMENT
DAMAGE, CORROSION, ETC.)
OK  Low rate of adjacent structural damage.
Acceptable  Medium rate of adjacent structural damage.
Difficulty  High rate of adjacent structural damage/Multiple service actions in area.
[Amdt 20/2]
[Amdt 20/20]

AMC 20-21
AMC 20-21
AMC 20-21 Programme to enhance aeroplane Electrical Wiring

Interconnection System (EWIS) maintenance
1 PURPOSE
This AMC provides acceptable means of compliance for developing enhanced EWIS
maintenance for operators, holders of type certificates (TC), holders of supplemental type
certificates (STC) and maintenance organisations. The information in this AMC is derived from
the maintenance, inspection, and alteration best practices identified through extensive
research. This AMC provides an acceptable means of compliance with the appropriate
certification, maintenance and operating rules. This AMC promotes a housekeeping philosophy
of “protect, clean as you go” when performing maintenance, repair, or alterations on or around
aircraft EWIS.
2 OBJECTIVE
The objective of this AMC is to enhance the maintenance of aircraft EWIS through adoption by
the aviation industry of the following:
a. Enhanced Zonal Analysis Procedure (EZAP). This AMC presents an “enhanced zonal
analysis procedure” and logic that will benefit all aircraft regardless of whether they
currently have a structured Zonal Inspection Programme (ZIP), (see Appendix A.
Enhanced Zonal Analysis Logic Diagram and Steps and Appendix B. EZAP Worksheets).
Application of this procedure will ensure that appropriate attention is given to wiring
installations. Using EZAP it will be possible to select stand-alone inspections (either
general or detailed) and tasks to minimise the presence of combustible material. The
procedure and logic in this AMC complement existing zonal analysis procedures and will
also allow the identification of new wiring tasks for those aircraft that do not have a
structured ZIP.
b. Guidance for General Visual Inspection (GVI). This AMC provides clarification of the
definition for a GVI as well as guidance on what is expected from such an inspection,
whether performed as a stand-alone GVI or as part of a zonal inspection. It is assumed
this new inspection standard will be the standard applied by operators, or their
maintenance provider, when the new tasks are incorporated in to their maintenance
programme.
c. Protection and Caution. This AMC identifies protection and caution to be added to
maintenance instructions, thereby enhancing procedures that will lead to minimisation
of contamination and accidental damage while working on the aircraft.
The enhanced aircraft wiring maintenance information described in this AMC is intended to
improve maintenance and inspection programmes for all aircraft systems. This information,
when used appropriately, will improve the likelihood that wiring system degradation, including
age-related problems, will be identified and corrected. Therefore, the goal of enhanced wiring
maintenance information is to ensure that maintenance actions, such as inspection, repair,
overhaul, replacement of parts, and preservation, do not cause a loss of wiring system function,
do not cause an increase in the potential for smoke and fire in the aircraft, and do not inhibit
the safe operation of the aircraft.

AMC 20-21
In order to fully realise the objectives of this AMC, operators, TC holders, STC holders and
maintenance providers, will need to rethink their current approach to maintaining and
modifying aircraft wiring and systems. This may require more than simply updating
maintenance manuals and work cards and enhancing training. Maintenance personnel need to
be aware that aircraft EWIS should be maintained with the same level of intensity as any other
system in the aircraft. They also need to recognise that visual inspection of wiring has inherent
limitations. Small defects such as breached or cracked insulations, especially in small gauge wire
may not always be apparent. Therefore effective wiring maintenance combines visual
inspection techniques with improved wiring maintenance practices and training.
Good wiring maintenance practices should contain a "protect, clean as you go" housekeeping
philosophy. In other words, care should be taken to protect wire bundles and connectors during
work, and to ensure that all shavings, debris and contamination are cleaned up after work is
completed. This philosophy is a proactive approach to wiring system health. Wiring needs to be
given special attention when maintenance is being performed on it, or around it. This is
especially true when performing structural repairs, work under STCs or field approvals, or other
modifications.
To fully achieve the objectives of this AMC it is imperative that all personnel performing
maintenance on or around EWIS receive appropriate training (see AMC 20-22: Aeroplane EWIS
training programme).
3 APPLICABILITY
a. The guidance provided in this document is directed to operators, TC applicants and
holders, STC applicants and maintenance organisations:
b. The guidance provided in this AMC can be applied to all aeroplane maintenance or
inspection programmes. The EZAP in Appendix A of this AMC is specifically directed
towards enhancing the maintenance programmes for aircraft whose current programme
does not include tasks derived from a process that specifically considers wiring in all zones
as the potential source of ignition of a fire.
c. This AMC, when followed in its entirety, outlines an acceptable means of compliance to
the requirement for the development of enhanced scheduled maintenance tasks for the
EWIS for the aircraft mentioned in 3a. above.
d. Similarly, it also provides an acceptable means of compliance for CS 25.1739 and 25.1529
Appendix H25.5 for new designs.
4 RELATED DOCUMENTS
— Regulation (EC) No 216/20081
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil
aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002
and Directive 2004/36/EC (OJ L 79, 19.3.2008, p.1).
2
Commission Regulation (EC) No 1702/2003 of 24 September 2003 laying down implementing rules for the airworthiness and
environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and
production organisations (OJ L 243, 27.9.2003, p. 6). Regulation as last amended by Regulation (EC) No 287/2008 (OJ L 87, 29.3.2008,
p.3).

AMC 20-21

— EASA Certification Specification CS-25 Large Aeroplanes2
— EU-OPS Commercial Air Transportation (Aeroplanes)3
5 RELATED READING MATERIAL
a. EASA AMC 20
— AMC 20-22 Aeroplane EWIS training
— AMC 20-23 Development of electrical standard wiring practices documentation
b. FAA Advisory Circulars (AC).
— AC 25-16 Electrical Fault and Fire Protection and Prevention
— AC 25.981-1B Fuel Tank Ignition Source Prevention Guidelines
— AC 43-12A Preventive Maintenance
— AC 43.13-1B Acceptable Methods, Techniques and Practices for Repairs and
Alterations to Aircraft
— AC 43-204 Visual Inspection For Aircraft
— AC 43-206 Avionics Cleaning and Corrosion Prevention/Control
— AC 65-15A Airframe and Powerplant Mechanics Airframe Handbook, Chapter 11,
Aircraft Electrical Systems
— AC 120-YYY Training modules for wiring maintenance
c. Reports
— Transport Aircraft Intrusive Inspection Project, (An Analysis of the Wire
Installations of Six Decommissioned Aircraft), Final Report, The Intrusive Inspection
Working Group, December 29, 2000.
http://www.mitrecaasd.org/atsrac/intrusive_inspection.html
— FAA Aging Transport Non-Structural Systems Plan, July 1998.
— National Transportation Safety Board, Safety Recommendation, September 19,
2000, A-00-105 through -108.
http://www.ntsb.gov/recs/letters/2000/A00_105_108.pdf
— Wire System Safety Interagency Working Group, National Science and Technology
Council, Review of Federal Programmes for Wire System Safety 46 (2000).
— Aging Transport Systems Rulemaking Advisory Committee, Task 1 and 2, Aging
Systems, Final Report.
1
Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical products,
parts and appliances, and on the approval of organisations and personnel involved in these tasks (OJ L 315, 28.11.2003, p. 1). Regulation
as last amended by Regulation (EC) No 376/2007 of (OJ L 94, 4.4.2007, p. 18).
2
Executive Director Decision No 2003/2/RM of 14 October 2003 on certification specifications, including airworthiness codes and
acceptable means of compliance, for large aeroplanes («CS-25»). Decision as last amended by Executive Director Decision No
2008/006/R of 29 August 2008 (CS-25 Amendment 5).
3 Council Regulation (EEC) No 3922/91 of 16 December 1991 on the harmonisation of technical requirements and administrative
procedures in the field of civil aviation (OJ L 373, 31.12.1991, p. 4). Regulation as last amended by Regulation (EC) No 8/2008 of 11
December 2007 (OJ L 10, 12.1.2008, p. 1).

AMC 20-21
http://www.mitrecaasd.org/atsrac/final_reports/Task_1&2_Final%20_August_20
00.pdf
— Aging Transport Systems Rulemaking Advisory Committee, Task 3, Final Report.
http://www.mitrecaasd.org/atsrac/final_reports/Task_3_Final.pdf
— Aging Transport Systems Rulemaking Advisory Committee, Task 4, Final Report,
Standard Wiring Practices.
http://www.mitrecaasd.org/atsrac/final_reports/Task_4_Final_Report_Sept_200
0.pdf
Aircraft Wiring Systems Training Curriculum and Lesson Plans.
http://www.mitrecaasd.org/atsrac/final_reports/Task_5_Final_March_2001%20.
pdf
— ATA Specification 117 (Wiring Maintenance Practices/Guidelines).
d. Other Documents
— Operator/Manufacturer Scheduled Maintenance Development, ATA Maintenance
Steering Group (MSG-3). May be obtained from the Air Transport Association of
America; Suite 1100, 1301 Pennsylvania Ave, NW, Washington, DC 20004-1707.
6 DEFINITIONS
Arc tracking: A phenomenon in which a conductive carbon path is formed across an insulating
surface. This carbon path provides a short circuit path through which current can flow. Normally
a result of electrical arcing. Also referred to as "Carbon Arc Tracking," "Wet Arc Tracking," or
"Dry Arc Tracking."
Combustible: For the purposes of this AMC the term combustible refers to the ability of any
solid, liquid or gaseous material to cause a fire to be sustained after removal of the ignition
source. The term is used in place of inflammable/flammable. It should not be interpreted as
identifying material that will burn when subjected to a continuous source of heat as occurs
when a fire develops.
Contamination: For the purposes of this AMC, wiring contamination refers to either of the
following:
— The presence of a foreign material that is likely to cause degradation of wiring;
— The presence of a foreign material that is capable of sustaining combustion after removal
of ignition source.
Detailed Inspection (DET): An intensive examination of a specific item, installation or assembly
to detect damage, failure or irregularity. Available lighting is normally supplemented with a
direct source of good lighting at an intensity deemed appropriate. Inspection aids such as
mirrors, magnifying lenses or other means may be necessary. Surface cleaning and elaborate
access procedures may be required.
Electrical Wiring Interconnection System (EWIS): See CS 25.1701.
Functional Failure: Failure of an item to perform its intended function within specified limits.
General Visual Inspection (GVI): A visual examination of an interior or exterior area, installation
or assembly to detect obvious damage, failure or irregularity. This level of inspection is made
from within touching distance unless otherwise specified. A mirror may be necessary to
enhance visual access to all exposed surfaces in the inspection area. This level of inspection is

AMC 20-21
made under normally available lighting conditions such as daylight, hangar lighting, flashlight or
droplight and may require removal or opening of access panels or doors. Stands, ladders or
platforms may be required to gain proximity to the area being checked.
Lightning/High Intensity Radiated Field (L/HIRF) protection: The protection of aeroplane
electrical systems and structure from induced voltages or currents by means of shielded wires,
raceways, bonding jumpers, connectors, composite fairings with conductive mesh, static
dischargers, and the inherent conductivity of the structure; may include aircraft specific devices,
e.g., RF Gaskets.
Maintenance: As defined in Regulation (EC) No 2042/2003 Article 2(h) “maintenance means
inspection, overhaul, repair, preservation, and the replacement of parts, but excludes
preventive maintenance.” For the purposes of this advisory material, it also includes preventive
maintenance.
Maintenance Significant Item (MSI): Items identified by the manufacturer whose failure could
result in one or more of the following:
— could affect safety (on ground or in flight);
— is undetectable during operations;
— could have significant operational impact;
— could have significant economic impact.
Needling: The puncturing of a wire’s insulation to make contact with the core to test the
continuity and presence of voltage in the wire segment.
Stand-alone GVI: A GVI which is not performed as part of a zonal inspection. Even in cases where
the interval coincides with the zonal inspection, the stand-alone GVI shall remain an
independent step within the work card.
Structural Significant Item (SSI): Any detail, element or assembly that contributes significantly
to carrying flight, ground, pressure or control loads and whose failure could affect the structural
integrity necessary for the safety of the aircraft.
Swarf: A term used to describe the metal particles, generated from drilling and machining
operations. Such particles may accumulate on and between wires within a wire bundle.
Zonal Inspection: A collective term comprising selected GVI and visual checks that are applied
to each zone, defined by access and area, to check system and powerplant installations and
structure for security and general condition.
7 BACKGROUND
Over the years there have been a number of in-flight smoke and fire events where
contamination sustained and caused the fire to spread. Regulators and Accident Investigators
have conducted aircraft inspections and found wiring contaminated with items such as dust,
dirt, metal shavings, lavatory waste water, coffee, soft drinks, and napkins. In some cases dust
has been found completely covering wire bundles and the surrounding area.
Research has also demonstrated that wiring can be harmed by collateral damage when
maintenance is being performed on other aircraft systems. For example a person performing
an inspection of an electrical power centre or avionics compartment may inadvertently cause
damage to wiring in an adjacent area.
In recent years regulator and industry groups have come to the realisation that current
maintenance practices may not be adequate to address aging non-structural systems. While age

AMC 20-21
is not the sole cause of wire degradation, the probability that inadequate maintenance,
contamination, improper repair or mechanical damage has caused degradation to a particular
EWIS increases over time. Studies by industry and regulator working groups have found that
although EWIS management is an important safety issue, there has been a tendency to be
complacent about EWIS. These working groups have concluded that there is a need to better
manage EWIS so that they continue to function safely.
8 WIRE DEGRADATION
Normal maintenance actions, even using acceptable methods, techniques and practices, can
over time be a contributing factor to wire degradation. Zones that are subject to a high level of
maintenance activity display more deterioration of the wiring insulation than those areas not
subject to frequent maintenance. Degradation of wiring is further accelerated when
inappropriate maintenance practices are used. Examples include the practice of needling wires
to test the continuity or voltage, and using a metal wire or rod as a guide to feed new wires into
an existing bundle. These practices could cause a breach in the wiring insulation that can
contribute to arcing.
Over time, insulation can crack or breach, thereby exposing the conductor. This breakdown,
coupled with maintenance actions, can exacerbate EWIS malfunction. Wiring that is
undisturbed will have less degradation than wiring that is disturbed during maintenance.
For additional information on the principle causes of wire degradation see Appendix E.
9 INSPECTION OF EWIS
Typical analytical methods used for the development of maintenance programmes have not
provided a focus on wiring. As a result most operators have not adequately addressed
deterioration of EWIS in their programmes. EASA has reviewed the current inspection
philosophies with the objectives of identifying improvements that could lead to a more
consistent application of the inspection requirements, whether they are zonal, stand-alone GVI,
or DET inspections.
EASA believes that it would be beneficial to provide guidance on the type of deterioration that
a person performing a GVI, DET, or zonal inspection would be expected to discover. Though it
may be realistically assumed that all operators provide such guidance to their inspectors, it is
evident that significant variations exist and, in certain areas of the world, a significant
enhancement of the inspection could be obtained if internationally agreed guidance material
could be produced. The guidance provided by this AMC assumes each operator will adopt recent
improvements made to the definitions of GVI and DET inspections. This information should be
incorporated in operators’ training material and in the introductory section of maintenance
planning documentation.
This section is divided into three parts. The first part addresses the levels of inspection
applicable to EWIS, the second part provides guidance for performing zonal inspections, and
the third part provides lists of installations and areas of concern.
a. Levels of inspection applicable to EWIS
(1) Detailed Inspection (DET)
An intensive examination of a specific item, installation or assembly to detect
damage, failure or irregularity. Available lighting is normally supplemented with a
direct source of good lighting at an intensity deemed appropriate. Inspection aids
such as mirrors, magnifying lenses or other means may be necessary. Surface
cleaning and elaborate access procedures may be required.

AMC 20-21
A DET can be more than just a visual inspection since it may include tactile
assessment in which a component or assembly is checked for tightness/security.
This is of particular significance when identifying applicable and effective tasks to
ensure the continued integrity of installations such as bonding jumpers, terminal
connectors, etc.
Though the term Detailed Visual Inspection remains valid for DET using only
eyesight, it should be recognised that this may represent only part of the inspection
called for in the source documents used to establish an operator’s Maintenance
Programme. For this reason it is recommend that the acronym “DVI” not be used
since it excludes tactile examination from this level of inspection.
(2) General Visual Inspection (GVI).
A visual examination of an interior or exterior area, installation or assembly to
detect obvious damage, failure or irregularity. This level of inspection is made from
within touching distance unless otherwise specified. A mirror may be necessary to
enhance visual access to all exposed surfaces in the inspection area. This level of
inspection is made under normally available lighting conditions such as daylight,
hangar lighting, flashlight or droplight and may require removal or opening of
access panels or doors. Stands, ladders or platforms may be required to gain
proximity to the area being checked.
Recent changes to this definition have added proximity guidance (within touching
distance) and the allowance to use a mirror to enhance visual access to exposed
surfaces when performing a GVI. These changes should result in more consistent
application of GVI and support the expectations of what types of EWIS
discrepancies should be detected by a GVI.
Though flashlights and mirrors may be required to provide an adequate view of all
exposed surfaces, there is no requirement for equipment removal or displacement
unless this is specifically called for in the access instructions. Paint and/or sealant
removal is not necessary and should be avoided unless the observed condition is
suspect. Should unsatisfactory conditions be suspected, items may need to be
removed or displaced in order to permit proper assessment.
It is expected that the area to be inspected is clean enough to minimise the
possibility that accumulated dirt or grease might hide unsatisfactory conditions
that would otherwise be obvious. Any cleaning that is considered necessary should
be performed in accordance with accepted procedures in order to minimise the
possibility of the cleaning process itself introducing anomalies.
In general, the person performing a GVI is expected to identify degradation due to
wear, vibration, moisture, contamination, excessive heat, aging, etc., and make an
assessment as to what actions are appropriate to address the noted discrepancy.
In making this assessment, any potential effect on adjacent system installations
should be considered, particularly if these include wiring. Observations of
discrepancies, such as chafing, broken clamps, sagging, interference,
contamination, etc., need to be addressed.
(3) Zonal Inspection
A collective term comprising selected GVI and visual checks that are applied to each
zone, defined by access and area, to check system and powerplant installations and

AMC 20-21
A zonal inspection is essentially a GVI of an area or zone to detect obvious

unsatisfactory conditions and discrepancies. Unlike a stand-alone GVI, it is not
directed to any specified component or assembly.
b. Guidance for zonal inspections
The following EWIS degradation items are typical of what should be detectable and
subsequently addressed as a result of a zonal inspection (as well as a result of a stand-
alone GVI). It is also recommended that these items be included in maintenance and
training documentation. This list is not intended to be exhaustive and may be expanded
as considered appropriate.
(1) Wire/Wire Harnesses
— Wire bundle/wire bundle or wire bundle/structure contact/chafing
— Wire bundle sagging or improperly secured
— Wires damaged (obvious damage due to mechanical impact, overheat,
localised chafing, etc.)
— Lacing tape and/or ties missing/incorrectly installed
— Wiring protection sheath/conduit deformity or incorrectly installed
— End of sheath rubbing on end attachment device
— Grommet missing or damaged
— Dust and lint accumulation
— Surface contamination by metal shavings/swarf
— Contamination by liquids
— Deterioration of previous repairs (e.g., splices)
— Deterioration of production splices
— Inappropriate repairs (e.g., incorrect splice)
— Inappropriate attachments to or separation from fluid lines
(2) Connectors
— External corrosion on receptacles
— Backshell tail broken
— Rubber pad or packing on backshell missing
— No backshell wire securing device
— Foolproofing chain broken
— Missing or broken safety wire
— Discoloration/evidence of overheat on terminal lugs/blocks
— Torque stripe misalignment
(3) Switches
— Rear protection cap damaged
(4) Ground points

AMC 20-21
— Corrosion
(5) Bonding braid/bonding jumper
— Braid broken or disconnected
— Multiple strands corroded
— Multiple strands broken
(6) Wiring clamps or brackets
— Corroded
— Broken/missing
— Bent or twisted
— Faulty attachment (bad attachment or fastener missing)
— Unstuck/detached
— Protection/cushion damaged
(7) Supports (rails or tubes/conduit)
— Broken
— Deformed
— Fastener missing
— Missing edge protection on rims of feed through holes
— Racetrack cushion damaged
— Obstructed drainage holes (in conduits)
(8) Circuit breakers, contactors or relays
— Signs of overheating
— Signs of arcing
c. Wiring installations and areas of concern
Research has shown that the following installations and areas need to be addressed in
existing maintenance material.
(1) Wiring installations
Clamping points – Wire chafing is aggravated by damaged clamps, clamp cushion
migration, or improper clamp installations. Aircraft manufacturers specify clamp
type and part number for EWIS throughout the aircraft. When replacing clamps use
those specified by the aircraft manufacturer. Tie wraps provide a rapid method of
clamping especially during line maintenance operations. Improperly installed tie
wraps can have a detrimental effect on wire insulation. When new wiring is
installed as part of a STC or any other modification the drawings will provide wiring
routing, clamp type and size, and proper location. Examples of significant wiring
modifications are the installation of new avionics systems, new galley installations
and new instrumentation. Wire routing, type of clamp and clamping location
should conform to the approved drawings. Adding new wire to existing wire
bundles may overload the clamps causing wire bundle to sag and wires to chafe.

AMC 20-21
Raceway clamp foam cushions may deteriorate with age, fall apart, and
consequently would not provide proper clamping.
Connectors – Worn environmental seals, loose connectors, missing seal plugs,
missing dummy contacts, or lack of strain relief on connector grommets can
compromise connector integrity and allow contamination to enter the connector,
leading to corrosion or grommet degradation. Connector pin corrosion can cause
overheating, arcing and pin-to-pin shorting. Drip loops should be maintained when
connectors are below the level of the harness and tight bends at connectors should
be avoided or corrected.
Terminations – Terminations, such as terminal lugs and terminal blocks, are
susceptible to mechanical damage, corrosion, heat damage and contamination
from chemicals, dust and dirt. High current-carrying feeder cable terminal lugs can
over time lose their original torque value due to vibration. One sign of this is heat
discoloration at the terminal end. Proper build-up and nut torque is especially
critical on high current carrying feeder cable lugs. Corrosion on terminal lugs and
blocks can cause high resistance and overheating. Dust, dirt and other debris are
combustible and therefore could sustain a fire if ignited from an overheated or
arcing terminal lug. Terminal blocks and terminal strips located in equipment
power centres (EPC), avionics compartments and throughout the aircraft need to
be kept clean and free of any combustibles.
Backshells – Wires may break at backshells, due to excessive flexing, lack of strain
relief, or improper build-up. Loss of backshell bonding may also occur due to these
and other factors.
Sleeving and Conduits – Damage to sleeving and conduits, if not corrected, may
lead to wire damage. Therefore, damage such as cuts, dents and creases on
conduits may require further investigation for condition of wiring within.
Grounding Points – Grounding points should be checked for security (i.e., finger
tightness), condition of the termination, cleanliness, and corrosion. Any grounding
points that are corroded or have lost their protective coating should be repaired.
Splices – Both sealed and non-sealed splices are susceptible to vibration,
mechanical damage, corrosion, heat damage, chemical contamination, and
environmental deterioration. Power feeder cables normally carry high current
levels and are very susceptible to installation error and splice degradation. All
splices should conform to the TC or STC holder’s published recommendations. In
the absence of published recommendations, environmental splices are
recommended to be used.
(2) Areas of concern
Wire Raceways and Bundles – Adding wires to existing wire raceways may cause
undue wear and chafing of the wire installation and inability to maintain the wire
in the raceway. Adding wire to existing bundles may cause wire to sag against the
structure, which can cause chafing.
Wings – The wing leading and trailing edges are areas that experience difficult
environments for wiring installations. The wing leading and trailing edge wiring is
exposed on some aircraft models whenever the flaps or slats are extended. Other
potential damage sources include slat torque shafts and bleed air ducts.

AMC 20-21
Engine, Pylon, and Nacelle Area – These areas experience high vibration, heat,
frequent maintenance, and are susceptible to chemical contamination.
Accessory compartment and equipment bays – These areas typically contain items
such as electrical components, pneumatic components and ducting, hydraulic
components and plumbing, and may be susceptible to vibration, heat, and liquid
contamination.
Auxiliary Power Unit (APU) – Like the engine/nacelle area, the APU is susceptible
to high vibration, heat, frequent maintenance, and chemical contamination.
Landing Gear and Wheel Wells – This area is exposed to severe external
environmental conditions in addition to vibration and chemical contamination.
Electrical Panels and Line Replaceable Units (LRU) – Panel wiring is particularly
prone to broken wires and damaged insulation when these high density areas are
disturbed during troubleshooting activities, major modifications, and
refurbishments. Wire damage may be minimised by tying wiring to wooden dowels
to reduce wire disturbance during modification. There may be some configurations
where connector support brackets would be more desirable and cause less
disturbance of the wiring than removal of individual connectors from the supports.
Batteries – Wires in the vicinity of all aircraft batteries are susceptible to corrosion
and discoloration. These wires should be inspected for corrosion and discoloration.
Discoloured wires should be inspected for serviceability.
Power Feeders – High current wiring and associated connections have the potential
to generate intense heat. Power feeder cables, terminals, and splices may be
subject to degradation or loosening due to vibration. If any signs of overheating
are seen, splices or termination should be replaced. Depending on design, service
experience may highlight a need to periodically check for proper torque of power
feeder cable terminal ends, especially in high vibration areas. This applies to galley
and engine/APU generator power feeders.
Under Galleys, Lavatories, and Cockpit – Areas under the galleys, lavatories, and
cockpit, are particularly susceptible to contamination from coffee, food, water, soft
drinks, lavatory fluids, dust, lint, etc. This contamination can be minimised by
adherence to proper floor panel sealing procedures in these areas.
Fluid Drain plumbing – Leaks from fluid drain plumbing may lead to liquid
contamination of wiring. In addition to routine visual inspections, service
experience may highlight a need for periodic leak checks or cleaning.
Fuselage Drain provisions – Some installations include features designed to catch
leakage that is plumbed to an appropriate exit. Blockage of the drain path can
result in liquid contamination of wiring. In addition to routine visual inspections,
service experience may highlight that these installations and associated plumbing
should be periodically checked to ensure the drain path is free of obstructions.
Cargo Bay/Underfloor – Damage to wiring in the cargo bay underfloor can occur
due to maintenance activities in the area.
Wiring subject to movement – Wiring that is subject to movement or bending
during normal operation or maintenance access should be inspected at locations
such as doors, actuators, landing gear mechanisms, and electrical access panels.

AMC 20-21
Access Panels – Wiring near access panels may receive accidental damage as a
result of repetitive maintenance access and thus may warrant special attention.
Under Doors – Areas under cargo, passenger and service entry doors are
susceptible to fluid ingress from rain, snow and liquid spills. Fluid drain provisions
and floor panel sealing should be periodically inspected and repaired as necessary.
Under Cockpit Sliding Windows – Areas under cockpit sliding windows are
susceptible to water ingress from rain and snow. Fluid drain provisions should be
periodically inspected and repaired as necessary.
Areas where wiring is difficult to access – Areas where wiring is difficult to access
(e.g., flight deck instrument panels, cockpit pedestal area) may accumulate
excessive dust and other contaminants as a result of infrequent cleaning. In these
areas it may be necessary to remove components and disassemble other systems
to facilitate access to the area.
10 ENHANCED ZONAL ANALYSIS PROCEDURE (EZAP)
The EZAP identified in Appendix A of this AMC is designed to permit appropriate attention to
be given to electrical wiring installations. This is achieved by providing a means to identify
applicable and effective tasks to minimise accumulation of combustible materials and address
wiring installation discrepancies that may not otherwise be reliably detected by inspections
contained in existing maintenance programmes.
For aircraft models operating on maintenance programmes that already include a dedicated
ZIP, the logic described in this AMC will result in enhancements to those programmes, and the
zonal inspection requirements may not differ greatly from the existing ZIP.
In analysis conducted under the EZAP, items such as plumbing, ducting, systems installations,
etc., should be evaluated for possible contribution to wiring failures. In cases where a GVI is
required to assess degradation of these items, a zonal GVI within a ZIP may be considered
appropriate.
For those operators that do not have a dedicated ZIP, application of the logic is likely to result
in identification of a large number of wiring-related tasks that will need to be consolidated
within the existing Systems/Powerplant Programme.
In either case, any new tasks identified by the logic may be compared with existing tasks and
credit given for equivalent tasks already contained in the maintenance programme. For
operators with ZIP that already contain zonal GVI, the number of new tasks that must be added
to the programme may be significantly fewer than for an operator without a dedicated ZIP.
Therefore, operators without a ZIP may find it beneficial to develop a ZIP in accordance with an
industry-accepted methodology in conjunction with application of the EZAP.
The logic and procedures identified in this AMC apply to TC, STC and other modifications. It is
expected that the TC and STC holders would use the logic and procedures to identify any need
for additional instructions for continued airworthiness. However, the operator may be required
to ensure the logic is used to identify such instructions for modifications or STC where they are
no longer supported by the design organisation or STC holder.
11 MAINTENANCE PRACTICES: PROTECTION AND CAUTION RECOMMENDATIONS
EASA has identified some specific maintenance and servicing tasks for which more robust
practices are recommended to be adopted by operators, and/or maintenance providers. These
recommendations apply to all tasks, including those performed on an unscheduled basis
without an accompanying routine job instruction card. Performance of these maintenance

AMC 20-21
practices will help prevent contamination of EWIS that result from contact with harmful solids
(such as metal shavings) or fluids during maintenance, modifications, and repairs of aeroplane
structures, and components. In addition, the training of maintenance and servicing personnel
should address the potential consequences of their actions on the wiring in the work vicinity.
a. Item 1: Installation, repair, or modification to wiring.
Wiring and its associated components (protective coverings, connectors, clamping
provisions, conduits, etc.) often comprise the most delicate and maintenance-sensitive
portions of an installation or system. Extreme care should be exercised and proper
procedures used during installation, repair, or modification of wiring to ensure safe and
reliable performance of the function supplied by the wiring.
Proper wire selection, routing/separation, clamping configurations, use of splices, repair
or replacement of protective coverings, pinning/de-pinning of connections, etc., should
be performed in accordance with the applicable sections of the Aircraft Maintenance
Manual (AMM), Wiring Practices Manual (WPM), or other documents authorised for
maintenance use. In addition, special care should be taken to minimise disturbance of
existing adjacent wiring during all maintenance activities. When wiring is displaced during
a maintenance activity, special attention should be given to returning it to its normal
configuration in accordance with the applicable maintenance instructions.
b. Item 2: Structural repairs, STC, modifications.
Structural repair, STC or modification activity inherently introduces tooling and residual
debris that is harmful to aircraft wiring. Structural repairs or modifications often require
displacement (or removal) of wiring to provide access to the work area. Even minor
displacement of wiring, especially while clamped, can damage wire insulation, which can
result in degraded performance, arcing, or circuit failure.
Extreme care should be exercised to protect wiring from mechanical damage by tools or
other equipment used during structural repairs, STC or modifications. Drilling blindly into
the aircraft structure should be avoided. Damage to wire installation could cause wire
arcing, fire and smoke. Wiring located adjacent to drilling or riveting operations should
be carefully displaced or covered to reduce the possibility of mechanical damage.
Debris such as drill shavings, liberated fastener pieces, broken drill bits, etc., should not
be allowed to contaminate or penetrate wiring or electrical components. This can cause
severe damage to insulation and potential arcing by providing a conductive path to
ground or between two or more wires of different loads. Once contaminated, removal of
this type of debris from wire bundles is extremely difficult. Therefore, precautions should
be taken to prevent contamination of any kind from entering the wire bundle.
Before initiating structural repair, STC or modification activity, the work area should be
carefully surveyed to identify all wiring and electrical components that may be subject to
contamination. All wiring and electrical components in the debris field should be covered
or removed to prevent contamination or damage. Consideration should be given to using
drills equipped with vacuum aspiration to further minimise risk of metallic debris
contaminating wire bundles. Clean electrical components and wiring after completion of
work per applicable maintenance instructions.
c. Item 3: Aircraft De-Icing or Anti-Icing.
In order to prevent damage to exposed electrical components and wiring in areas such as
wing leading and trailing edges, wheelwells, and landing gear, care should be exercised

AMC 20-21
when spraying de/anti-icing fluids. Direct pressure spray onto electrical components and
wiring can lead to contamination or degradation and thus should be avoided.
d. Item 4: Inclement weather.
EWIS in areas below doorways, floors, access panels, and servicing bays are prone to
corrosion or contamination due to their exposure to the elements. Snow, slush, or
excessive moisture should be removed from these areas before closing doors or panels.
Remove deposits of snow/slush from any items (e.g. cargo containers) before loading in
the aircraft. During inclement weather, keep doors/panels closed as much as possible to
prevent ingress of snow, slush, or excessive moisture that could increase potential for
EWIS degradation.
e. Item 5: Component removal/installation (relating to attached wiring).
Excessive handling and movement during removal and installation of components may
be harmful to aircraft wiring. Use appropriate connector pliers (e.g. soft jawed) to loosen
coupling rings that are too tight to be loosened by hand. Alternately, pull on the plug
body and unscrew the coupling ring until the connector is separated. Do not use excessive
force, and do not pull on attached wires. When reconnecting, special care should be taken
to ensure the connector body is fully seated, the jam nut is fully secured, and no tension
is on the wires.
When equipment is disconnected, use protective caps on all connectors (plug or
receptacle) to prevent contamination or damage of the contacts. Sleeves or plastic bags
may be used if protective caps are not available. Use of sleeves or plastic bags should be
temporary because of the risk of condensation. It is recommended to use a humidity
absorber with sleeves or plastic bags.
f. Item 6: Pressure Washing.
In order to prevent damage to exposed electrical components and wiring in areas such as
wing leading and trailing edges, wheelwells, and landing gear, care should be exercised
when spraying water or cleaning fluids. Direct high-pressure spraying onto electrical
components and wiring can lead to contamination or degradation and should be avoided.
When practical, wiring and connectors should be protected before pressure washing.
Water rinse should be used to remove cleaning solution residue after washing.
Breakdown of wire insulation may occur with long term exposure of wiring to cleaning
solutions. Although these recommendations are good practice and technique, the
aeroplane maintenance manual or STC holder’s instructions should be consulted for
additional detailed instructions regarding pressure washing.
g. Item 7: Cleaning of EWIS (in situ).
Extreme care should be exercised and proper procedures used during cleaning to ensure
safe and reliable performance of the function supplied by the wiring.
Care should be taken to avoid displacement or disturbance of wiring during cleaning of
non-aggressive contamination. However, in the event of contamination by aggressive
contaminants (e.g. livestock waste, salt water, battery electrolyte, etc.) such
displacement may be necessary. In these cases wiring should be released from its
installation so as to avoid undue stress being induced in wiring or connectors. Similarly,
if liquid contamination enters the bundle, then ties should be removed before separating
the wires. Although these recommendations for cleaning of EWIS are considered good
practice and technique, the aeroplane maintenance manual or STC holder’s instructions
should be consulted for additional detailed instructions.

AMC 20-21
Clean only the area and items that have contamination. Before cleaning, make sure that
the cleaning materials and methods will not cause more contamination. If a cloth is used,
make sure that it is clean, dry, and lint-free. A connector should be completely dry before
mating. Any fluids remaining on a connector can have a deteriorating affect on the
connector or the system or both.
h. Item 8: Servicing, modifying, or repairing waste/water systems.
EWIS in areas adjacent to waste/water systems are prone to contamination from those
systems. Care should be exercised to prevent any fluids from reaching electrical
components and wiring while servicing, modifying, or repairing waste/water systems.
Cover exposed electrical components and wiring during waste/water system
modification or repair. Operator practice may call for a weak acid solution to be
periodically flushed through lavatory systems to enhance reliability and efficiency of
operation. In view of the effect of acid contamination on systems and structure, the
system should be confirmed to be free of leaks before using such solutions.
i. Item 9: Servicing, modifying, or repairing oil systems.
Electrical wiring interconnections in areas adjacent to oil systems are prone to
contamination from those systems. To minimise the attraction and adhesion of foreign
material, care should be exercised to avoid any fluids from reaching electrical
components and wiring while servicing, modifying, or repairing oil systems. Oil and debris
in combination with damaged wiring can present a fire hazard.
j. Item 10: Servicing, modifying, or repairing hydraulic systems.
EWIS in areas adjacent to hydraulic systems are prone to contamination from those
systems. To minimise the attraction and adhesion of foreign material, care should be
exercised to avoid any fluids from reaching electrical components and wiring while
servicing, modifying, or repairing hydraulic systems.
k. Item 11: Gaining access (entering zones).
When entering or working on the aircraft, care should be exercised to prevent damage
to adjacent or hidden electrical components and wiring, including wiring that may be
hidden from view (e.g., covered by insulation blankets). Use protective boards or
platforms for adequate support and protection. Avoid using wire bundles as handholds,
steps and supports. Work lights should not be hung or supported by wiring. If wiring must
be displaced (or removed) for work area access, it should be adequately released from
its clamping (or other restraining provisions) to allow movement without damage and
returned after work is completed.
l. Item 12: Application of Corrosion Preventions Compounds (CPC).
When applying CPC in aeroplane zones containing wire and associated components (i.e.
clamps, connectors and ties), care should be taken to prevent CPC from coming in contact
with the wire and components. Dust and lint is more likely to collect on wire that has CPC
on it. Application of CPC should be done in accordance with the aircraft manufacturer’s
recommendations.
12 CHANGES
The programme to enhance EWIS maintenance also applies to EWIS installed, modified, or
affected by changes or STC. Changes that could affect EWIS include, but are not limited to, those
that install new equipment in close proximity to wiring, introduce a heat source in the zone, or
introduce potential sources of combustible material or harmful contamination into the zone.

AMC 20-21
The owner/operator is responsible for determining if the EWIS has been changed (or affected
by a change) and ensuring that their maintenance programme is enhanced as appropriate.
[Amdt 20/4]

AMC 20-21
Appendix A to AMC 20-21 Enhanced Zonal Analysis Logic Diagram

and Steps
Figure 1. Enhanced Zonal Analysis Procedure
1. Identify aircraft zones, including boundaries
2. List details of Zone, e.g.

- Access
- Installed equipment
- L/HIRF protection features
- Wire bundle installation
- Possible combustible materials
3.
Yes No
Zone contains
wiring?
4. 7.
Combustible No
No
materials in Is wiring close to both
zone? primary and back-up
hydraulic, mechanical, or
Yes electrical flight controls?
5. Yes
8.
Is there an effective No further action
task to significantly No Selection of wiring
reduce the likelihood inspection level and
of accumulation of interval
combustible materials?
See Figure 2.
Yes
6.
Inspection Task(s)
Define task and interval
9.
Continue the analysis
Consider consolidation with
GVI existing inspection tasks in
GVI consolidated
stand-alone GVI Systems & Powerplant and/or
in zonal inspection
DET Zonal Programmes
Maintenance Programme Maintenance Programme

Systems and Powerplant Zonal Section
Section Aircraft with ZIP
Recommend inclusion in
ATA 20

AMC 20-21
Figure 2. Step 8 - Wiring Inspection Level and Interval Selection
Using rating tables, assess zone attributes to

determine appropriate level of inspection
(examples provided in Appendix B)
Programmes with Zonal Inspection Programme Programmes without Zonal Inspection programme
List zone
Yes List zone
description
description and
and Yes boundaries for
boundaries Is GVI of all
Is zonal GVI GVI of all wiring
for zonal GVI wiring in the
alone in the zone
zone at same
effective for
Define interval effective
all wiring in
specific for all wiring in
the zone?
wiring in the the zone? Define specific
zone for wiring in the
which stand- zone for which
No
alone GVI is GVI at more
justified No
Zonal GVI must be frequent
augmented with Some wiring interval is
Define requires GVI at justified
stand-alone GVI
specific more frequent
and/or DET wiring in the interval and/or Define specific
inspection zone for DET inspection wiring in the
which DET is zone for which
justified DET is justified
Using rating tables, assess likelihood of damage to wiring in the zone

to determine an appropriate interval for each inspection task
identified
(examples provided in Appendix B)

AMC 20-21
Explanation for Steps in Enhanced Zonal Analyses Procedure Logic Diagram

The following paragraphs provide further explanation of each step in the Enhanced Zonal Analyses
Procedure logic, (Figures 1 and 2). It is recommended that, where possible, the analysts utilise the
availability of actual aircraft to ensure they fully understand the zones being analysed. This will aid in
determination of density, size, environmental issues, and accidental damage issues.
Step 1 “Identify aircraft zones, including boundaries”
The system consists of Major Zones, Major Sub Zones and Zones.
The zones, wherever possible, shall be defined by actual physical boundaries such as wing
spars, major bulkheads, cabin floor, control surface boundaries, skin, etc. and include
access provisions for each zone.
If the type design holder or operator has not yet established aircraft zones, it is
recommended that it does so. Whenever possible, zones should be defined using a
consistent method such as ATA iSpec 2200 (formerly ATA Spec 100), varied only to
accommodate particular design constructional differences.
Step 2 “List of details of zone”
An evaluation will be carried out to identify system installations, significant components,
L/HIRF protection features, typical power levels in any installed wiring bundles,
combustible materials (present or possible accumulation), etc.
With respect to power levels the analyst should be aware whether the bundle consists
primarily of main generator feeder cables, low voltage instrumentation wiring or
standard bus wiring. This information will later be used in determining the potential
effects of deterioration.
The reference to combustible materials highlights the need to assess whether the zone
might contain material/vapour that could cause a fire to be sustained in the event of an
ignition source arising in adjacent wiring. Examples include the possible presence of fuel
vapours, dust/lint accumulation and contaminated insulation blankets. See also under
Step 4 for further information.
For aircraft types whose design directives may not have excluded the possibility of
inadequate segregation between systems, the analyst should identify locations where
both primary and back-up flight controls are routed within 2 inches/50 mm of a wiring
harness. This information is required to answer the question in Step 7.
Step 3 “Zone contains wiring?”
This question serves as a means to eliminate from the EZAP those zones that do not
contain any wiring.
Step 4 “Combustible materials in zone?”
This question requires an evaluation of whether the zone might contain combustible
material that could cause a fire to be sustained in the event of an ignition source arising
in adjacent wiring. Examples include the possible presence of fuel vapours, dust/lint
accumulation, and contaminated insulation blankets.
With respect to commonly used liquids (e.g., oils, hydraulic fluids, corrosion prevention
compounds) the analyst should refer to the product specification in order to assess the
potential for combustibility. The product may be readily combustible only in vapour/mist

AMC 20-21
form and thus an assessment is required to determine if conditions might exist in the
zone for the product to be in this state.
Although liquid contamination of wiring by most synthetic oil and hydraulic fluids (e.g.
skydrol) may not be considered combustible, it is a cause for concern if it occurs in a zone
where it causes significant adherence of dust and lint.
The analyst should assess what sources of combustible products may contaminate the
zone following any single failure considered likely from in-service experience.
Unshrouded pipes having connections within the zone should be considered as potential
contamination sources. Inherent ventilation in the zone should be taken into account
when determining the potential for subsequent combustion. This influences the response
to the question of how near to the harness the source should be for there to be a concern.
Avionics and instruments located in the flight compartment and equipment bays tend to
attract dust, etc. In view of the heat generated by these components and the relatively
tightly packed installations, the analyst should consider these zones as having potential
for combustible material. Thus, the enhanced logic should always be used for these
zones.
Note: Although moisture (whether clean water or otherwise) is not combustible, its
presence on wiring is a cause for concern because it may increase the probability of arcing
from small breaches in the insulation, which could cause a localised fire in the wire
bundle. The risk of a sustained fire caused by moisture induced arcing is mitigated in Step
5 by identification of a task to reduce the likelihood of accumulation of combustible
material on or adjacent to the wiring.
Step 5 “Is there an effective task to significantly reduce the likelihood of accumulation of
combustible materials?”
Most operator maintenance programmes have not included tasks directed towards
removal or prevention of significant accumulations of combustible materials on or
adjacent to wiring.
This question requires an evaluation of whether the accumulation on or adjacent to
wiring can be significantly reduced. Task effectiveness criteria should include
consideration of the potential for damaging the wiring.
Though restoration tasks (e.g., cleaning) are the most likely applicable tasks, the
possibility to identify other tasks is not eliminated. A detailed inspection of a hydraulic
pipe might be assessed as appropriate if high-pressure mist from pinhole corrosion could
impinge a wire bundle and the inherent zone ventilation is low.
Step 6 “Define task and interval”
This step will define an applicable task and an effective interval. It should be included as
a dedicated task in the Systems and Powerplant section. Within Maintenance Review
Board (MRB) Reports, this may be introduced under ATA 20 with no Failure Effect
Category quoted.
It is not the intent that restoration tasks should be so aggressive as to damage the wiring,
but should be applied to a level that significantly reduces the likelihood of combustion.
Step 7 “Is wiring close to primary and back-up hydraulic, mechanical, or electrical flight
controls?”

AMC 20-21
Where wiring is close (i.e. within 5 cm (2 inches)) to both primary and back-up hydraulic,
mechanical, or electrical flight controls, this question is asked to ensure that Step 8 logic
is applied even in the absence of combustible materials in the zone.
For zones where combustible materials are present (as determined in Step 4), proximity
is addressed in the inspection level definition portion of Step 8 and this question need
not be asked.
It addresses the concern that segregation between primary and back-up flight controls
may not have been consistently achieved. Even in the absence of combustible material,
a localised wire arcing could impact continued safe flight and landing if hydraulic pipes,
mechanical cables, or wiring for fly-by-wire controls are routed in close proximity (i.e.
within 5 cm (2 inches)) to a wiring harness. In consideration of the redundancy in flight
control systems, the question needs to be answered ‘Yes’ only if both the primary and
back-up system might be affected by wire arcing. Note that in zones where a fire might
be sustained by combustible material the enhanced logic will automatically be followed.
On all aircraft type designs, irrespective of TC date, modifications may not have taken
into account the TC holder’s design and installation criteria. It is thus recommended that
STC holders assess their design changes with this question included in the logic unless
they can demonstrate that they followed equivalent installation criteria. Similarly, air
carriers and air operators will have to assess modifications that have been accomplished
on their aircraft.
Step 8 “Selection of Wiring Inspection Level and Interval”
a. Inspection Level.
At this point in the analysis, it is already confirmed that wiring is installed in a zone
where the presence of combustible materials is possible and/or the wiring is in
close proximity to primary and back-up hydraulic or mechanical flight controls.
Therefore, some level of inspection of the wiring in the zone is required, and this
step details how the proper level of inspection and interval can be selected.
One method of selecting the proper inspection level and interval is through the use
of ratings tables which rate attributes of the zone and how the wiring is affected
by, or can affect those attributes. The precise format of this will be determined by
the analyst, but example rating tables appear in Appendix B and may be referred
to for clarity.
The inspection level characteristics that may be included in the rating system are:
— Zone size (volume);
— Density of installed equipment within the zone;
— Potential effects of fire on adjacent wiring and systems.
Zone size will be assessed relative to the size of the aircraft, typically identified as
small, medium or large. The smaller the zone and the less congested it is, the more
likely it is that wiring degradation will be identified by GVI.
Density of installed equipment, including wiring, within the zone will be assessed
relative to the size of the zone. The density of the zone is typically identified as low,
medium or high.
Potential effects of fire on adjacent wiring and systems requires the analyst to
assess the potential effect of a localised fire on adjacent wiring and systems by

AMC 20-21
considering the potential for loss of multiple functions to the extent that continued
safe operation may not be possible.
Consideration of potential effect must also include whether wiring is in close
proximity (i.e. within 5 cm (2 inches)) to both primary and back-up flight controls.
A GVI alone may not be adequate if a fire caused by failure of the wiring poses a
risk to aircraft controllability.
At minimum, all wiring in the zone will require a GVI at a common interval. For
operators with a ZIP, this may be defined as a zonal GVI. For operators without ZIP,
it shall be defined as a GVI of all wiring in the zone.
The question is asked, "Is a GVI (or zonal GVI) of all wiring in the zone at the same
interval effective for all wiring in the zone?" This is to consider if there are specific
items/areas in the zone that are more vulnerable to damage or contamination and
thus may warrant a closer or more frequent inspection.
This determination could result in the selection of a more frequent GVI, a stand-
alone GVI (for operators with a ZIP), or even a DET inspection. The intention is to
select a DET of wiring only when justified by consideration of all three
characteristics of the zone (size, density, and potential effect of fire). The analyst
should be cautious to avoid unnecessary selection of DET where GVI is adequate.
Over-use of DET dilutes the effectiveness of the inspection.
Note: The level of inspection required may be influenced by tasks identified in
Steps 5 and 6. For example, if a cleaning task was selected in Step 5 and 6 that will
minimise the accumulation of combustible materials in the zone, this may justify
selection of a GVI in lieu of a DET for the wiring in the zone.
b. Inspection Interval.
The selection of an effective interval can also be accomplished using a rating
system. The characteristics for wiring to be rated should include the following:
— Possibility of Accidental Damage;
— Environmental factors.
The rating tables should be designed to define increasing inspection frequency
with increasing risk of accidental damage and increasing severity of the local
environment within the zone. Examples are provided in Appendix E.
The selection of inspection tasks possible in this step is specific to whether the
maintenance programme includes a dedicated ZIP or not.
For ZIP programmes, the possible inspection tasks are:
— Zonal GVI;
— Stand-alone GVI;
— DET.
For non-ZIP programmes, the possible inspection tasks are:
— GVI;
— DET.
Note: At this point the analyst will have determined the required inspection level
and interval for wiring in the zone. Task consolidation in Step 9 allows

AMC 20-21
consideration as to whether an inspection selected as a result of this analysis can

be considered accomplished as part of the existing maintenance programme.
Step 9 “Task Consolidation”
This step in the procedure examines the potential for consolidation between the tasks
derived from the EZAP and inspections that already exist in the Maintenance Programme.
Consolidation requires that the inspections in the existing maintenance programme are
performed in accordance with the inspection definitions provided in this AMC.
For programmes that include a ZIP:
Some GVI identified by application of the EZAP may be adequately covered by existing
zonal GVI in the zone and no change or addition to the existing zonal GVI is required. This
should reduce the number of new GVI that must be introduced into a programme that
already includes a ZIP.
The consolidation of GVI tasks has to take into account the access requirements and the
interval of each task. The Working Group may conclude that a stand-alone GVI of the
wiring may be justified if the zonal GVI of the other systems within the same zone does
not need to have such a frequent inspection.
Stand-alone GVI and DET identified by application of EZAP cannot be consolidated into
the ZIP and must be introduced and retained as dedicated tasks in the scheduled
maintenance programme under ATA 20. These tasks, along with tasks identified to reduce
the accumulation of combustible materials, shall be uniquely identified to ensure they
are not consolidated in the zonal programme nor deleted during future programme
development. Within MSG-3 based MRB Reports, these may be introduced under ATA 20
with no Failure Effect Category quoted.
For programmes without a ZIP:
Although non-ZIP programmes may already include some dedicated inspections of wiring
that may be reviewed for equivalency to new tasks identified by application of the EZAP,
it is expected that a significant number of new wiring inspections will be identified for
introduction as dedicated tasks in the System and Powerplant programme. All new tasks
identified by application of EZAP shall be uniquely identified to ensure they are not
deleted during future programme development.
The following guide can be used to determine proper consolidation between EZAP
derived inspections and existing inspections that have not been specifically identified as
stand-alone tasks, of the same item or area:
a. Where the EZAP inspection interval and existing inspection interval are equal, but
the inspection levels are different, the more intense inspection will take precedent
(i.e. a 1C DET takes precedent over a 1C GVI).
b. Where the EZAP inspection interval and existing inspection interval are different,
but the inspection levels are equal, the more frequent inspection will take
precedent (i.e. a 1C GVI takes precedent over a 2C GVI).
c. Where the EZAP inspection interval and level are different from the existing
inspection interval and level, these tasks may be consolidated only when the more
frequent inspection is also the more intense (i.e. a 1C DET takes precedent over a
2C GVI). When the more frequent inspection is less intense, the tasks should not
be consolidated.

AMC 20-21
For all programmes, these tasks shall be uniquely identified in the programme for future
development consideration.
For EZAP-derived STC tasks, it may not be possible for the STC holder to determine
whether a ZIP exists on specific aircraft that will utilise the STC. Therefore, where a ZIP
exists, consolidation of EZAP-derived STC tasks into a specific operator’s ZIP will be the
responsibility of the operator and subject to approval by the competent authority.
In cases where the STC holder determines a requirement for a GVI that should not be
consolidated into a ZIP, this stand-alone GVI should be specifically identified as such in
the EZAP derived ICAW for the STC.
[Amdt 20/4]

AMC 20-21
Appendix B to AMC 20-21 Examples of Typical EZAP Worksheets

The following worksheets are provided as an example to assist implementation of the EZAP logic explained
in this AMC. These may be adjusted by the analyst to suit specific applications.
1. Details of Zone.
2. Assessment of Zone Attributes.
3A. Inspection Level Determination based on Rating Tables (for use where a dedicated ZIP exists).
3B. Inspection Level Determination based on Rating Tables (for use where no dedicated ZIP exists).
4. Interval Determination based on Rating Tables.
5. Task Summary.
In particular, the interval ranges quoted in the rating table on Sheet 4 are solely to explain a typical
arrangement of values. For a particular application, these must be compatible with the interval framework
used in the existing maintenance or inspection programme. They may be expressed in terms of usage
parameter (e.g. flight hours or calendar time) or in terms of letter check (as in the example).

AMC 20-21
Enhanced Zonal Analysis - Details of Zone Sheet 1 of 5
ZONE NO: ZONE DESCRIPTION:
1. Zone Details (Boundaries, Access):
2. EQUIPMENT INSTALLED COMMENTS
Hydraulic Plumbing
Hydraulic Components (valves, actuators, pumps)

This sheet is used to comply with Steps 1 and 2 of
Pneumatic Plumbing the Enhanced Zonal Analysis Procedure:
Pneumatic Components (valves, actuators)

1. Describe the zone (location, access, boundaries)
Electrical Wiring - Power Feeder (high voltage, high amperage)
2. List the content of the zone; installed equipment,
Electrical Wiring - Motor Driven Devices wiring, plumbing, components, etc.
Electrical Wiring - Instrumentation, and Monitoring In the comments section on this sheet, it would be
Electrical Wiring - Data Bus appropriate to note significant wire related items
such as "Wire bundle routed within 2" of high-temp
Electrical Components anti-ice ducting". The intent is to provide the analyst
with a clear understanding of what's in the zone and
Primary Flight Control Mechanisms
how it could potentially affect wiring.
Secondary Flight Control Mechanisms
Engine Control Mechanisms
Fuel Components
Insulation
Oxygen
Potable Water
Waste Water
Sample EZAP Worksheet Date: Page 1 of 5

AMC 20-21
Enhanced Zonal Analysis - Assessment of Zone Attributes Sheet 2 of 5
Steps 1 and 2 completed on Sheet 1.

Answers and Explanation to Questions
(Note: Steps 1 & 2 completed on Sheet 1.)
N
3. Zone contains wiring?
Y
3.
This sheet is used to answer Questions 3 thru 7 of the
Enhanced Zonal Analysis Procedure.
7. Is wiring close to If the answer to Questions 3 and 7 is 'NO', then no further

both primary and back- action is required in this analysis which is designed to address
N N
4. Combustible materials in up hydraulic,
zone? mechanical, or
No further action. 4. only wiring systems.
electrical flight
Y controls? Y If the answer to Question 5 is 'YES', and a task is identified
that can significantly reduce the likelihood of accumulation of
combustible materials, the task and interval must be defined in
Step 6. If the task identified is a cleaning task to remove
5. dust/lint accumulation from wiring, the interval for the task must
be frequent enough to keep the wiring relatively clean based
5. Is there an effective task 8. Wiring on the expected rate of accumulation of dust/lint on the wiring in
to significantly reduce the N inspection task the zone.
likelihood of accumulation determination.
of combustible materials? See Sheet 3.
In all cases, after Step 5 and/or Step 6, the analysis is
Y
6. continued to Step 8.
6. Define task and interval. Continue the analysis

List on Sheet 5, Task
7.
Summary.
Sample EZAP Worksheet Date: Page 2 of 5

AMC 20-21

AMC 20-21

AMC 20-21
Enhanced Zonal Analysis - Interval Determination Based on Hostility of Environment and Likelihood of Accidental Damage Sheet 4 of 5
Interval selection is specific to each task identified on Sheet 3A or 3B. For GVI of entire zone, consider overall zone environment and likelihood of
damage. For Stand-alone GVI or DET, consider environment and likelihood of damage only in respect to the specific item/area defined for
inspection.
Item/Area Defined for Inspection:
Inspection Level:
Hostility of Environment Likelihood of Accidental Damage

1 - Passive, 2 - Moderate, 3 - Severe 1 - Low, 2 - Medium, 3 - High
Temperature Ground Handling Equipment
Vibration F. O. D.
Chemicals (toilet fluids, etc.) Weather Effects (hail, etc.)
Humidity Frequency of Maintenance Activities
Contamination Fluid Spillage
Other - Passenger Traffic
Highest Result Other -
Highest Result
Interval Determination
Likelihood of Accidental Damage
1 2 3
1 4C-6C 2C-4C 1C-2C

Hostility of
Environment 2 2C-6C 1C-4C A-1C
3 1C-6C 1C-4C A-1C
RESULT
Upon completion, enter all task and interval selections onto Sheet 5, Task Summary.
Sample EZAP Worksheet Date: Sheet 4 of 5

AMC 20-21
Enhanced Zonal Analysis - Task Summary Sheet 5 of 5
Zone Description:
TASK SUMMARY
Task Number Access Interval Task Description
This Sheet is used to list all tasks and intervals selected

as a result of EZAP analysis.
Sample EZAP Worksheet Date: Sheet 5 of 5

[Amdt AMC/4]

AMC 20-21
Appendix C to AMC 20-21 Determination if a major change to an

aircraft should be specifically subjected to an EZAP
The EZAP provides a means for TC and STC holders to develop improvements to EWIS maintenance
programs. These improvements will be in the form of new inspections and other tasks designed to
prevent significant accumulation of combustible materials on or adjacent to EWIS components that
would be added to the Instructions for Continued Airworthiness or Service Bulletins (SB) for the
aircraft and STC.
While TC holders are required to conduct the EZAP for all zones in an aircraft, it may be determined
that EZAP for an SB or STC is not necessary where the modification does not appreciably affect the
zones where it is installed. The “Determination if SB modification or STC requires EZAP” procedure
was developed to identify modifications that sufficiently affect zone attributes to warrant re-
application of EZAP to the entire zone.
This logic assumes that the aircraft TC holder has accomplished the EZAP on each zone of the aircraft
without consideration of the SB modification or STC installation. The objective of this analysis is to
assess whether the modification itself has affected wiring or certain zone attributes that could change
the outcome of the EZAP performed by the aircraft TC holder.
The determination if the SB or STC requires EZAP, and re-application of the EZAP to SB or STC affected
zones, is the responsibility of the respective holder of the SB or STC. It is expected that the TC and STC
holders will collaborate with each other and operators as necessary to obtain information required to
conduct the analysis. The TC or STC holder should communicate the results of the procedure, including
the cases when no new tasks are identified. The method of communication may be via SB, Service
Letter, ICAW Revision, or other means acceptable to EASA.
In situations where a previously installed STC is no longer supported by a viable STC holder (e.g. STC
holder defunct), the responsibility for determining if the STC requires EZAP, and re-application of EZAP
to any affected zones, is assigned to the individual operators who utilise the STC on their aircraft. In
cases where the operator does not have experience in application of analytical logic processes, it will
be necessary for the operator to gain competence in, or seek external assistance in conducting the
analysis.
A record of the outcome of operator accomplished analysis for STC (even if no tasks are identified)
should be permanently retained by the operator. A copy of the record should be included in the
aircraft records normally transferred upon change of aircraft operator.
The attached logic chart provides a means to assess whether an SB modification or STC has sufficiently
affected wiring or certain other zone attributes as to require reapplication of the EZAP to the entire
zone with consideration of the modification present. The section following the chart provides detailed
explanations of each step in the “Determination if SB modification or STC requires EZAP” with
appropriate examples.
It is recommended that, where possible, the analyst should utilise the availability of actual aircraft to
ensure they fully understand the zones being analysed. Specifically, it must be determined how
installation of the modification could affect zone attributes such as density, environment, proximity
of wiring to primary and back-up flight controls, presence of combustible materials, and potential for
accidental damage to wiring.

AMC 20-21
Appendix C. Figure 1. Determination if SB modification or STC requires EZAP
1
Does the STC:
- affect or modify wiring or its environment
- install or result in wiring being located
within 5 cm (2 inches) of both primary & backup hydraulic,
mechanical, or
electrical flight controls
- change the density of the zone, or NO 2
- change the potential effects of fire in the zone?
No further action required
YES
3
Perform EZAP analysis
4 5
Determine if there is an existing YES No further action required because the existing
MRBR EZAP task(s) that is
EZAPderived maintenance task is adequate
applicable and effective?
NO
6
Develop appropriate task and incorporate it into
existing maintenance program
Explanation of Steps
Step 1: Does the SB or STC affect or modify wiring or it’s environment?
The question asks whether the STC affects or modifies wiring. Modifications to wiring or
other EWIS components include, but are not limited to removal, addition, relocation, etc.
Does the SB or STC install or result in wiring being located within 5 cm (2 inches) of
primary and back-up hydraulic, mechanical or electric flight controls, change the density
of the zone or change the potential effects of fire in the zone?
Does the SB or STC affect zone density? If the STC includes the addition or deletion of
numerous components in a small area, the density of the zone could be changed even if
wire bundles are untouched. A significant change in the zone density should warrant re-
analysis of the zone.
Potential effects of fire on adjacent wiring and systems require the analyst to assess the
potential effect of a localised fire on adjacent wiring and systems by considering the
potential for loss of multiple functions to the extent that a hazard could be introduced.

AMC 20-21
Consideration of potential effect must also include whether wiring is in close proximity
(i.e. within 5 cm (2 inches)) to both primary and back-up flight controls.
Additionally, this question requires an evaluation of whether the zone might contain
combustible material that could cause a fire to be sustained in the event of an ignition
source arising in adjacent wiring. Examples include the possible presence of fuel vapours,
dust/lint accumulation, and contaminated insulation blankets.
With respect to commonly used liquids (e.g. oils, hydraulic fluids, and corrosion
prevention compounds), the analyst should refer to the product specification in order to
assess the potential for combustibility. The product may be readily combustible only in
vapour/mist form and thus an assessment is required to determine if conditions might
exist in the zone for the product to be in this state.
Although liquid contamination of wiring by most synthetic oil and hydraulic fluids (e.g.
skydrol) may not be considered combustible, it is a cause for concern if it occurs in a zone
where contamination causes significant adherence of dust and lint.
If the answer to this question is ‘No’, then no further action is required (Step 2), since the
density of the zone or the potential effects of fire in the zone has not changed.
Step 2: No further action is required.
Step 3: Perform an EZAP analysis.
If the answer to question 1 is ‘Yes’, then the only way to determine if existing EWIS
maintenance tasks are sufficient is to perform the EZAP for the SB or STC and compare
the results with the existing EWIS maintenance tasks (see Step 4).
Step 4: Is there an existing MRBR EZAP task(s) that is applicable and effective?
Once the SB or STC EZAP has been accomplished, a comparison of the derived
maintenance tasks can be made with the existing EWIS maintenance tasks. If the existing
tasks are adequate, then no further action regarding EWIS maintenance actions for the
STC is necessary.
Step 5: No further action is required since the existing EZAP-derived maintenance task is
adequate.
Step 6: Develop an appropriate task and incorporate it into the existing maintenance
programme.
These tasks should be incorporated into the operator’s existing maintenance programme.
[Amdt 20/4]

AMC 20-21
Appendix D to AMC 20-21

(RESERVED)

AMC 20-21
Appendix E to AMC 20-21 Causes of Wire Degradation

The following items are considered principal causes of wiring degradation and should be used to help
focus maintenance programmes:
Vibration - High vibration areas tend to accelerate degradation over time, resulting in “chattering”
contacts and intermittent symptoms. High vibration of tie-wraps or string-ties can cause damage to
insulation. In addition, high vibration will exacerbate any existing problem with wire insulation
cracking.
Moisture - High moisture areas generally accelerate corrosion of terminals, pins, sockets, and
conductors. It should be noted that wiring installed in clean, dry areas with moderate temperatures
appears to hold up well.
Maintenance - Scheduled and unscheduled maintenance activities, if done improperly, may contribute
to long-term problems and wiring degradation. Certain repairs may have limited durability and should
be evaluated to ascertain if rework is necessary. Repairs that conform to manufacturers
recommended maintenance practices are generally considered permanent and should not require
rework. Furthermore, care should be taken to prevent undue collateral damage to EWIS while
performing maintenance on other systems.
Metal shavings and debris have been discovered on wire bundles after maintenance, repairs,
modifications, or STC have been performed. Care should be taken to protect wire bundles and
connectors during modification work. The work areas should be cleaned while the work progresses to
ensure that all shavings and debris are removed; the work area should be thoroughly cleaned after
the work is complete; and the work area should be inspected after the final cleaning.
Repairs should be performed using the most effective methods available. Since wire splices are more
susceptible to degradation, arcing, and overheating, the recommended method of repairing a wire is
with an environmental splice.
Indirect Damage - Events such as pneumatic duct ruptures or duct clamp leakage can cause damage
that, while not initially evident, can cause wiring problems at a later stage. When events such as these
occur, surrounding EWIS should be carefully inspected to ensure that there is no damage or no
potential for damage is evident. The indirect damage caused by these types of events may be broken
clamps or ties, broken wire insulation, or even broken conductor strands. In some cases the pressure
of the duct rupture may cause wire separation from the connector or terminal strip.
Contamination - Wire contamination refers to either of the following situations:
a. The presence of a foreign material that is likely to cause degradation of wiring.
b. The presence of a foreign material that is capable of sustaining combustion after removal of
ignition source.
The contaminant may be in solid or liquid form. Solid contaminants such as metal shavings, swarf,
debris, livestock waste, lint and dust can accumulate on wiring and may degrade or penetrate wiring
or electrical components.
Chemicals in fluids such as hydraulic fluid, battery electrolytes, fuel, corrosion inhibiting compounds,
waste system chemicals, cleaning agents, de-icing fluids, paint, soft drinks and coffee can contribute
to degradation of wiring.
Hydraulic fluids, de-icing fluids and battery electrolyte require special consideration. These fluids,
although essential for aircraft operation, can damage connector grommets, wire bundle clamps, wire
ties and wire lacing, causing chafing and arcing. Wiring exposed to these fluids should be given special

AMC 20-21
attention during inspection. Contaminated wire insulation that has visible cracking or breaches to the
core conductor can eventually arc and cause a fire. Wiring exposed to, or in close proximity to, any of
these chemicals may need to be inspected more frequently for damage or degradation.
When cleaning areas or zones of the aircraft that contain both wiring and chemical contaminants,
special cleaning procedures and precautions may be needed. Such procedures may include wrapping
wire and connectors with a protective covering prior to cleaning. This would be especially true if
pressure-washing equipment is utilised. In all cases the aircraft manufacturer recommended
procedures should be followed.
Waste system spills also require special attention. Service history has shown that these spills can have
detrimental effects on aircraft EWIS and have resulted in smoke and fire events. When this type of
contamination is found all affected components in the EWIS should be thoroughly cleaned, inspected
and repaired or replaced if necessary. The source of the spill or leakage should be located and
corrected.
Heat - Exposure to high heat can accelerate degradation of wiring by causing insulation dryness and
cracking. Direct contact with a high heat source can quickly damage insulation. Burned, charred or
even melted insulation are the most likely indicators of this type of damage. Low levels of heat can
also degrade wiring over a longer period of time. This type of degradation is sometimes seen on
engines, in galley wiring such as coffee makers and ovens, and behind fluorescent lights, especially the
ballasts.
[Amdt 20/4]

AMC 20-22
AMC 20-22
AMC 20-22 Aeroplane Electrical Wiring Interconnection System

Training Programme
1 PURPOSE
This AMC provides acceptable means of compliance for developing an enhanced Electrical
Wiring Interconnection System (EWIS) training programme. The information in this AMC is
derived from the best practices training developed through extensive research. This AMC is an
effort by the Agency to officially endorse these best practices and to dispense this information
industry-wide so that the benefits of this information can be effectively realised. Following this
AMC will result in a training programme that will improve the awareness and skill level of the
aviation personnel in EWIS production, modification, maintenance, inspection, alterations and
repair. This AMC promotes a philosophy of training for all personnel who come into contact
with aeroplane EWIS as part of their job and tailors the training for each workgroup to their
particular needs.
2 OBJECTIVE
This AMC has been published in order to provide the approved organisations with acceptable
means of compliance to comply with their training obligations as required in paragraphs
21.A.145 and 21.A.245 of Part-21, 145.A.30 and 145.A.35 of Part-145 and M.A.706 of Part-M
with respect to EWIS.
To fully realise the objectives of this AMC, operators, holders of type certificates (TC), holders
of supplemental type certificates (STC), maintenance organisations and persons performing
modifications or repairs, will need to rethink their current approach to maintaining and
modifying aeroplane wiring and systems. This may require more than simply updating
maintenance manuals and work cards and enhancing training. Maintenance personnel need to
be aware that aeroplane EWIS should be maintained with the same level of intensity as any
other system in the aeroplane. They also need to recognise that visual inspection of wiring has
inherent limitations. Small defects such as breached or cracked insulation, especially in small
gage wire may not always be apparent. Therefore, effective wiring maintenance combines
visual inspection techniques with improved wiring maintenance practices and training.
The objective of this EWIS training programme is to give operators, holders of TC, holders of
STC, maintenance organisations and persons performing field approval modifications or repairs
a model for the development of their own EWIS training programme. This will ensure that
proper procedures, methods techniques, and practices are used when performing
maintenance, preventive maintenance, inspection, alteration, and cleaning of EWIS.
The training syllabus and curriculum for those personnel directly involved in the maintenance
and inspection of EWIS, identified as Target Group 1 and 2, are in Appendix A and C to this AMC.
This AMC also provides guidance on the development of EWIS training programmes for
personnel who are not directly involved in the maintenance and inspection of EWIS. Although
there is no direct regulatory requirement for EWIS training of these personnel, operators may
choose to provide EWIS training. The training syllabus and curriculum for these personnel,
identified as Target Groups 3 through 8, are in Appendix B and C to this AMC.
It is believed that training personnel in these groups would greatly enhance awareness of the
importance of EWIS safety in the overall safe operation of aeroplanes. Although these groups

AMC 20-22
are not directly involved in the maintenance of EWIS, they have the potential to have an adverse
impact on EWIS. This can occur through inadvertent contact with EWIS during aeroplane
cleaning or when individuals perform unrelated maintenance that could impact the integrity of
EWIS. Mechanics leaving drill shavings on wire bundles is one example of how this could occur.
Some people prepare paperwork that guides mechanics, training this target group in EWIS
should help to ensure that proper attention is paid to EWIS issues.
This programme was developed for eight different target groups and may be used for the
minimum requirements for initial and recurrent training (see training matrix). Depending on the
duties, some may fall into more than one target group and, therefore, must fulfil all objectives
of the associated target groups. The target groups are:
a. Qualified staff performing EWIS maintenance.
These staff members are personnel who perform wiring systems maintenance and their
training is based on their job description and the work being done by them (e.g. avionics
skilled workers or technicians cat B2).
b. Qualified staff performing maintenance inspections on wiring systems.
These staff members are personnel who perform EWIS inspections (but not
maintenance), and their training is based on their job description and the work being
done by them (e.g. inspectors/technicians cat B2).
c. Qualified staff performing electrical/avionic engineering on in-service aeroplane.
These staff members are personnel who are authorised to design EWIS installations,
modifications and repairs (e.g. electric/avionic engineers).
d. Qualified staff performing general maintenance/inspections not involving wire
maintenance (LRU change is not considered wire maintenance).
These staff members are personnel who perform maintenance on aeroplane that may
require removal/reconnection of electrical connective devices (e.g.
inspectors/technicians cat A or B1).
e. Qualified staff performing other engineering or planning work on in-service aeroplane.
These staff members are personnel who are authorised to design mechanical/structure
systems installations, modifications and repairs, or personnel who are authorised to plan
maintenance tasks.
f. Other service staff with duties in proximity to EEWIS.
These staff members are personnel whose duties would bring them into contact/view of
aeroplane wiring systems. This would include, but not be limited to: Aeroplane cleaners,
cargo loaders, fuelers, lavatory servicing personnel, de-icing personnel, push back
personnel.
g. Flight Deck Crew.
(E.g. Pilots, Flight Engineers)
h. Cabin Crew.
3 APPLICABILITY
This AMC describes acceptable means, but not the only means, of compliance with the
appropriate certification, maintenance and operating regulations.

AMC 20-22
The information in this AMC is based on lessons learned by Aging Transport Systems Rulemaking
Advisory Committee (ATSRAC) Harmonised Working Groups, regulatory authorities,
manufacturers, airlines and repair stations. This AMC can be applied to any aeroplane training
programme.
4 RELATED DOCUMENTS
a. EASA AMC-20
— AMC 20-21 Programme to Enhance Aeroplane Electrical Wiring Interconnection
System Maintenance
— AMC 20-23 Development of Electrical Standard Wiring Practices Documentation
b. FAA 14 CFR Parts
— Part 21, Certification Procedures for Products and Parts
— Part 25, Airworthiness Standards, Transport Category Aeroplanes
— Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration
— Part 91, General Operating and Flight Rules
— Part 119, Certification: Air Carriers and Commercial Operators
— Part 121, Operating Requirements: Domestic, Flag, and Supplemental Operations
— Part 125, Certification and Operations: Aeroplanes Having a Seating Capacity of 20
or More Passengers or a Maximum Payload Capacity of 6,000 pounds or More
— Part 129, Operations: Foreign Air Carriers and Foreign Operators of U.S.-Registered
Aircraft Engaged in Common Carriage
1
and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1).
2
Commission Regulation (EC) No 1702/2003 of 24 September 2003 laying down implementing rules for the airworthiness and
p. 3).
3
Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical products,
4
Executive Director Decision No 2003/2/RM of 14 October 2003 on certification specifications, including airworthiness codes and
5
Council Regulation (EEC) No 3922/91 of 16 December 1991 on the harmonisation of technical requirements and administrative
December 2007 (OJ L 10, 12.1.2008, p. 1).

AMC 20-22
— Part 135, Operating Requirements: Commuter and On-demand Operations

— Part 145, Repair Stations
c. FAA Advisory Circulars (AC)
— AC 20-13, Protection of Aircraft Electrical/Electronic Systems against the Indirect
Effects of Lightning
— AC 20-53A, Protection of Aeroplane Fuel Systems against Fuel Vapour Ignition due
to Lightning AC 25-16, Electrical Fault and Fire Protection and Prevention
— AC 25.981-1B, Fuel Tank Ignition Source Prevention Guidelines
— AC 25.17YY Development of Standard Wiring Practices Documentation
— AC 43-3, Non-destructive Testing in Aircraft
— AC 43-4A, Corrosion Control for Aircraft
— AC 43-7, Ultrasonic Testing for Aircraft
— AC 43-12A, Preventive Maintenance
— AC 43.13-1A, Acceptable Methods, Techniques and Practices - Aircraft Inspection
and Repair
— AC 43.13-1B, Acceptable Methods, Techniques and Practices for Repairs and
— AC 43-204, Visual Inspection for Aircraft
— AC 43-206, Avionics Cleaning and Corrosion Prevention/Control
— AC 65-15A, Airframe and Powerplant Mechanics Airframe Handbook, Chapter 11.
— AC 120-XX, Programme to enhance aircraft Electrical Wiring Interconnection
System maintenance
— AC 120-YY Aircraft Electrical Wiring Interconnection System training programme
d. Reports
Working Group, December 29, 2000.
— FAA Aging Transport Non-Structural Systems Plan, July 1998.
— National Transportation Safety Board, Safety Recommendation, September 19,
2000, A-00-105 through -108.
http://www.ntsb.gov/recs/letters/2000/A00_105_108.pdf
— Wire System Safety Interagency Working Group, National Science and Technology
Council, Review of Federal Programmes for Wire System Safety 46 (2000).
Systems, Final Report.
00.pdf

AMC 20-22
— Aging Transport Systems Rulemaking Advisory Committee, Task 3, Final Report.

Standard Wiring Practices.
0.pdf
Aircraft Wiring Systems Training Curriculum and Lesson Plans.
http://www.mitrecaasd.org/atsrac/final_reports/Task_5_Final_March_2001%20.
pdf
— ATA Specification 117 (Wiring Maintenance Practices/Guidelines).
— Aging Transport Systems Rulemaking Advisory Committee, Task 6, Task 7 and Task
9 Working Group Final Reports
http://www.mitrecaasd.org/atsrac/final_reports.html
e. Other Documents
ATA Operator/Manufacturer Scheduled Maintenance Development as revised, ATA
Maintenance Steering Group (MSG-3), may be obtained from the Air Transport
Association of America; Suite 1100: 1301 Pennsylvania Ave, NW, Washington, DC 20004-
1707.
FAA Handbook Bulletin 91-15 "Origin and propagation of inaccessible aircraft fire under
in-flight airflow conditions".
6 DEFINITIONS
Arc tracking: A phenomenon in which a conductive carbon path is formed across an insulating
surface. This carbon path provides a short circuit path through which current can flow.
Normally, a result of electrical arcing. Also referred to as "Carbon Arc Tracking", "Wet Arc
Tracking", or "Dry Arc Tracking".
Combustible: For the purposes of this AMC, the term combustible refers to the ability of any
solid, liquid or gaseous material to cause a fire to be sustained after removal of the ignition
source. The term is used in place of inflammable/flammable. It should not be interpreted as
identifying material that will burn when subjected to a continuous source of heat as occurs
when a fire develops.
Contamination: For the purposes of this AMC, wiring contamination refers to either of the
following:
— The presence of a foreign material that is likely to cause degradation of wiring.
— The presence of a foreign material that is capable of sustaining combustion after removal
of ignition source.
Detailed Inspection (DET): An intensive examination of a specific item, installation, or assembly
to detect damage, failure or irregularity. Available lighting is normally supplemented with a
direct source of good lighting at an intensity deemed appropriate. Inspection aids such as
mirrors, magnifying lenses or other means may be necessary. Surface cleaning and elaborate
access procedures may be required.
Functional Failure: Failure of an item to perform its intended function within specified limits.

AMC 20-22
General Visual Inspection (GVI): A visual examination of an interior or exterior area, installation,
or assembly to detect obvious damage, failure or irregularity. This level of inspection is made
from within touching distance unless otherwise specified. A mirror may be necessary to
enhance visual access to all exposed surfaces in the inspection area. This level of inspection is
made under normally available lighting conditions such as daylight, hangar lighting, flashlight or
droplight and may require removal or opening of access panels or doors. Stands, ladders or
platforms may be required to gain proximity to the area being checked.
Lightning/High Intensity Radiated Field (L/HIRF) protection: The protection of aeroplane
electrical systems and structure from induced voltages or currents by means of shielded wires,
raceways, bonding jumpers, connectors, composite fairings with conductive mesh, static
dischargers, and the inherent conductivity of the structure; may include aeroplane specific
devices, e.g., RF Gaskets.
Maintenance: As defined in Regulation (EC) 2042/2003 Article 2(h) “maintenance means
inspection, overhaul, repair, preservation, and the replacement of parts, but excludes
preventive maintenance.” For the purposes of this advisory material, it also includes preventive
maintenance.
Maintenance Significant Item (MSI): Items identified by the manufacturer whose failure:
— could affect safety (on ground or in flight).
— is undetectable during operations.
— could have significant operational impact.
— could have significant economic impact.
Needling: The puncturing of a wire’s insulation to make contact with the core to test the
continuity and presence of voltage in the wire segment.
Stand-alone General Visual Inspection (GVI): A GVI which is not performed as part of a zonal
inspection. Even in cases where the interval coincides with the zonal inspection, the stand-alone
GVI shall remain an independent step within the work card.
Structural Significant Item (SSI): Any detail, element or assembly that contributes significantly
to carrying flight, ground, pressure, or control loads and whose failure could affect the structural
integrity necessary for the safety of the aeroplane.
Swarf: A term used to describe the metal particles, generated from drilling and machining
operations. Such particles may accumulate on and between wires within a wire bundle.
Zonal Inspection: A collective term comprising selected GVI and visual checks that are applied
to each zone, defined by access and area, to check system and powerplant installations and
7 BACKGROUND
Over the years there have been a number of in-flight smoke and fire events where
contamination sustained and caused the fire to spread. Regulators and Accident Investigators
have conducted aircraft inspections and found wiring contaminated with items such as dust,
dirt, metal shavings, lavatory waste water, coffee, soft drinks, and napkins. In some cases, dust
has been found completely covering wire bundles and the surrounding area.
Research has also demonstrated that wiring can be harmed by collateral damage when
maintenance is being performed on other aircraft systems. For example, a person performing

AMC 20-22
an inspection of an electrical power centre or avionics compartment may inadvertently cause

damage to wiring in an adjacent area.
Aviation Accident Investigators have specifically cited the need for improved training of
personnel to ensure adequate recognition and repair of potentially unsafe wiring conditions.
This AMC addresses only the training programme. It does not attempt to deal with the condition
of the fleet's wiring, or develop performance tests for wiring.
This AMC captures, in EASA guidance form, the aeroplane EWIS training programme developed
by ATSRAC. This includes a training syllabus, curriculum, training target groups and a matrix
outlining training for each training group.
8 ESSENTIAL ELEMENTS FOR A TRAINING PROGRAMME
a. Initial Training.
Initial training should be conducted for each designated work group. The initial training
for each designated work group is outlined in EWIS Minimum Initial Training Programme
- Appendix A and B. Curriculum and Lesson Plans for each dedicated module are included
in Appendix C.
The most important criteria are to meet the objectives of the Lesson Plans – Appendix C
(using classroom discussion, computer-based training or hands-on practical training).
Assessment or achieving the objectives should be at the discretion of the training
organisation (such as written test, oral test or demonstration of skills).
Supporting documentation such as AMC is an integral part of training and should be used
to support development of the Curriculum and Lesson Plans.
b. Refresher Training.
Refresher training should be conducted in a period not exceeding two years. It could
consist of a review of previously covered material plus any new material or revisions to
publications. Refresher training will follow the EWIS Minimum Initial Training Programme
- Appendix A or B for that particular target group.
[Amdt 20/4]

AMC 20-22
Appendix A to AMC 20-22 – EWIS Minimum Initial Training

Programme for Group 1 and 2
Target Group 1: Qualified staff performing EWIS maintenance.

Target Group 2: Qualified staff performing maintenance inspections on EWIS.
TARGET GROUP 1 2
A – GENERAL ELECTRICAL WIRING INTERCONNECTION SYSTEM PRACTICES
Know or demonstrate safe handling of aeroplane electrical systems, line replaceable
units (LRU), tooling, troubleshooting procedures, and electrical measurement.
1. Safety practices X X
2. Electrostatic discharge sensitive (ESDS) device handling and protection X X
3. Tools, special tools, and equipment X
4. Verifying calibration/certification of instruments, tools, and equipment X
5. Required wiring checks using the troubleshooting procedures and charts X
6. Measurement and troubleshooting using meters X
7. LRU replacement general practices X X
B – WIRING PRACTICES DOCUMENTATION
Know or demonstrate the construction and navigation of the applicable aeroplane wiring
system overhaul or practices manual.
8. Standard wiring practices manual structure/overview X X
9. Chapter cross-reference index X X
10. Important data and tables X X
11. Wiring diagram manuals X X
12. Other documentation as applicable X X
C – INSPECTION
Know the different types of inspections, human factors in inspections, zonal areas and
typical damages.
13. General visual inspection (GVI), detailed inspection (DET), special detailed inspection X X
(SDI), and zonal inspection, and their criteria and standards
14. Human factors in inspection X
15. Zonal areas of inspection X
16. Wiring system damage X X
D – HOUSEKEEPING
Know the contamination sources, materials, cleaning and protection procedures.
17. Aeroplane external contamination sources X X
18. Aeroplane internal contamination sources X X
19. Other contamination sources X X
20. Contamination protection planning X
21. Protection during aeroplane maintenance and repair X
22. Cleaning processes X
E – WIRE
Know or demonstrate the correct identification of different wire types, their inspection
criteria and damage tolerance, repair and preventative maintenance procedures.
23. Wire identification, type and construction X X
24. Insulation qualities and damage limits X X

AMC 20-22
25. Inspection criteria and standards for wire and wire bundles X
26. Wire bundle installation practices X X
27. Typical damage and areas found (aeroplane specific) X X
28. Maintenance and repair procedures X X
29. Sleeving X X
30. Unused wires - termination and storage X X
31. Electrical bonding and grounds X X
F – CONNECTIVE DEVICES
Know or demonstrate the procedures to identify, inspect, and find the correct repair for
typical types of connective devices found on the applicable aeroplane.
32. General connector types and identification X X
33. Cautions and protections X X
34. Visual inspection procedures X X
35. Typical damage found X X
36. Repair procedures X X
G – CONNECTIVE DEVICE REPAIR
Demonstrate the procedures for replacement of all parts of typical types of connectors
found on the applicable aeroplane.
37. Circular connectors X
38. Rectangular connectors X
39. Terminal blocks - modular X
40. Terminal blocks - non-modular X
41. Grounding modules X
42. Pressure seals X
[Amdt 20/4]

AMC 20-22
Appendix B to AMC 20-22 – EWIS Minimum Initial Training

Programme for Group 3 through 8
Target Group 3: Qualified staff performing electrical/avionic engineering on in-service aeroplane.

Target Group 4: Qualified staff performing general maintenance/inspections not involving wire
maintenance (LRU change is not considered wire maintenance)
Target Group 5: Qualified staff performing other engineering or planning work on in-service
aeroplane
Target Group 6: Other service staff with duties in proximity to electrical wiring interconnection
systems
Target Group 7: Flight Deck Crew
Target Group 8: Cabin Crew
TARGET GROUPS 3 4 5 6 7 8
A – GENERAL ELECTRICAL WIRING INTERCONNECTION

SYSTEM PRACTICES
Know or demonstrate the safe handling of aeroplane
electrical systems, line replaceable units (LRU), tooling,
troubleshooting procedures, and electrical measurement.
1. Safety practices X X X X
2. Electrostatic discharge sensitive (ESDS) device X
handling and protection
7. LRU replacement general practices X
B – WIRING PRACTICES DOCUMENTATION

Know or demonstrate the construction and navigation of
the applicable aeroplane wiring system overhaul or
practices manual.
8. Standard wiring practices manual structure/overview X
9. Chapter cross-reference index X
10. Important data and tables X
11. Wiring diagram manuals X
12. Other documentation as applicable X
C – INSPECTION
Know the different types of inspections, human factors in
inspections, zonal areas and typical damages.
13. General visual inspection (GVI), detailed inspection X X
(DET), special detailed inspection (SDI), and zonal
inspection, and their criteria and standards
14. Human factors in inspection X
15. Zonal areas of inspection X
16. Wiring system damage X X Low Low Low
level level level
D – HOUSEKEEPING
Know the contamination sources, materials, cleaning and
protection procedures.

AMC 20-22
17. Aeroplane external contamination sources X X X X

18. Aeroplane internal contamination sources X X X X
19. Other contamination sources X X X X
20. Contamination protection planning X X X
21. Protection during aeroplane maintenance and repair X X X
22. Cleaning processes X X X X
E – WIRE
Know or demonstrate the correct identification of different
wire types, their inspection criteria and damage tolerance,
repair and preventative maintenance procedures.
23. Wire identification, type and construction X
24. Insulation qualities and damage limits X
25. Inspection criteria and standards of wire and wire X
bundles
26. Wire bundle installation practices X
27. Typical damage and areas found (aeroplane specific) X X X Low Low Low
level level level
28. Maintenance and repair procedures X
29. Sleeving X
30. Unused wires - termination and storage X
31. Electrical bonding and grounds X X X
Bond
F – CONNECTIVE DEVICES
Know or demonstrate the procedures to identify, inspect,
and find the correct repair for typical types of connective
devices found on the applicable aeroplane.
32. General connector types and identification X
33. Cautions and protections X
34. Visual inspection procedures X
35. Typical damage found X
36. Repair procedures X
[Amdt 20/4]

AMC 20-22
Appendix C to AMC 20-22 – Curriculum and Lessons Plan

Electrical Wiring Interconnection System Curriculum

1 OVERVIEW
This training is targeted at each person who performs aeroplane maintenance, inspections,
alterations or repairs on EWIS and/or structure. After training, the person is able to properly
evaluate the EWIS and effectively use the manufacturers Chapter 20 Wiring System overhaul
manual for that aeroplane. The training programme must include: wiring system condition,
applicable repair schemes, wiring modifications and ancillary repairs to wiring systems and
components. All of the training components are integrated to maintain wiring system quality
and airworthiness of the aeroplane.
2 OBJECTIVES
Depending on the modules taught, the person shows competency in the following skills:
a. Know or demonstrate the safe handling of aeroplane electrical systems, Line Replaceable
Units (LRU), tooling, troubleshooting procedures, and electrical measurement.
b. Know or demonstrate the construction and navigation of the applicable aeroplane wiring
system overhaul or wiring practices manual.
c. Know the different types of inspections, human factors in inspections, zonal areas and
typical damages.
d. Know the contamination sources, materials, cleaning and protection procedures.
e. Know or demonstrate the correct identification of different wire types, their inspection
criteria, and damage tolerance, repair and preventative maintenance procedures.
f. Know or demonstrate the procedures to identify, inspect and find the correct repair for
typical types of connective devices found on the applicable aeroplane.
g. Demonstrate the procedures for replacement of all parts of typical types of connective
devices found on the applicable aeroplane.
3 SCOPE
The course is to be used by training providers for all maintenance persons at any stage in their
careers. The person can be trained to the appropriate level using the applicable modules,
depending on the person’s experience, work assignment and operator’s policy.
MODULE A – GENERAL ELECTRICAL WIRING INTERCONNECTION SYSTEM PRACTICES:

(1) Safety practices
(2) ESDS device handling and protection
(3) Tools, special tools and equipment
(4) Verify calibration/certification of instruments, tools, and equipment
(5) Required wiring checks using the Troubleshooting Procedures and charts
(6) Measurement and troubleshooting using meters
(7) LRU replacement general practices

AMC 20-22
MODULE B – WIRING PRACTICES DOCUMENTATION:

(1) Chapter 20 structure/overview
(2) Chapter 20 cross-reference index
(3) Chapter 20 important data and tables
(4) Wiring Diagram Manual
(5) Other documentation (as applicable)
MODULE C – INSPECTION:
(1) Special inspections
(2) Criteria and standards
(3) Human factors in inspection
(4) Zonal areas of inspection
(5) Wiring system damage
MODULE D – HOUSEKEEPING:
(1) Aeroplane external contamination sources
(2) Aeroplane internal contamination sources
(3) Other contamination sources
(4) Contamination protection planning
(5) Protection during aeroplane maintenance and repair
(6) Cleaning processes
MODULE E – WIRE:
(1) Identification, type and construction
(2) Insulation qualities
(3) Inspection criteria and standards of wire and wire bundles
(4) Wire bundle installation practices
(5) Typical damage and areas found (aeroplane specific)
(6) Maintenance and repair procedures
(7) Sleeving
(8) Unused wires - termination and storage
(9) Electrical bonding and grounds
MODULE F – CONNECTIVE DEVICES:
(1) General types and identification
(2) Cautions and protections
(3) Visual inspection procedures
(4) Typical damage found
(5) Repair procedures

AMC 20-22
MODULE G – CONNECTIVE DEVICE REPAIR:

(1) Circular connectors
(2) Rectangular connectors
(3) Terminal blocks - modular
(4) Terminal blocks - non-modular
(5) Grounding modules
(6) Pressure seals
MODULE A: GENERAL ELECTRICAL WIRING INTERCONNECTION SYSTEM PRACTICE

1 OVERVIEW
Through Module A, the instructor lays the groundwork of safe, effective maintenance and repair
of the aeroplane EWIS and LRU removal and replacement, including BITE test, without damage
to the aeroplane or injury to the student.
The instructor may vary the depth and scope of the topics to be covered, depending on the type
of aeroplane to be maintained and skills of the persons.
2 OBJECTIVES
After this module is complete, the student is able to demonstrate the following skills:
a. Know the safety procedures of normal and non-normal maintenance procedures so that
the person can protect himself/herself and the aeroplane.
b. Recognise ESDS equipment and demonstrate standard anti-static procedures so that no
damage occurs to that equipment.
c. Demonstrate the correct use of hand tools including specialised and automated tools and
equipment.
d. Verify the calibration of electrical measuring instruments, tools and equipment so that
correct maintenance procedures may be carried out.
e. Demonstrate the process and procedures to successfully use the troubleshooting
procedures and charts of current aeroplane faults and know re-occurring problems
causing “No Fault Found” on removed LRU.
f. Demonstrate the correct use of electrical meters for measuring voltage, current,
resistance, continuity, insulation and short to ground.
g. Know the removal and replacement techniques so that no damage will occur to the LRU
or aeroplane connector.
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training. The following strategies
can be used to expedite learning and are recommended to the instructor:
ESDS handling and protection Multimedia/training aids
Calibration/certification of instruments, tools, and equipment Company policy
Wiring checks using the Troubleshooting Procedures and charts Aeroplane manuals
Measurement and troubleshooting using meters Meters and circuits
LRU removal and replacement Aeroplane manuals

AMC 20-22
MODULE A – GENERAL ELECTRICAL WIRING INTERCONNECTION SYSTEM PRACTICES:

1 Safety Practices
a. Current is lethal - First aid
b. Applying power to the aeroplane
c. Isolating the circuit
d. Aeroplane warnings
e. Human factors
2 ESDS Device Handling and Protection
a. Sources of electrostatic discharge
b. Soft and hard failures
c. ESDS safety procedures
d. ESDS handling/packing procedures
3 Tools, Special Tools and Equipment
a. General hand tools
b. Specialised tools
c. Automated tools and equipment
4 Verify Calibration/Certification of Instruments, Tools and Equipment
a. Tools requiring certification
b. Determining certification requirements
c. Typical problems
5 Required Wiring Checks Using the Troubleshooting Procedures and charts
a. Troubleshooting procedures manual (all chapters)
b. Aeroplane Maintenance Manual/Illustrated Parts Catalogue
c. Wiring schematics/troubleshooting graphics
d. Wiring diagrams
e. The process of troubleshooting
f. Testing of LRU connectors
g. Troubleshooting exercises
h. Company “No Fault Found” policy and data
6 Measurement and Troubleshooting Using Meters
a. Voltage, current and resistance
b. Continuity
c. Insulation
d. Short to ground

AMC 20-22
e. Loop impedance
7 LRU Replacement - General Practices
a. Different retention devices
b. Certification considerations (e.g. CAT 2/CAT3 Landing)
c. LRU re-racking procedures
d. “No Fault Found” data (aeroplane specific)
e. Built-in test equipment (BITE)
MODULE B: WIRING PRACTICES DOCUMENTATION

1 OVERVIEW
Through Module B, the instructor lays the groundwork for safe, effective maintenance and
repair of aeroplane EWIS. The intent of this module is to teach the person how to locate desired
information in the Chapter 20 Wiring System overhaul manual, Wiring Diagram Manual and
other applicable documentation. The instructor may vary the depth and scope of the topics to
be covered, depending on the type of aeroplane to be maintained and skills of the persons.
2 OBJECTIVES
After this module is complete, the person is able to demonstrate the following skills:
a. Know the applicable Sub-Chapters and Section to follow during normal and non-normal
electrical maintenance procedures.
b. Demonstrate the use of the Cross-Reference Index, Chapter Table of Contents, and
Subject Tables of Contents so as to find specific material within each Sub-Chapter and
Section.
c. Demonstrate the use of the associated tables for replacement of wire, connective devices
and contacts, and associated components, including approved replacements.
d. Demonstrate the use of the Wiring Diagram Manual.
e. Demonstrate the use of other documentation (as applicable).
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training. The Chapter 20 Wiring
Practices Manual, Wiring Diagram Manual, and other applicable documentation should be
made available to the class so that hands-on exploration of the material can be achieved.
MODULE B – WIRING PRACTICES DOCUMENTATION:

1 Chapter 20 Structure/Overview
a. Table of contents
b. Sub-chapter titles
c. Section structure
d. General procedures
2 Chapter 20 Cross-Reference Index

AMC 20-22
a. Cross-reference index – Alphanumeric

b. Cross-reference index – Standard Part number
c. Cross-reference index – Suppliers
e. Equivalence tables – Std Part Numbers EN-ASN-NSA
3 Chapter 20 Important Data and Tables
a. Contact crimp tools, insertion/extraction tools
b. Wire Insulation removal tools
c. Electrical cable binding
d. Wire type codes and part numbers identification
e. Connective devices types and contacts
f. Terminal blocks and terminations
g. Terminal blocks modules, grounding modules and contacts
h. Cleaning procedures
i. Repair procedures
4 Wiring Diagram Manual (WDM)
a. Front matter
b. Diagrams
c. Charts
d. Lists
5 Other documentation (as applicable)
MODULE C: INSPECTION
1 OVERVIEW
Through Module C, the instructor lays the groundwork for safe, effective maintenance and
repair of aeroplane wiring systems, by teaching the skills of inspection so as to identify wiring
system damage. The instructor may vary the depth and scope of the topics to be covered,
depending on the type of aeroplane to be maintained and skills of the persons.
2 OBJECTIVES
a. Know the different types of inspections: General Visual Inspection (GVI), Detailed
Inspection (DET), Zonal Inspection and Enhanced Zonal Analysis Procedure (EZAP).
b. Know the criteria and standards of inspection so that the person knows which tools are
used to ensure inspection procedures and standards are achieved, which leads to all
defects being found.
c. Know the effects of fatigue and complacency during inspection and how to combat these
effects (Human Factors).

AMC 20-22
d. Know the specific zonal inspection requirements related to system affiliation and
environmental conditions.
e. Recognise typical wiring system damage, such as hot gas, fluid contamination, external
mechanically induced damage, chafing, corrosion, signs of overheating of wire, wire
bundles, connective and control device assemblies.
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training. ATA 117 video and colour
photos of actual wiring system damage could be used to show typical problems found on the
aeroplane. Examples of discrepancies should be made available to the student. AMC 20-21,
Programme to Enhance Aeroplane EWIS Maintenance is recommended as a source of typical
aeroplane wiring installations and areas of concern.
MODULE C – INSPECTION
1. Special Inspections
a. General Visual Inspection (GVI)
b. Detailed Inspection (DET)
c. Zonal Inspection
d. Enhanced Zonal Analysis Procedure (EZAP)
2. Criteria and Standards
a. Tools
b. Criteria/standards
c. Procedures of inspection
3. Human Factors in Inspection
a. Fatigue
b. Complacency
4. Zonal Areas of Inspection
a. Zonal areas of inspection
b. Zonal inspection procedures and standards
5. Wiring System Damage
a. Swarf/FOD/metal shavings
b. External mechanically induced damage
c. Hot gas
d. Fluid contamination
e. Vibration/chafing
f. Corrosion
g. Signs of overheating

AMC 20-22
MODULE D: HOUSEKEEPING
1 OVERVIEW
Through Module D, the instructor lays the groundwork for safe, effective maintenance and
repair of aeroplane EWIS, by teaching housekeeping strategies, so as to keep the EWIS free of
contamination. The Instructor may vary the depth and scope of the topics to be covered,
depending on the type of aeroplane to be maintained and skills of the persons.
2 OBJECTIVES
a. Recognise external contamination and other damage due to external environmental
conditions.
b. Know the aeroplane internal contamination sources so that inspection processes can be
effectively carried out and contamination damage easily recognised.
c. Recognise other possible contamination sources.
d. Know the planning procedures to be followed, on EWIS areas in different parts of the
aeroplane.
e. Know the protection procedures and processes to protect the EWIS during maintenance
and repair.
f. Know the process of cleaning wiring systems during maintenance and repair.
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training. ATA 117 video and colour
photos of actual EWIS contamination could be used to show typical problems found on the
aeroplane. Relevant Aeroplane Maintenance Manual and/or Chapter 20 Wiring Practices
procedures should be used. The ATSRAC Task Group 1, Non-Intrusive Inspection Final Report
could be used to identify typical housekeeping issues. AMC 20-21, Programme to Enhance
Aeroplane EWIS Maintenance is recommended as a source of typical aeroplane wiring
installations and areas of concern.
MODULE D – HOUSEKEEPING
1 Aeroplane External Contamination Sources
a. De-ice fluids
b. Water and rain
c. Snow and ice
d. Miscellaneous (e.g. cargo/beverage spillage)
e. Air erosion
2 Aeroplane Internal Contamination Sources
a. Hydraulic oils
b. Engine and APU oils
c. Fuel
d. Greases

AMC 20-22
e. Galleys and toilets

f. Lint/Dust
g. Bleed air and hot areas
h. Hazardous materials
3 Other Contamination Sources
a. Paint
b. Corrosion inhibitor
c. Drill shavings/Swarf
d. Foreign objects (screws, washers, rivets, tools, etc.)
e. Animal waste
4 Contamination Protection Planning
a. Have a plan/types of plan/area mapping
b. Protection and Caution Recommendations
c. Procedures
d. Keep cleaning
5 Protection during Aeroplane Maintenance and Repair
a. Recommended general maintenance protection procedures
b. Recommended airframe repair protection procedures
c. Recommended powerplant repair protection procedures
6 Cleaning Processes
a. Fluid contamination
(1) Snow and ice
(2) De-ice fluid
(3) Cargo spillage
(4) Water and rain
(5) Galleys
(6) Toilets water waste
(7) Oils and greases
(8) Pressure washing
b. Solid contamination
(1) Drill shavings/Swarf
(2) Foreign objects (screws, washers, rivets, tools, etc.)
c. Environmental contamination
(1) Lint and dust
(2) Paint

AMC 20-22
(3) Corrosion inhibitor

(4) Animal waste
MODULE E: WIRE
1 OVERVIEW
Through Module E, the instructor lays the groundwork for safe, effective maintenance,
alteration and repair of aeroplane EWIS by teaching wire selection and inspection strategies.
The Instructor may vary the depth and scope of the topics to be covered, depending on the type
2 OBJECTIVES
a. Demonstrate the procedure used to identify specific wire types using the aeroplane
manuals.
b. Know from approved data different insulation types and their relative qualities.
c. Know the inspection criteria for wire and wire bundles.
d. Know the standard installation practices for wire and wire bundles (aeroplane specific).
e. Know typical damage that can be found (aeroplane specific).
f. Demonstrate the repair procedures for typical damage found on the student’s type of
aeroplane.
g. Demonstrate the procedures to fitting differing types of sleeving (aeroplane specific).
h. Know the procedures for termination and storage of unused wires.
i. Know the correct installation practices for electrical bonds and grounds (aeroplane
specific).
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training with hands-on practice
for Section 6. Chapter 20 Wiring Practices, Wiring Diagram Manual and WDM Lists should be
made available to the class to ensure hands-on use of the manual so that wire identification,
inspection, installation and repair procedures can be fully explored. Examples of wire
discrepancies should be made available to the student. The ATSRAC Task Group 1, Intrusive
Inspection Final Report could be used to identify typical wire issues. AMC 20-21, Programme to
Enhance Aeroplane EWIS Maintenance is recommended as a source of typical aeroplane wiring
installations and areas of concern.
MODULE E – WIRE
1 Identification, Type and Construction
a. Wire type codes – alphanumeric
b. Wire type codes – specification and standard part number
c. Wire type codes – specified wire and alternate
d. Manufacturer identification

AMC 20-22
2 Insulation Qualities
a. Types of insulation
b. Typical insulation damage and limitations
c. Carbon arcing
3 Inspection Criteria and Standards of Wire and Wire Bundles
a. Inspection of individual wiring
b. Inspection of wire bundles
4 Wire Bundle Installation Practices
a. Routing
b. Segregation rules
c. Clearance
d. Clamp inspection
e. Clamp removal and fitting
f. Conduit types and fitting
g. Raceways
h. Heat shields and drip shields
5 Typical Damage and Areas Found (aeroplane specific)
a. Vibration
b. Heat
c. Corrosion
d. Contamination
e. Personnel traffic passage
6 Maintenance and Repair Procedures
a. Wire damage assessment and classification
b. Approved repairs - improper repairs
c. Shielded wire repair
d. Repair techniques
e. Terminals and splices
f. Preventative maintenance procedures
7 Sleeving
a. Identification sleeves
b. Shrink sleeves
c. Screen braid grounding crimp sleeves
d. Screen braid grounding solder sleeves
8 Unused Wires - Termination and Storage

AMC 20-22
a. Termination – end caps

b. Storage and attachment
9 Electrical Bonding and Grounds
a. Inspection standards
b. Primary Bonding (HIRF protection)
c. Secondary Bonding (System grounding)
d. Lightning strikes
MODULE F: CONNECTIVE DEVICES

1 OVERVIEW
Through Module F, the instructor lays the groundwork for safe, effective maintenance,
alteration and repair of aeroplane EWIS by teaching the identification, inspection and repair of
connective devices found on the aeroplane. The instructor may vary the depth and scope of the
topics to be covered, depending on the type of aeroplane to be maintained and skills of the
persons.
2 OBJECTIVES
a. Know the general types and positive identification of connective devices (aeroplane
specific).
b. Know the various safety procedures, cautions and warnings prior to inspection.
c. Know the relevant visual inspection procedures for each type of connector so that any
internal or external damage can be found.
d. Recognise typical external and internal damage to the connector.
e. Demonstrate where to find the relevant repair schemes from Chapter 20 for connector
repair.
3 STRATEGIES
Normal classroom lecture can be used for the majority of the training. The Chapter 20 Wiring
Practices manual should be made available to the class so that hands-on use of the manual can
be ensured. Connector identification, inspection and repair procedures should be fully explored.
Colour photographs of typical external damage and internal damage could be used to show
problems on the aeroplane. The ATSRAC Task Group 1, Non-Intrusive Inspection and Intrusive
Inspection Final Report, Chapter 7, could be used to identify typical connector issues. AMC 20-
21, Programme to Enhance Aeroplane EWIS Maintenance is recommended as a source of typical
aeroplane wiring installations and areas of concern.
MODULE F – CONNECTIVE DEVICES

1 General Types and Identification
a. Part number identification
b. Reference tables

AMC 20-22
c. Specific connective devices chapters

2 Cautions and Protections
a. Safety precautions
b. Maintenance precautions
3 Visual Inspection Procedures
a. Installed inspection criteria
b. Removed inspection criteria
4 Typical Damage Found
a. Exterior damage
b. Internal damage
5 Repair Procedures
a. Finding the correct section
b. Finding the correct part
c. Finding the correct tooling
d. Confirming the correct repair
MODULE G: CONNECTIVE DEVICES REPAIR

1 OVERVIEW
Through Module G, the instructor lays the groundwork for safe, effective maintenance,
alteration and repair of aeroplane EWIS. This module is primarily a hands-on class, emphasising
the repair and replacement of connective devices found on the aeroplane. This list can be used
to cover typical connectors for aeroplanes and can be adjusted to suit training requirements.
The instructor may vary the depth and scope of the topics to be covered, depending on the type
2 OBJECTIVE
After this module is complete, the person will have the following skills:
a. Demonstrate the replacement of components for circular connectors.
b. Demonstrate the replacement of components for rectangular connectors.
c. Demonstrate the replacement of components for terminal blocks - modular.
d. Demonstrate the replacement of components for terminal blocks - non-modular.
e. Demonstrate the replacement of components for grounding modules.
f. Demonstrate the replacement of pressure seals.
3 STRATEGIES
This class is primarily a hands-on class to give the student motor skills in the repair of connective
devices from their aeroplane. The Chapter 20 Wiring Practices Manual and the appropriate
connective devices should be made available to the class so that repair procedures can be fully
explored. Photographs of typical internal conditions and external damage could be made
available. It is recommended that MODULE F: CONNECTORS should precede this module.

AMC 20-22
AMC 20-21, Programme to Enhance Aeroplane EWIS Maintenance is recommended as a source

of typical aeroplane wiring installations and areas of concern.
MODULE G – CONNECTIVE DEVICES REPAIR

1 Circular Connectors
a. Disassembly
b. Back-shell maintenance
c. Contact extraction and insertion
d. Contact crimping
e. Assembly and strain relief
2 Rectangular Connectors
a. Disassembly
b. Back-shell maintenance
c. Contact extraction and insertion
d. Contact Crimping
e. Assembly and strain relief
3 Terminal Blocks - Modular
a. Disassembly
b. Contact extraction and insertion
c. Contact Crimping
d. Assembly and strain relief
4 Terminal Block – Non-modular
a. Disassembly
b. Terminal Lug Crimping
c. Terminal Lug Stacking
d. Assembly, torque and strain relief
5 Grounding Modules
a. Disassembly
b. Contact extraction and insertion
c. Contact Crimping
d. Assembly and strain relief
6 Pressure Seals
a. Disassembly
b. Maintenance
c. Assembly and strain relief
[Amdt 20/4]

AMC 20-23
AMC 20-23
AMC 20-23 Development of Electrical Standard Wiring Practices

documentation
1 PURPOSE
This AMC provides acceptable means of compliance for developing an electrical standard wiring
practices document for operators, holders of and applicants for type certificates (TC), applicants
for supplemental type certificates (STC) and maintenance organisations. The information in this
AMC is based on recommendations submitted to the FAA from the Aging Transport Systems
Rulemaking Advisory Committee (ATSRAC). JAA and latterly EASA are participating members of
ATSRAC. The information in this AMC is derived from the maintenance, inspection, and
alteration best practices identified through extensive research by ATSRAC working groups and
Federal government working groups. This AMC provides a means, but not the only means of
creating a document that meets the expectations of CS 25.1529 and Appendix H.
2 OBJECTIVE
The objective of this AMC is to promote a common format for documents containing standard
practices for electrical wiring, and to provide a summary of the minimum content expected to
be contained within that document. Although the title of the document or manual is left to the
discretion of the organisation, such a document will be referred to in this AMC as the Electrical
Standard Wiring Practices Manual (ESWPM).
Titles in other organisations for such document may be Standard Wiring Practices Manual
(SWPM) or Electrical Standard Practices Manual (ESPM).
3 APPLICABILITY
The guidance provided in this AMC is applicable to all operators, holders of and applicants for
TC, applicants for STC and maintenance organisations.
4 RELATED DOCUMENTS
— Regulation (EC) No. 216/20081
— Regulation No. 1702/20032
— Regulation No. 2042/20033
1
and Directive 2004/36/EC (OJ L 79, 19.3.2008, p.1).
2 Commission Regulation (EC) No 1702/2003 of 24 September 2003 laying down implementing rules for the airworthiness and
p.3).
3 Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical products,

AMC 20-23

a. EASA AMC-20
— AMC 20-21, Programme to Enhance Aircraft Electrical Wiring Interconnection
System Maintenance
— AMC 20-22, Aircraft Electrical Wiring Interconnection System Training Programme
b. FAA 14 CFR Parts
— Part 21, Certification Procedures for Products and Parts
— Part 25, Airworthiness Standards, Transport Category Airplanes
— Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration
— Part 91, General Operating and Flight Rules
— Part 119, Certification: Air Carriers and Commercial Operators
— Part 121, Operating Requirements: Domestic, Flag, and Supplemental Operations
— Part 125, Certification and Operations: Airplanes Having a Seating Capacity of 20
or More Passengers or a Maximum Payload Capacity of 6,000 pounds or More
— Part 129, Operations: Foreign Air Carriers and Foreign Operators of U.S.-Registered
Aircraft Engaged in Common Carriage
— Part 135, Operating Requirements: Commuter and On-demand Operations and
Rules Governing Persons on Board such Aircraft
— Part 145, Repair Stations
c. FAA Advisory Circulars (AC)
— AC 25-16, Electrical Fault and Fire Protection and Prevention
— AC 25.981-1B, Fuel Tank Ignition Source Prevention Guidelines
— AC 43-12A, Preventive Maintenance
— AC 43.13-1B, Acceptable Methods, Techniques and Practices for Repairs and
— AC 43-204, Visual Inspection for Aircraft
— AC 43-206, Avionics Cleaning and Corrosion Prevention/Control
— AC 65-15A, Airframe and Powerplant Mechanics Airframe Handbook, Chapter 11.
— AC 25.17XX Certification of EWIS on Transport Category Airplanes
1 Executive Director Decision No 2003/2/RM of 14 October 2003 on certification specifications, including airworthiness codes and
2 Council Regulation (EEC) No 3922/91 of 16 December 1991 on the harmonisation of technical requirements and administrative
December 2007 (OJ L 10, 12.1.2008, p. 1).

AMC 20-23
d. Reports
Systems, Final Report
00.pdf
— Aging Transport Systems Rulemaking Advisory Committee, Task 3, Final Report
Standard Wiring Practices
0.pdf
Working Group, December 29, 2000
— Aging Transport Systems Rulemaking Advisory Committee Task 7, Final Report,
Electrical Standard Wire Practices Manual (ESWPM)
http://www.mitrecaasd.org/atsrac/final_reports/Task_7_Final_Report-10-31-
2002.pdf
e. Other Documents
— ATA Specification 117 (Wiring Maintenance Practices/Guidelines)
— FAA Policy Statement Number ANM-01-04: System Wiring Policy for Certification
of Part 25 Airplanes, June 25, 2001
6 DEFINITIONS
Consumable materials: Materials consumed during the maintenance or repair of EWIS which
are not an eventual component of the EWIS.
Drip loop: The practice of looping a wire or wire bundle to provide a point lower than the
adjacent connector for moisture to collect.
Legacy document: An organisation’s ESWPM existing prior to the adoption of the requirements
of H25.5(a)(2) of Appendix H to CS-25.
Master Breakdown Index (MBI): An index developed to supplement a legacy document. An MBI
provides a means of finding information without the need for reformatting the legacy SWPM.
An example of an MBI is presented at the end of paragraph 9 of this AMC.
Separation: Defined as either spatial distance, or physical barrier, between wiring from adjacent
structure, systems or wiring; or the practice of installing wiring supporting redundant or multi-
channel systems.
Standard practices: Industry-wide methods for repair and maintenance of electrical wire, cable
bundles and coaxial cables. Procedures and practices for the inspection, installation and
removal of electrical systems components including, but not limited to: wire splices, bundle
attachment methods, connectors and electrical terminal connections, bonding/grounding, etc.

AMC 20-23
7 STANDARDISED ESWPM FORMAT

A representative example of the standard format and sequence of major topics included within
an ESWPM is contained within Appendix A of this AMC.
8 MINIMUM ESWPM CONTENT
A definition and description of ESWPM minimum content is necessary to ensure that operators
and repair stations have at their disposal the information necessary to properly maintain their
airplanes. Although the original airframe manufacturer’s electrical installation design
philosophy concerning components, installation procedures, segregation rules, etc. need not be
included within the ESWPM, sufficient minimum information should be provided to enable the
end-user to maintain the aircraft in a condition that conforms to the electrical installation design
philosophy of the original manufacturer.
The content of any ESWPM should include, at a minimum, the following:
a. Front Matter
Provide information regarding the content and use of the ESWPM. Describe changes to
the document in a record of revisions. Ensure the document contains a table of contents
or index to allow the user to readily retrieve necessary information.
b. Safety Practices
Provide general instruction, cautions and warnings which describe safe practices
implemented prior to the start of any or all of the specific standard electrical practices
contained within the core of the ESWPM. Safety cautions, warnings or notes specific to
the procedure shall be placed within the body of the procedure.
c. Cleaning Requirements and Methods
“Protect, clean as you go” philosophy.
Non-destructive methods for cleaning dust, dirt, foreign object debris (FOD), lavatory
fluid, and other contaminants produced by an aircraft environment from wiring systems.
Wire replacement guidelines when an accumulation of contaminants, either on the
surface and/or imbedded in the wire bundle, cannot be safely removed.
d. Wire and Cable Identification
(1) Specify requirements for wire and cable identification and marking to provide
safety of operation, safety to maintenance personnel, and ease of maintenance.
(2) Specify methods of direct wire marking. Also, identify specific requirements and
cautions associated with certain types of wire marking.
e. Wire and Cable Damage Limits
Specify limits to positively identify the thresholds where damaged wire/cable
replacement may be necessary and where repairs can be safely accomplished. Establish
limits for each applicable wire/cable type, if necessary.
(1) Include damage limits for terminals, studs, connectors, and other wiring system
components, as necessary.
f. Installation Clamping and Routing Requirements
(1) Specify the requirements for the installation of wiring systems with respect to
physical attachment to the aircraft structure. These requirements must be

AMC 20-23
compatible with the different environments applicable to aircraft and aircraft

systems.
(2) Specify applicable methods of clamping, support, termination, and routing to
facilitate installation, repair, and maintenance of wires, wire bundles, and cabling.
(3) Specify minimum bend radii for different types of wire and cable.
(4) Specify minimum clearance between wiring and other aircraft systems and aircraft
structure.
(5) Include the requirements for the installation of wiring conduit with respect to
physical attachment, routing, bend radii, drain holes, and conduit end coverings.
(6) Emphasise special wiring protective features, such as spatial separation,
segregation, heat shielding, and moisture protection that are required to be
maintained throughout the life of the aircraft.
(7) Ensure necessary information for the maintenance of bonding, grounding and
lightning, high-intensity radio frequency (L/HIRF) provisions is included.
(8) Include information on the use and maintenance of wire protective devices,
conduits, shields, sleeving etc. (this bullet is deleted in the FAA AC).
g. Repair and Replacement Procedures
Describe methods to safely repair and/or replace wiring and wiring system components.
(1) Include types and maximum numbers of splice repairs for wiring and any
limitations on the use of splices. When splicing wire, environmental splices are
highly recommended over non-environmental splices. Guidance should be
provided on how long a temporary splice may be left in the wire.
(2) Specify procedures for the repair, replacement, and maintenance of connectors,
terminals, modular terminal blocks, and other wiring components.
h. Inspection Methods
In wiring inspection methods, include a general visual inspection (GVI), or a detailed
inspection (DET), as determined by the Enhanced Zonal Analysis Procedure (EZAP).
Typical damage includes heat damage, chafing, cracked insulation, arcing, insulation
delaminating, corrosion, broken wire or terminal, loose terminals, incorrect bend radii,
contamination, and deteriorated repairs.
(1) Identify detailed inspections and, where applicable, established and emerging new
technologies non-destructive test methods to complement the visual inspection
process.
Whenever possible, ensure that inspection methods can detect wiring problems
without compromising the integrity of the installation.
i. Customised data
Provide a location and procedures that allow users to include customised or unique data
such as that relating to STC, operator-unique maintenance procedures, etc.
A comprehensive listing of the typical content included within an ESWPM, including the
minimum required content described above, is contained within Appendix A of this AMC.

AMC 20-23
9 ALTERNATIVE PROCEDURE FOR LEGACY DOCUMENTS

The definition of a new layout and chapter format may require each organisation with an
existing ESWPM to reformat and to republish using the standardised format. Whether the
organisation produces a stand-alone manual or provides the electrical standard practices as
Chapter 20 of a wiring diagram manual, the resultant reorganisation would cause a significant
economical impact for both the authoring organisation and their end-users.
To address this concern, a conversion tool, identified in the last paragraph of this chapter, was
devised which takes the following variables into account:
— Effects on manufacturers’ current technical document editorial policy as it exists in
current legacy documents.
— Costs resulting from an immediate major manual overhaul.
— Inconvenience to end-users who are accustomed to the format they are currently using.
When using a traditional paper format ESWPM, the most efficient method of retrieving
standard procedures and maintenance information has traditionally been to search in:
— the table of contents (TOC) and/or
— the indexes (i.e., alphanumerical index and/or numerical index, as available).
The ease and speed with which information may be found with these methods relies heavily on
the quality of the TOC and/or the indexes. For aircraft maintenance technicians needing to
locate and extract the pertinent and applicable data necessary to perform a satisfactory design
modification or maintenance action, finding relevant data may be time-consuming.
When using an electronic format, a search engine can often be used. This allows the user to
bypass the TOC or indexes in finding the needed procedure or data. By searching with such
alternative methods, a user can find information without needing to know the rules, such as
ATA references, governing assignment of the subject matter to its place in the TOC.
The use of a conversion tool, identified as a Master Breakdown Index (MBI) is one method of
achieving a common format until existing legacy documents can be physically altered or
digitised to an electronic format. The intent of the MBI is to supplement the TOC and existing
indexes by providing to users a method of searching existing documents using topical
information rather than by part number, alphabetic subject, or Chapter-Section-Subject
reference. The arrangement of the MBI duplicates the standardised format described in
Paragraph 7 of this AMC, but does not require complete rearrangement of legacy documents
to achieve a common format. The MBI acts as a conversion key used to effectively convert an
existing document arrangement into the proposed arrangement. In essence the MBI duplicates
in paper form for legacy documents the electronic search engine for HTML-based documents.
This is an example of an MBI which could be used to mitigate the need for legacy documents to
be reformatted to achieve the standardised format described above:
APPEARS IN THIS
GROUP MAJOR TOPIC
DOCUMENT AS SUBJECT
GENERAL DATA SAFETY PRACTICES 20-10-10
AIRPLANE ENVIRONMENTAL AREAS 20-20-12
CONSUMABLE MATERIALS 20-00-11
WIRING MATERIALS 20-10-13
COMMON TOOLS 20-00-13
EWIS PROTECTION DURING MAINTENANCE 20-10-20

AMC 20-23
ELECTRICAL WIRING EWIS CLEANING 20-10-20

INTERCONNECT EWIS INSPECTION 20-10-20
SYSTEM (EWIS) EWIS TESTING 20-10-13
MAINTENANCE
EWIS DISASSEMBLY 20-10-19
EWIS REPAIR AND REPLACEMENT 20-20-00
WIRING INSTALLATION WIRE SEPARATION / SEGREGATION 20-10-11
20-10-12
ELECTRICAL BONDS AND GROUNDS 20-30-60
WIRE HARNESS INSTALLATION 20-10-17
20-10-18 Installation of
Sleeves on Wiring
WIRING ASSEMBLY WIRE AND CABLE TYPES 20-00-15
WIRE MARKING 20-60-01
WIRE HARNESS ASSEMBLY 20-50-01
WIRE INSULATION AND CABLE JACKET 20-90-12
REMOVAL
TERMINATION TYPE (SPECIFICS OF 20-61-44
TERMINATIONS)
ELECTRICAL DEVICES DEVICE TYPE (SPECIFICS OF ELECTRICAL 20-80-09 Assembly of
DEVICE) Leach Relay Sockets
SPECIFIC SYSTEM UNIQUE WIRING 20-73-00 Fuel Quantity
WIRING ASSEMBLIES/INSTALLATIONS Indicating System
AIRLINE CUSTOMISED AIRLINE SPECIFIED 20-91-00
DATA
[Amdt 20/4]

AMC 20-23
Appendix A: Groups, Major Topics, Standardised Sequence and

Description of Minimum Content
GROUP MAJOR TOPIC DESCRIPTION

Safety regulations and general safety precautions to
SAFETY PRACTICES
prevent injury to personnel and damage to the airplane
Definition of types of areas upon which wiring
AIRPLANE ENVIRONMENTAL
configuration and wiring component selection is
AREAS
constrained
GENERAL DATA Wiring maintenance processing materials (solvents,
CONSUMABLE MATERIALS
aqueous cleaners, lubricants, etc.)
Materials that become an integral part of the wiring
WIRING MATERIALS configuration excluding wire and cable, e.g., sleeves,
shield material, tie material, sealants, etc.
COMMON TOOLS Description and operation of common tools
EWIS PROTECTION DURING Procedures to protect EWIS during airplane
MAINTENANCE maintenance and modification
In support of inspection as well as prevention of
degradation and preparation for repair; recommended
EWIS CLEANING
cleaning materials and procedures based on type of
contamination
Criteria for correct installation, correct wiring assembly
configuration; damage conditions and limits for wiring
EWIS EWIS INSPECTION components (wire and cable, termination types,
MAINTENANCE electrical devices); factors that warrant disassembly for
inspection; determination of cause of damage
EWIS TESTING Wiring integrity testing
Data and procedures in support of inspection, cleaning
EWIS DISASSEMBLY
when applicable; also supports new wiring installation
Repair of wiring installation, wiring assembly
EWIS REPAIR AND configuration, wiring components (wire and cable,
REPLACEMENT wiring terminations, electrical devices); wire and cable
replacement; wiring functional identification
Explanation of separation/segregation categories,
WIRE SEPARATION/
separation/segregation identification, and necessary
SEGREGATION
conditions for maintaining separation/segregation
WIRING ELECTRICAL BONDS AND Bond surface preparation, ground hardware
INSTALLATION GROUNDS configurations, bond integrity testing
Routing, supports; wiring protection, factors affecting
WIRE HARNESS
wiring assembly configuration; connection to
INSTALLATION
equipment, new wiring, removal from service
The principal material component of airplane wiring;
WIRE AND CABLE TYPES includes type identification and basic description;
alternative wire types (replacements, substitutions)
WIRING
WIRE MARKING Marking; applicable conditions
ASSEMBLY
Wiring assembly configuration: Assembly materials,
WIRE HARNESS ASSEMBLY layout, overall protection; factors affecting wiring
installation

AMC 20-23
GROUP MAJOR TOPIC DESCRIPTION

Wire and cable: Insulation removal, jacket removal;
WIRE INSULATION AND
associated damage limits, tool description and
CABLE JACKET REMOVAL
operation
Wiring terminations and accessories (connectors,
terminal lugs, splices, backshells, etc.) grouped by
termination type from simple to complex:
a. Common data or procedures by group (if any), e.g.,
<<TERMINATION TYPE>> tool description and operation, definition of
e.g., SOURIAU 8950 SERIES internal damage and limits, internal cleaning,
CONNECTORS accessories
b. By individual type - part numbers and description,
definition of internal damage and limits (if not
specified by common data), disassembly,
assembly, installation
Electrical devices (circuit breakers, relays, switches,
filters, lamps, etc.) grouped by device type:
a. Common data or procedures by group (if any), e.g.,
tool description and operation, definition of
<<DEVICE TYPE>>
ELECTRICAL internal damage and limits, internal cleaning,
e.g., KLIXON 7274 SERIES
DEVICES accessories
CIRCUIT BREAKER
b. By individual type - part numbers and description,
definition of internal damage and limits (if not
specified by common data), disassembly,
assembly, installation
For wiring that has a necessarily specific configuration
(e.g. Primary Flight Control, Fuel Quantity Indicator
SPECIFIC SYSTEM System, etc.):
SPECIFIC WIRING ASSEMBLY
WIRING – Applicable conditions for repair and replacement
– Disassembly, assembly, installation, assembly integrity
testing
AIRLINE
CUSTOMISED AIRLINE SPECIFIED Reserved for airline use
DATA
[Amdt 20/4]

AMC 20-24
AMC 20-24
AMC 20-24 Certification Considerations for the Enhanced ATS in

Non-Radar Areas using ADS-B Surveillance (ADS-B-NRA) Application
via 1090 MHZ Extended Squitter.
1 PREAMBLE
1.1 The scope of this Acceptable Means of Compliance (AMC) is the airworthiness and
operational approval of the “Enhanced Air Traffic Services in Non-Radar Areas using ADS-
B Surveillance” (ADS-B-NRA) application.
1.2 Operational benefits of the ADS-B-NRA application include the enhancement of the Air
Traffic Control Service in current non-radar airspace. ADS-B-NRA would provide
controllers with improved situational awareness of aircraft positions, and in consequence
appropriate separation minima could be applied depending on the environment and the
approval of the competent authority. Current non-radar airspace is controlled using
procedural methods which demand large separations. ADS-B-NRA separation minima
would be smaller than that used in current non-radar airspace. Alerting Services in
nonradar airspace will be enhanced by more accurate information on the latest position
of aircraft.
Hence, it is expected that in areas where radar coverage is not feasible or not
economically justified this application will provide benefits to capacity, efficiency and
safety in a way similar to what would be achieved by use of SSR radar.
1.3 The European CASCADE programme is the mechanism for co-ordination of the European
implementation of ADS-B (ADS-B-NRA and other ADS-B based ground and airborne
surveillance applications). One of the programme’s aims is to ensure harmonisation and
efficiency of implementation.
1.4 CASCADE uses the globally interoperable 1090 MHz Extended Squitter (ES) data link
technology, compliant with ICAO SARPS in Annex 10 and in line with the
recommendations of the Conference ICAO ANC-11.
1.5 In parallel, the FAA Airservices Australia and Nav Canada plan to deploy ADS-B using the
same data link technology. It is assumed that aircraft will be interoperable with all
implementation programmes using the EUROCAE/RTCA ADS-B-NRA standard (ED126,
DO-303).
1.6 The meaning of abbreviations may be found in Appendix 1.
2 PURPOSE
2.1 This AMC is for operators seeking to operate in airspace classifications A to E where ADS-
B-NRA services have been implemented by the Air Navigation Service Provider. It
provides the basis for approval of aircraft systems and identifies operational
considerations.
It may also assist other stakeholders by alerting them to aircraft requirements, operator
procedures and related assumptions. These other stakeholders could include airspace
planners, air traffic service providers, ATS system manufacturers, surveillance data

AMC 20-24
processing system manufacturers, communication service providers, aircraft and avionics

equipment manufacturers and ATS regulatory authorities.
2.2 Acceptable Means of Compliance (AMC) illustrate a means, but not the only means, by
which a requirement contained in an EASA airworthiness code or an implementing rule
of the Basic Regulation, can be met.
An applicant correctly implementing this AMC in its entirety is assured of acceptance of
compliance with the airworthiness considerations prior to use of the automatic
dependent surveillance broadcast equipment. The operational considerations in this
AMC are consistent with the operational considerations in the position paper 039 revision
8, that is endorsed by the JAA Operations Sectorial Team (OST). An Operator that, in
conjunction with the airworthiness considerations, has correctly implemented this AMC
should be ensured of acceptance of compliance with the operations rules applicable in
JAA Member States.
3 SCOPE
3.1 This AMC is applicable to the various ATS services contained in the ADS-B-NRA
application, including separation services. This AMC fulfils the ADS-B-NRA Safety,
Performance Requirements and Interoperability Requirements as established in
EUROCAE ED-1261, using the methodology described in EUROCAE document ED-78A2.
AMC requirements are driven by the ED-126 requirements for a 5NM separation service
(applicable to both en-route and TMA airspace).
Note: the actual choice of ADS-B-NRA ATC service provision, including of the applicable
separation minima, is at the discretion of the implementing Air Traffic Service Provider,
and should be based on local safety cases.
3.2 The AMC addresses the 1090 MHz Extended Squitter (ES) data link technology as the ADS-
B transmit technology.3
4.1 Related Regulatory Requirements
— CS/FAR 25.1301, 25.1307, 25.1309, 25.1322, 25.1431, 25.1581, or equivalent
requirements of CS 23, 27 and 29, if applicable.
— EU-OPS 1.230, 1.420, 1.845, 1.865, 1040, 1.1045 and 1.1060, as amended, or, if
applicable, equivalent requirements of JAR-OPS 3.
— National operating regulations.
4.2 Related EASA/JAA TGL/NPA/AMC (and FAA TSO) Material
— ETSO-2C112b: Minimum Operational Performance Specification for SSR Mode S
Transponders (adopts ED-73B)
— ETSO-129A (TSO-129/TSO-129A): Airborne Supplemental Navigation Equipment
Using the Global Positioning System (GPS)
1 ED-126: “Safety, Performance and Interoperability Requirements Document for ADS-B-NRA” Application
2 ED-78A: Guidelines for approval of the provision and use of Air Traffic Services supported by Data communications
3 Other, requirements compliant, ADS-B transmit systems (e.g. VDL Mode 4) are expected to be covered through separate regulatory
material, as appropriate.

AMC 20-24
— ETSO-145/ETSO-146 (TSO-145/TSO-146; TSO-145A/TSO-146A): Airborne

Navigation Sensors Using the Global Positioning System (GPS) Augmented by the
Wide Area Augmentation System (WAAS)
— AMC 20-13 Certification of Mode S Transponder Systems for Enhanced Surveillance
— JAA Temporary Guidance leaflet (TGL) 13, Revision 1: Certification of Mode S
Transponder Systems for Elementary Surveillance
4.3 Related FAA Advisory Circular Material
— FAA AC20-138A: Airworthiness Approval of Global Navigation Satellite System
(GNSS) Equipment
4.4 Related EUROCAE/RTCA Standards
— ED-126 (DO-303): Safety, Performance and Interoperability Requirements
Document for ADS-B-NRA Application (December 2006)
— ED78A (DO-264): Guidelines for Approval of the Provision and Use of Air Traffic
Services Supported by data communications;
— ED-102 (DO-260): MOPS for 1090MHz for ADS-B
— DO-260A: MOPS for 1090MHz for ADS-B
— ED-73B (DO-181C): Minimum Operational Performance Specification for
Secondary Surveillance Radar Mode S Transponders
— ED-26: MPS for airborne altitude measurements and coding systems
4.5 Related ICAO Standards and Manuals
— PANS-ATM, Doc 4444, Amendment 4: Procedures for Air Navigation Services – Air
Traffic Management
— Annex 10 (Volume III & IV): Aeronautical Telecommunications
5 ASSUMPTIONS
Applicants should note that this AMC is based on the following assumptions.
5.1 Air Traffic Service Provider (ATSP)
ATSP implements the ADS-B-NRA application compliant with relevant requirements of
the safety, performance and interoperability requirements of EUROCAE standard ED-126.
Deviations from, or supplements to the established standards are assessed by the ATSP.
Deviations that potentially impact the airborne domain should be assessed in
coordination with relevant stakeholders as per ED78A.
Section 8 of this document, “Airworthiness Considerations”, lists permissible deviations
from the target requirements related to the use of existing aircraft installations in support
of initial implementations1. These deviations are currently considered operationally
acceptable under the assumption that ground mitigation means as discussed in the
following subsections, are implemented, at the descretion of the ATSP.
5.1.1 Consistency of position quality indicators with associated position information at
time of transmission
1
Refer to sections 8.3.3, 8.3.5 and 8.8.2.

AMC 20-24
In cases where position quality indicators are not consistent with actual position
quality (e.g., due to uncompensated latency in position transmissions), the
implementing ATSP might:
— treat the higher quality indicator encodings as an advised lower one (e.g.
NUC=7 may be treated as NUC=5) or,
— consider, for separation purpose, a quality indicator more stringent than the
one stated in ED-126 (e.g. NUC =5 rather than NUC=4).
5.1.2 Encoding of NUC Quality Indicator (DO-260 compliant transponders)
In order to mitigate the encoding of the NUC quality indicator based on accuracy
quality information (HFOM) in the case of the unavailability of the GPS RAIM
function (i.e. unavailability of HPL information), the implementing ATSP may, for
instance, rely on the analysis of the frequency and duration of the unavailability of
the RAIM function (as part of the local safety assessment).
5.1.3 Transmission of generic emergency indicator only
In order to mitigate the transmission of only the generic emergency indicator (and
not also the discrete codes selected by the flight crew), It is assumed that
appropriate operational procedures have been established by the implementing
ATSP and that pilots and controllers have been trained in their use.
5.1.4 Communications Service Provider (CSP)
In case of CSPs providing (part of) the ground surveillance data communication
services (operation of ADS-B ground stations and/or surveillance data networks),
the CSP is committed to provide communication services to ATSPs with the
expected Quality of Service as defined in a specific Service Level Agreement.
The Service Level Agreement is bilaterally agreed between the CSP and an ATSP.
The terms of reference of the Service Level Agreement are consistent with the
performance requirements of the ED-126 document.
Each State publishes in its AIP/NOTAM, or equivalent notification, information related to
the surveillance provisions, schedule, relevant procedures and confirmation of
compliance with ED-126.
6 SYSTEM DESCRIPTION
The basic concept of ADS-B involves the broadcasting of surveillance information from aircraft
via a data link.
To support the ADS-B-NRA application, the overall ADS-B avionics system (in the following
referred to as “ADS-B System”) would need to provide the following functions:
— Adequate surveillance data provision capability;
— ADS-B message processing (encoding and generation);
— ADS-B message transmission (1090 MHz ES airborne surveillance data-link);
Whereas the latter two functions are incorporated in the 1090 MHz ES ADS-B transmit system,
the surveillance data provision is realised through various on-board surveillance data sources
(e.g. horizontal position source, barometric altimetry, ATC transponder control panel).

AMC 20-24
The horizontal position accuracy and integrity requirements of the ADS-B-NRA application are
associated with quality indicators which form part of the air-to-ground ADS-B message
exchange. The interconnecting avionics architecture is part of the ADS-B System.
7 FUNCTIONAL CRITERIA
Note: ICAO and EUROCAE/RTCA interoperability references, including aspects of range and
resolution of the various data items listed hereafter, for both ED-102/DO-260 and DO-260A
equipment-based ADS-B transmit systems, are presented in Appendix 4.
7.1 In line with ED-126 (section 4), the ADS-B System needs to meet the following surveillance
data transmission requirements, as a minimum:
— A unique ICAO 24 bit aircraft address (contained within each ADS-B message
transmission);
— Horizontal Position (latitude and longitude);
— Horizontal Position Quality Indicator(s) (position integrity for both ED-102/DO-260
and DO-260A based ADS-B transmit systems, as well as accuracy for DO-260A
based ADS-B transmit systems);
— Barometric Altitude;
— Aircraft Identification;
— Special Position Identification (SPI);
— Emergency Status and Emergency Indicator;
— Version Number (in aircraft operational status message, if avionics are DO-260A
compliant).
7.2 In line with ED-126 (section 4), it is recommended that the ADS-B System meets the
following optional surveillance data transmission requirement:
— Ground Velocity.
8.1 Airworthiness Certification Objectives
For the purposes of the ADS-B-NRA application, the ADS-B System installed in the aircraft
needs to be designed to deliver data that satisfy the airborne domain requirements in
line with ED-126 Section 3.4, (Appendix 3 provides a summary for information purposes).
8.2 ADS-B System
8.2.1 The (overall) ADS-B System integrity level with respect to the processing of
horizontal position data and horizontal position quality indicators, covering the
processing (and data exchange) chain from horizontal position data source(s) to
ADS-B transmit data string encoding) needs to be 10-5/fh (refer also to Table 1 in
Appendix 3).
Note 1: this integrity level is required to adequately protect against the corruption
of horizontal position data and horizontal position quality indicators when applying
separation.
Note 2: These performance figures have been set for the “ADS-B out” function, to
be used in ADS-B NRA operations as laid down by the Operational Safety
Assessment in Annex C of ED 126.

AMC 20-24
Note 3: Compliance with these performance figures do not constitute per se a

demonstration that the safety objectives of ADS-B NRA operations allocated to
avionics are achieved.
Note 4: Also refer to § 3.1.
8.2.2 The (overall) ADS-B System continuity level needs to be 2*10-4/fh (refer also to
Table 1 in Appendix 3).
Note 1: These performance figures have been set for the “ADS-B out” function, to
be used in ADS-B NRA operations as laid down by the Operational Safety
Assessment in Annex C of ED 126;
Note 2: Compliance with these performance figures do not constitute per se a
demonstration that the safety objectives of ADS-B NRA operations allocated to
avionics are achieved;
Note 3: Also refer to § 3.1.
8.2.3 The latency of the horizontal position data, including any uncompensated latency,
introduced by the (overall) ADS-B System does not exceed 1.5 second in 95% and
3 seconds in 99.9% of all ADS-B message transmission cases (refer also to Table 1
in Appendix 3).
8.3 ADS-B Transmit System
8.3.1 Compliance with the air-ground interoperability requirements, as specified in ED-
126 and presented in Section 7.1 and Appendix 4, needs to be demonstrated.
8.3.2. For 1090 MHz Extended Squitter ADS-B transmit systems, this should be
demonstrated by the relevant tests documented in:
— ED-73B/ETSO-2C112b (or DO-181C);
— ED-102, as a minimum, or an equivalent standard which is acceptable to the
Agency (e.g. DO-260 or DO-260A).
8.3.3 ADS-B transmit systems need to transmit horizontal position quality indicators
consistent with the associated position information at the time of transmission.
For the expression of the position accuracy quality, the related indicator should
therefore reflect:
— The quality (in terms of both integrity and accuracy) of the position
measurement itself; and
— Any (uncompensated) latency incurring prior to transmission.
Note: guidance on the quality indicators is provided in Appendix 4.
The applicant needs to demonstrate the correctness of consistent quality indicator
encodings in line with (minimum) position source quality and any
(uncompensated) maximum latency as expressed in 8.2.3.
Permissible deviation for initial implementations:
For initial implementations, some aircraft installations may not take into account
any (uncompensated) latency in the encoding of the position accuracy quality
indicator as applicable at the time of transmission. Hence, such installations might
transmit horizontal position quality indicators that are consistent with the

AMC 20-24
associated position information only for lower quality indicator encodings1 (e.g.
NUC=5 or NAC=5) but not higher ones (e.g. NUC=7 or NAC=7). Such deviation from
the above target requirement need to be listed in the Aircraft Flight Manual (refer
to Section 9.3).
8.3.4 The value of the horizontal position quality indicators need to be based on the
integrity information for the encoding of the ED-102/DO-260 related NUC and the
DO-260A related NIC quality indicator, as related to the horizontal position
sources.
In addition, the encoding of the DO-260A NAC quality indicator needs to be based
on the accuracy information of the horizontal position sources.
8.3.5 In case of ED-102/DO-260 based ADS-B transmit systems, the NUC Quality
Indicator value need to be encoded based on the integrity containment radius2
only.
For initial implementations, some GNSS position source based aircraft installations
may encode the NUC Quality Indicator on accuracy quality information (HFOM)
under rare satellite constellation circumstances leading to the temporary
unavailability of the integrity monitoring (RAIM) function (i.e. unavailability of
integrity containment radius calculation). Such deviation from the above target
requirement need to be listed in the Aircraft Flight Manual (refer to Section 9.3).
8.3.6 If the ADS-B transmit system does not have a means to determine an appropriate
integrity containment radius and a valid position is reported, then the Quality
Indicator (i.e. NUC or NIC) need to be encoded to indicate that the integrity
containment radius is unknown (i.e. NUC/NIC should be set to ‘zero’).
8.3.7 Transmitter antenna installation needs to comply with guidance for installation of
ATC transponders to ensure satisfactory functioning. (Also refer to ED-73B)
8.3.8 If more than one ADS-B transmit system is installed, simultaneous operation of
both transmit systems needs to be prevented.
8.4 Horizontal Position Data Sources
8.4.1 The requirements on horizontal position data sources are based on the ED-126
safety and performance assessments.
8.4.2 Components of horizontal position data sources external to the aircraft ADS-B
system (such as the GNSS space segment) fall outside these airworthiness
considerations. Such external components are assumed to operate in accordance
with their specified nominal performance3.
Nevertheless, failures of the external data source components are required to be
detected through on-board monitoring (as expressed in section 8.4.3).
1 This is a consequence of the definition of the quality indicator encoding describing an interval of values between a lower and an upper
bound (refer also to Appendix 4.2). For instance, a NUC=5 encoding expresses an upper bound of position accuracy quality indication of
0.3NM whilst a NUC=7 encoding expresses an upper bound of 0.05NM. Therefore, in case of e.g. the actual GNSS position source
performance, a NUC=5 encoding provides sufficient margin to also correctly express the effects of on-board uncompensated latency
whilst this is not the case for a NUC=7 encoding any more.
2 I.e. GNSS conformant HPL/HIL information.
3
For GNSS based systems, this includes satellite constellation aspects.

AMC 20-24
8.4.3 Any eligible horizontal position data source needs to meet the following minimum
requirements (refer also to Table 2 in Appendix 3):
— Correct encoding of quality indicator information in line with the actual
performance of the selected horizontal position data source(s), i.e. in
relation to position integrity containment bound (ED-102/DO-260 and DO-
260A ADS-B transmit systems) and position accuracy (DO-260A ADS-B
transmit systems);
— Position source failure probability: 10-4 per hour1;
— Position integrity alert failure probability, commensurate with the
performance characteristics of GNSS integrity monitoring2: 10-3 (per position
source failure event);
— Position integrity time to alert: 10 seconds.
8.4.4 If available and valid, integrity containment radius information should be provided
to the ADS-B transmit system from the position data source, or equivalent, on the
same interface as and together with each positional data.
8.4.5 If the integrity containment radius is not provided by the horizontal position data
source, the ADS-B transmit system may use other means to establish an
appropriate integrity containment radius3, provided a requirements compliant
integrity alert mechanism is available.
8.4.6 Use of GNSS Systems as Primary Position Data Source
8.4.6.1 GNSS is considered as primary horizontal position data source for the
provision of an acceptable accuracy and integrity performance in support of
the ATC separation services contained within the ADS-B-NRA application.
The ED-126 safety and performance assessments are based on the specified
performance and characteristics of GNSS systems, including receiver
autonomous integrity monitoring. Therefore, for GNSS systems as specified
in section 8.4.6.2, a safety and performance demonstration is not required.
8.4.6.2 If GNSS is used as a positional source, the GNSS system should be either
compatible with:
— ETSO C-129A, TSO C-129 or TSO C-129A; or
— ETSO C-145/C-146 or TSO C-145A/C-146A,
capable of delivering position data with a periodic interval of at least 1.2 s4.
8.4.6.3 For GNSS systems compatible with (E)TSO C-129 (any revision), it is highly
desired that the system incorporates Fault Detection and Exclusion
1 For GNSS based position sources, the failure occurs outside the aircraft system and is therefore expressed as per ATSU-hour. Proof of
compliance of alternative solely aircraft based sources should take this into account and might have to express the requirement as 10-5
per flight hour (i.e. for the en-route environment).
2 As realised through receiver autonomous integrity monitoring (RAIM), including its characteristics of increasingly less likely to fail for
position errors beyond the horizontal protection limit. Within ED-126, the position source failure is modelled as a bias error that equals
the integrity containment radius.
3 E.g. HPL/HIL based upon known RAIM protection threshold.
4 ETSO C-145/C146 provides additional capabilities compared with ETSO C129A such as: processing of GPS without Selective Availability,
processing of SBAS signals when available and Fault Detection Exclusion as a basic function. Therefore ETSO C145/146 usually provides
higher quality integrity values than ETSO C-129A equipment.

AMC 20-24
capability as defined in AC 20-138A, Appendix 1, “GPS as a Primary Means of

Navigation for Oceanic/Remote Operations”.
8.4.7 Use of Alternative Compliant Position Data Sources
As the ED-126 safety and performance assessments are based on the performance
and characteristics of GNSS systems, for alternative position sources a dedicated
safety and performance assessment is required to demonstrate compliance with
the ED-126 requirements.
8.4.8 Use of Temporary Back-up Position Data Sources
Back-up position data sources not complying with the requirements referred to in
section 8.4.3 may prove very useful in enhancing the continuity of ADS-B
surveillance provision during temporary outages of the primary (or equivalent
alternative) position data sources.
Any such back-up position data source needs to report its accuracy and integrity
performance to the ADS-B transmit system, in a format compliant with ED-102/DO-
260 or DO-260A, as appropriate.
8.5 Barometric Altitude Data Sources
8.5.1 Pressure altitude provided to the ADS-B transmit system needs to be in accordance
with existing requirements for ATC transponders.
8.5.2 The digitizer code selected needs to correspond to within plus or minus 38.1 m
(125 ft), on a 95% probability basis, with the pressure-altitude information
(referenced to the standard pressure setting of 1013.25 hectopascals), used on
board the aircraft to adhere to the assigned flight profile. (ICAO Annex 10, Vol IV,
3.1.1.7.12.2.4. See also EUROCAE ED-26).
The performance of the encoders and of the sensors needs to be independent from
the pressure setting selected.
8.5.3 The transponder should indicate correctly the altitude resolution (quantisation)
used, i.e. 25ft (from an appropriate source, default resolution) or 100ft (Gillham’s
coded source, permissible alternative resolution).
The conversion of Gillham’s coded data to another format before inputting to the
transponder is not permitted unless failure detection1 can be provided and the
resolution (quantisation) is set in the transmitted data to indicate 100ft.
8.5.4 In case more stringent barometric altimetry requirements are applicable in line
with e.g. airspace requirements (e.g. RVSM) or other function requirements (e.g.
ACAS II), then these requirements and their related regulation take precedence.
8.6 Aircraft Identification
8.6.1 Identification needs to be provided to the ADS-B transmit system so that the
information is identical to the filed ICAO flight plan. This information may be
provided from:
— A flight management system; or
— A pilot control panel; or
1 For instance, this need can be satisfied by means of dual independent altitude corrected sensors together with an altitude data
comparator (which may be incorporated and enabled in the ADS-B transmit system).

AMC 20-24
— For aircraft, which always operate with the same flight identification (e.g.
using registration as the flight identification) it may be programmed into
equipment at installation.
8.6.2 In case no ICAO flight plan is filed, the Aircraft Registration needs to be provided
to the ADS-B transmit system.
8.7 Special Position Identification (SPI)
For ATC transponder-based ADS-B transmit systems, the SPI capability needs to be
provided. The SPI capability should be integrated into the transponder functionality and
should be controlled from the transponder control panel.
8.8 Emergency Status/Emergency Indicator
8.8.1 When an emergency status (i.e. discrete emergency code) has been selected by
the flight crew, the emergency indicator needs to be set by the ADS-B transmit
system.
8.8.2 For ATC transponder-based ADS-B transmit systems, the discrete emergency code
declaration capability should be integrated into the transponder functionality and
should be controlled from the transponder control panel.
For initial implementations, instead of the required transmission of the discrete
emergency codes 7500, 7600 and 7700 when selected by the flight crew, the
transmission of only the generic emergency indicator can satisfy this requirement.
Such deviation from the above target requirement needs to be listed in the Aircraft
Flight Manual (refer to Section 9.3).
8.9 Airworthiness Considerations regarding Optional Provisions
8.9.1 Ground Velocity (OPTIONAL)
Ground velocity, e.g. from an approved GNSS receiver, in the form of East/West
and North/South Velocity (including a velocity quality indicator) is recommended
to be provided.
8.9.2 Special Position Identification (SPI) (OPTIONAL)
For non-ATC transponder-based ADS-B transmit systems (i.e. installations based on
dedicated ADS-B transmitters), a discrete input or a control panel should be
provided to trigger the SPI indication.
8.9.3 Emergency Status/Emergency Indicator (OPTIONAL)
For non-ATC transponder-based ADS-B transmit systems (i.e. installations based on
dedicated ADS-B transmitters), a discrete input or a control panel should be
provided to indicate the emergency status (discrete emergency code).
8.9.4 Flight Deck Control Capabilities (OPTIONAL)
8.9.4.1 Means should be provided to the flight crew to modify the Aircraft
Identification information when airborne.
8.9.4.2 Means should be provided to the flight crew to disable the ADS-B function
on instruction from ATC without disabling the operation of the ATC
transponder function.

AMC 20-24
Note: It is recommended to implement an independent ADS-B disabling function.

For future ADS B application such flight deck capability may become mandatory. It
should be recalled that disabling the operation of the transponder will disable also
the ACAS function.
8.9.4.3 Means should be provided to the flight crew to disable the transmission of
the barometric altitude.
9 COMPLIANCE WITH THIS AMC
9.1 Airworthiness
9.1.1 When showing compliance with this AMC, the following points should be noted:
a) The applicant will need to submit, to the Agency, a certification plan and a
compliance statement that shows how the criteria of this AMC have been
satisfied, together with evidence resulting from the activities described in
the following paragraphs.
b) Compliance with the airworthiness requirements (e.g. CS-25) for intended
function and safety may be demonstrated by equipment qualification, safety
analysis of the interface between the ADS-B equipment and data sources,
structural analyses of new antenna installations, equipment cooling
verification, evidence of a human to machine interface, suitable for ADS-B-
NRA.
c) The safety analysis of the interface between the ADS-B transmit system and
its data sources should show no unwanted interaction under normal or fault
conditions.
d) The functionality for ADS-B-NRA application may be demonstrated by
testing that verifies nominal system operation, the aircraft derived
surveillance data contained in the ADS-B messages, and the functioning of
system monitoring tools/fault detectors (if any).
9.1.2 The functionality for ADS-B-NRA application may be further demonstrated by
ground testing, using ramp test equipment where appropriate, that verifies
nominal system operation, the aircraft derived surveillance data contained in the
ADS-B messages, and the functioning of system monitoring tools/fault detectors (if
any).
Note: this limited testing assumes that the air-ground surveillance systems have
been shown to satisfactorily perform their intended functions in the flight
environment in accordance with applicable requirements.
To minimise the certification effort for follow-on installations, the applicant may
claim credit, from the Agency, for applicable certification and test data obtained
from equivalent aircraft installations.
9.2 Performance
Where compliance with a performance requirement cannot readily be demonstrated by
a test, then the performance may be verified by an alternative method such as analysis,
including statistical analysis of measurements under operational conditions.

AMC 20-24
9.3.1 The Aircraft Flight Manual (AFM) or the Pilot’s Operating Handbook (POH),
whichever is applicable, needs to provide at least a statement of compliance that
the ADS-B System complies with this AMC20-24 and if deviations are applicable.
Deviations,1 including those stated in this document, as appropriate may be
included or referred to.
9.4.1 The applicant will need to submit, to the Agency, a compliance statement, which
shows how the criteria of this AMC have been satisfied for existing installations.
Compliance may be supported by design review and inspection of the installed
system to confirm the availability of required features, functionality and
acceptable human-machine interface.
9.4.2 Where this design review finds items of non-compliance, the applicant may offer
mitigation that demonstrates an equivalent level of safety and performance. Items
presented by the applicant which impact safety, performance and interoperability
requirements allocation will need to be coordinated in accordance with ED-78A.
10.1 General
10.1.1 The installation should be certified according to airworthiness considerations in
section 8 prior to operational approval.
10.1.2 The assumptions in section 5, concerning Air Traffic and Communications Services
Providers, and Aeronautical Information Services, should have been satisfied.
10.1.3 A unique ICAO 24 bit aircraft address should be assigned by the responsible
authority to each airframe.
10.2.1 In all cases, flight crews should comply with the surveillance provisions, schedules
and relevant procedures contained in the Aeronautical Information Publications
(AIP) published by the appropriate authorities.
10.2.2 Direct controller-pilot VHF voice communications should be available at all times.
10.2.3 If flight crew receive equipment indications showing that position being broadcast
by the ADS-B system is in error (e.g. GPS anomaly), they should inform the ATSP,
as appropriate, using any published contingency procedures.
10.2.4 When there is not an independent Flight Deck Control selection between the ADS-
B function (ADS-B on/off) and the ATC transponder function, the crew must be fully
aware that disabling the ADS B function will also lead to disable the ACAS function.
10.3.1 Operations Manual
10.3.1.1 The Operations Manual should include a system description, operational
and contingency procedures and training elements for use of the ADS-B-NRA
application.
1
Refer to sections 8.3.3, 8.3.5 and 8.8.2.

AMC 20-24
10.3.1.2 The Operations Manual, preferably section B, should contain the

operational aspects described in this guidance material.
10.3.1.3 Operators operating under the provisions of ICAO Annex 6 Part II
“International General Aviation – Aeroplanes” are not required to have an
operations manual.
However, in order to use ADS-B applications, the operator should develop
similar training and operational procedures to the ones described in this
guidance material. This material may need to be approved by the State of
Registry of the operator in accordance with national practice and sight of
this approval may be required by the ADS-B navigation service provider.
10.3.2 Flight Crew Training
10.3.2.1 Aircraft operators should ensure that flight crew are thoroughly familiar
with all relevant aspects of ADS-B applications.
10.3.2.2 Flight crew training should address the:
a) General understanding of ADS-B-NRA operating procedures;
b) Specific ADS-B associated phraseology;
c) General understanding of the ADS-B technique and technology;
d) Characteristics and limitations of the flight deck human-machine
interface, including an overview of ADS-B environment and system
descriptions;
e) Need to use the ICAO defined format for entry of the Aircraft
Identification or Aircraft Registration marking as applicable to the
flight;
Note 1: ICAO Document 8168-OPS/611 Volume I (Procedures for Air
Navigation Services) requires that flight crew of aircraft equipped with
Mode “S” having an aircraft identification feature should set the
aircraft identification into the transponder. This setting is required to
correspond to the aircraft identification that has been specified at Item
7 of the ICAO flight plan and consists of no more than seven
characters. If the aircraft identification consists of less than seven
characters, no zeros, dashes or spaces should be added. If no flight
plan has been filed, the setting needs to be the same as the aircraft’s
registration, again, up to a maximum of seven characters.
Note 2: The shortened format commonly used by airlines (a format
used by International Airlines Transport Association (IATA)) is not
compatible with ICAO provisions for the flight planning and ATC
services used by ATC ground systems.
f) Operational procedures regarding the transmission of solely the
generic emergency flag in cases when the flight crew actually selected
a discrete emergency code (if implemented, refer to section 8.8) and
SPI;
g) Indication of ADS-B transmit capability within the ICAO flight plan but
only when the aircraft is certified according to this AMC;

AMC 20-24
h) Handling of data source errors (e.g. discrepancies between navigation

data sources) (refer to 10.2.3);
i) Incident reporting procedures;
j) Crew Resources Management and associated human factors issues.
Significant incidents associated with ATC surveillance information transmitted by the
ADS-B data link that affects or could affect the safe operation of the aircraft will need to
be reported in accordance with EU-OPS 1.420 (or national regulations, as applicable).
10.5 Minimum Equipment List
The MEL will need to be revised to indicate the possibility of despatch of aircraft with the
ADS-B system unserviceable or partially unserviceable.
11 MAINTENANCE
11.1 Maintenance tests should include a periodic verification check of aircraft derived data
including the ICAO 24 bit aircraft address using suitable ramp test equipment. The check
of the 24 bit aircraft address should be made also in the event of a change of state of
registration of the aircraft.
11.2 Maintenance tests should check the correct functioning of system fault detectors (if any).
11.3 Maintenance tests at ADS-B transmit system level for encoding altitude sensors with
Gillham’s code output should be based on the transition points defined in EUROCAE ED-
26, Table 13.
11.4 Periodicity for the check of the ADS-B transmitter should be established.
EASA documents are available from http://www.easa.europa.eu.
JAA documents are available from the JAA publisher Information Handling Services (IHS).
Information on prices, where and how to order is available on both the JAA web site www.jaa.nl
and the IHS web site www.avdataworks.com.
ICAO documents may be purchased from Document Sales Unit, International Civil Aviation
Organisation, 999 University Street, Montreal, Quebec, Canada H3C 5H7, (Fax: 1 514 954 6769,
e-mail: [email protected]) or through national agencies.
EUROCAE documents may be purchased from EUROCAE, 102 rue Etienne Dolet, 92240
MALAKOFF, France, (Fax: 33 1 46556265). Web site: www.eurocae.org.
RTCA documents may be purchased from RTCA, Incorporated, 1828 L Street, Northwest, Suite
820, Washington, D.C. 20036-4001 U.S.A. Web site: www.rtca.org.
EUROCONTROL documents may be requested from EUROCONTROL, Documentation Centre,
GS4, Rue de la Fusee, 96, B-1130 Brussels, Belgium; (Fax: 32 2 729 9109 or web site
www.eurocontrol.int).
FAA documents may be obtained from Department of Transportation, Subsequent Distribution
Office SVC-121.23, Ardmore East Business Centre, 3341 Q 75th Avenue, Landover, MD 20785,
USA.
Australia CASA documents are available from http://www.casa.gov.au/.
[Amdt 20/3]

AMC 20-24
Appendix 1 to AMC 20-24

Appendix 1.1: Common Terms

Reference should be made to EUROCAE document ED-126 for the definitions of terms.
Appendix 1.2: Abbreviations
ADS-B Automatic Dependent Surveillance- Broadcast
ADS-B-NRA Enhanced ATS in Non-Radar Areas using ADS-B Surveillance
AFM Aircraft Flight Manual
ANC Air Navigation Commission (ICAO)
ATSP Air Traffic Service Provider
ATC Air Traffic Control
ATS Air Traffic Services
ATSU Air Traffic Service Unit
ATM Air Traffic Management
CASCADE Co-operative ATS through Surveillance and Communication Applications Deployed in
ECAC
EUROCONTROL European Organisation for the Safety of Air Navigation
FAA Federal Aviation Administration
GNSS Global Navigation Satellite System
HPL Horizontal Protection Limit
HIL Horizontal Integrity Limit
ICAO International Civil Aviation Organisation
INTEROP Interoperability Requirements
MEL Minimum Equipment List
NIC Navigation Integrity Category
NACp Navigation Accuracy Category
NUC Navigation Uncertainty Category
POH Pilots Operating Handbook
RFG Requirement Focus Group
SIL Surveillance Integrity Level
SPI Special Position Identifier
SPR Safety and Performance Requirements
SSR Secondary Surveillance Radar
OSED Operational Services and Environment Definition
Rc Horizontal Position Integrity Containment Radius
TMA Terminal Manoeuvring Area
[Amdt 20/3]

AMC 20-24

Appendix 2.1: Summary of core ADS-B-NRA Operational Assumptions

— The ADS-B-NRA application assumes implementation of the procedures contained in the PANS-
ATM ADS-B amendment. Fallback procedures from the radar environment apply to ADS-B-NRA
when necessary. For example, ATC could apply alternate procedural separation (e.g., a vertical
standard) during degraded modes.
— En route traffic density is assumed to be the same as in the current environment in which single
radar coverage would enable the provision of a 5NM separation service for en route regions.
This corresponds to low or medium density.
— Direct Controller-Pilot Communication (VHF) is assumed to be available at all times.
— It is assumed that the ADS-B coverage is known to the Controller in the controlled airspace.
Appendix 2.2: Summary of core ADS-B-NRA Ground Domain Assumptions
— Controller operating procedures are assumed to be unaffected by the selection of an ADS-B
data link, i.e., the ADS-B data link is assumed to be transparent to the controller.
— Air Traffic Controllers are assumed to follow existing procedures for coordination and transfer
of aircraft. This applies to coordinating appropriate information with downstream units and
complying with local agreements established between ATC units regarding separation
standards to be established prior to entry into a bordering ATC unit.
— Appropriate ATS authorities are assumed to provide controllers with adequate contingency
procedures in the event of ADS-B failures or degradation.
— It is assumed that there is a monitoring capability in the ADS-B Receive Subsystem that monitors
the health and operation of the equipment and sends alerts and status messages to the Air
Traffic Processing Subsystem.
[Amdt 20/3]

AMC 20-24

Summary of ADS-B-NRA Airborne Safety and Performance Requirements
Parameter Requirement
Horizontal Position and Horizontal Position Quality 10-5/fh
Indicator(s)
ADS-B System Continuity 2*10-4/fh
Horizontal Position Latency1 1.5 sec/95%
Table 1: Overall Minimum Airborne ADS-B System2 Requirements
Horizontal Position Source
— Accuracy (95%) — 5 NM Sep: 926 m
— Integrity
— Containment Radius (Rc) — 5 NM Sep: Rc=2 NM
— Source Failure Probability 10-4/h 3
— Alert Failure Probability 10-3 (per position source failure event)
— Time to Alert — 5 NM Sep: 10 sec

Table 2: Minimum Horizontal Position Source Requirements
Note: for DO-260 based ADS-B transmit systems, the related encoding of the horizontal position quality
indicator through the Navigation Uncertainty Category (NUC) effectively leads to a containment radius
requirement of 1NM for a 5 NM separation service.
Note: accuracy and integrity containment radius requirements are expressed here as guidance to
related horizontal position source regulation (refer to section 8.4).
Note: the containment bound requirements reflect the outcomes of both the collision risk assessment
(CAP) and time-to-alert assessment.
Note: the accuracy and integrity containment radius requirements have to be met by the horizontal
position source, taking into account the effects of on-board latency (if not compensated for).
An uncompensated latency of 1.5 seconds translates into a dilution in the order of 450 metres
(assuming an aircraft speed of 600 knots in en-route airspace). This value of 450 metres has to be
added to the actual performance of the horizontal position source(s), the sum of which has to be within
the required bounds.
The GNSS equipment specified in 8.4.6 meets the overall accuracy and integrity requirements, including
the effects of an uncompensated latency of maximum 1.5 second accumulated up to the time of
transmission.
1 Uncompensated delay measured from to the time of validity of position measurement until ADS-B transmission (i.e. at RF level).
2 As defined in section 6.
3
For GNSS based functions, expressed as an assumption of GNSS performance.

AMC 20-24
Barometric Altitude — Accuracy: as per the installed sensors (refer to
section 8.5.2)
— Maximum Latency: 1 sec (as for SSR)
Aircraft Identification, SPI, Emergency Status As for SSR [AMC20-13].

Table 3: Other Minimum ADS-B Surveillance Data Requirements
Parameter Loss Corruption Note

Barometric Altitude Minor Minor As for SSR [AMC20-13].
Aircraft Identification Minor Minor As for SSR.[AMC20-13]
Table 4: Failure Condition Categories
[Amdt 20/3]

AMC 20-24

Appendix 4.1: Summary of ADS-B-NRA Air-to-ground Interoperability Requirements

The minimum set of parameters that should be provided to support the ADS-B-NRA application are
summarised in the following table extracted from ED-126:1
Version 0 Version 1
BDS
Parameter ICAO Annex 10 Amendment 79,
register DO-260/ED102 DO-260A
VOL III, App to chap 5
Aircraft identification 0.8 §2.3.4 §2.2.3.2.5 §2.2.3.2.5
SPI2 0.5 §2.3.2.6 §2.2.3.2.3.2 §2.2.3.2.3.2
Emergency indicator 0.5 §2.3.2.6 §2.2.3.2.3.2 §2.2.3.2.3.2
Barometric altitude 0.5 §2.3.2.4 §2.2.3.2.3.4 §2.2.3.2.3.4
Quality indicator 0.5 §2.3.1 §2.2.3.2.3.1 §2.2.3.2.3.1
(NUC/NIC)
Airborne Latitude 0.5 §2.3.2.3 §2.2.3.2.3.7 §2.2.3.2.3.7
Position Longitude 0.5 §2.3.2.3 §2.2.3.2.3.8 §2.2.3.2.3.8
Emergency status3 4 6.1 Table 2-97 §2.2.3.2.7.9 §2.2.3.2.7.8
Quality indicator (NACp) 6.5 No definition No definition §2.2.3.2.7.2.7
Quality indicator (SIL) 6.5 No definition No definition §2.2.3.2.3.1.1
Version Indicator5 6.5 No definition No definition §A.1.4.10.5
Table 5: Mandatory ADS-B-NRA Parameters
The minimum set of parameters that should be provided to support the ADS-B-NRA application are
summarised in the following table extracted from ED-126:
Version 0 Version 1
BDS
Parameter ICAO Annex 10 Amendment 79,
register DO-260/ED102 DO-260A
VOL III, App to chap 5
Airborne Ground Velocity 0.9 §2.3.5 §2.2.3.2.6 §2.2.3.2.6
Table 6: Optional ADS-B-NRA Parameters
Appendix 4.2: Guidance on Encoding of Positional Quality Indicators

In order to be able to check the compliance of the actually transmitted ADS-B data with the required
quality on the recipient side, ADS-B message transmissions contain “Quality Indicators”. These are
expressed for ED-102/DO-260 and DO-260A compliant ADS-B transmit systems as follows:
— ED-102/DO-260: Navigation Uncertainty Category (NUC), a combined expression of (accuracy
and) integrity requirements through a single parameter;
1 The notion of version “0” and “1” differentiates between DO-260/ED-102 and DO-260A transponders.
2 If provided by flight deck controls.
3 If provided by flight deck controls.
4 For special conditions under which the non-transmission of selected discrete emergency codes is allowed, refer to Section 8.8.2.
5
Only for D0-260A based ADS-B transmit systems.

AMC 20-24
— DO-260A: Navigation Accuracy Category (NACp) to express the position accuracy (as a 95
percentile), Navigation Integrity Category (NIC) to express the integrity containment radius and
Surveillance Integrity Level (SIL) to specify the probability of the true position lying outside that
containment radius without alerting.
Minimum acceptable NUC and NIC/NACp values in support of 5 NM ADS-B-NRA separation services,
based on the requirements summarised in Table 2 of Appendix 4, are as follows in line with the
“NIC/NACp to NUC” conversion table below.
NUC values (encoding based on HPL, with the accuracy requirements met by GNSS systems by design
and in line with the related NACp values in below conversion table):
— 5 NM separation: NUC = 4;
The corresponding NIC/NACp values are as follows.
— 5 NM separation: NIC = 4, NACp = 5,
The SIL value is established to SIL≥2 in line with the combination of the position source failure and
position integrity alert failure requirements, as summarised in Table 2 of Appendix 4.
Note 1: In case the SIL value is not output by the position data sources, it is recommended that the
ADS-B transmit system provides for the static setting of SIL as part of the installation procedure and as
demonstrated for the applicable position data source configuration.
Note 2: ED-126 provides, based on its reference collision risk analysis only, arguments for an equally
appropriate encoding of a SIL=2 as a matter of expressing the system integrity as well. As for the
presentation of the values presented in this document, it is at the discretion of the ATSP to decide upon
the appropriate threshold values required in support of the separation services in its airspace.
NUC (max Rc NM) NIC (max Rc NM) NACp (95% bound)
9 (0.003) 11 (0.004) 11 (3 m)
8 (0.01) 10 (0.013) 10 (10 m)
- 9 (0.04) 9 (30 m)
7 (0.1) 8 (0.1) 8 (0.05 NM)
6 (0.2) 7 (0.2) 7 (0.1 NM)
5 (0.5) 6 (0.6) 6 (0.3 NM)
4 (1.0) 5 (1.0) 5 (0.5 NM)
3 (2.0) 4 (2.0) 4 (1 NM)
- 3 (4.0) 3 (2 NM)
- 2 (8.0) 2 (4 NM)
2 (10) 1 (20) 1 (10 NM)
1 (20) 1 (20) 1 (10 NM)
0 (no integrity) 0 (> 20) 0 (unknown)
Table 7: NUC conversion to NIC and NACp
[Amdt 20/3]

AMC 20-25A
AMC 20-25A
AMC 20-25A Airworthiness considerations for Electronic Flight Bags

(EFBs)
1 PURPOSE AND SCOPE

This Acceptable Means of Compliance (AMC) is one, but not the only, means to obtain an
airworthiness approval for installed electronic flight bags (EFBs) and for EFB installed resources.
Additional guidance material can be found in ICAO Doc 10020 ‘Manual of Electronic Flight Bags’.
Operational considerations for the evaluation and approval of the use of EFB applications can
be found in Commission Regulation (EU) No 965/2012.
2.1 Related Certification Specifications
CS 25.561, 25.777, 25.789, 25.1301, 25.1302, 25.1309, 25.1316, 25.1321, 25.1322,
25.1357, 25.1431, 25.1529, 25.1581
CS 23.2270, 23.2500, 23.2505, 23.2510, 23.2600, 23.2605, 23.2620
CS 29.1301, 29.1309, 29.1321, 29.1322, 29.1431, 29.1581
CS 27.1301, 27.1309, 27.1321, 27.1322, 27.1581
Appendix G to CS-23, Appendix H to CS-25, and Appendices A to CS-27 and CS-29:
Instructions for Continued Airworthiness
EASA Special Condition: Information Security Protection of Aircraft Systems and
Networks
2.2 Related Guidance Material
EASA AMC 25.1581 Appendix 1 – Computerised Aeroplane Flight Manual
EASA AMC 25.1309 System Design and Analysis
EASA AMC 25-11 Electronic Flight Deck Displays
EUROCAE ED-130() Guidance for the Use of Portable Electronic Devices (PEDs) on Board
Aircraft
EUROCAE ED-12() Software Considerations in Airborne Systems and Equipment
Certification
EUROCAE ED-14D/DO-160D (or later revisions) Environmental Conditions and Test
Procedures for Airborne Equipment
EUROCAE ED-76/RTCA DO-200A (or later revisions) Standards for Processing Aeronautical
Data
EUROCAE ED-80() Design Assurance Guidance for Airborne Electronic hardware
FAA AC 120-76() Guidelines for the Certification, Airworthiness, and Operational Approval
of Electronic Flight Bag Computing Devices
FAA AC 20-173 Installation of Electronic Flight Bag Components

AMC 20-25A
EASA ETSO-C165A/FAA TSO-C165A Electronic Map Systems for Graphical Depiction of

Aircraft Position / Electronic Map Display Equipment for Graphical Depiction of Aircraft
Position (Own-ship)
RTCA DO-178() Software Considerations in Airborne Systems and Equipment Certification
RTCA DO-254() Design Assurance Guidance for Airborne Electronic Hardware
RTCA DO-257() Minimum Operation Performance Standards for the Depiction of
Navigational Information on Electronic Maps
RTCA DO-311() Minimum Operational Performance Standards for Rechargeable Lithium
Battery Systems
TGM/21/07 Electrical Wiring Policy for certification of large Aeroplanes, Engines and
Propeller
3 GLOSSARY OF TERMS IN THE CONTEXT OF THIS AMC
3.1 Consumer device
Electronic equipment primarily intended for non-aeronautical use.
3.2 Data connectivity for EFB systems
Data connectivity for EFB system supports either uni- or bi-directional data
communication between the EFB and other aircraft systems (e.g. avionics).
Direct interconnectivity between EFBs or direct connectivity between EFBs and ground
systems as with a T-PED (e.g. GSM, Bluetooth) are not covered by this definition.
3.3 Electronic Flight Bag (EFB)
An electronic information system, comprised of equipment and applications for flight
crew, which allows for the storing, updating, displaying, and processing of EFB functions
to support flight operations or duties.
3.4 EFB host platform
When considering an EFB system, the EFB host platform is the equipment (i.e. hardware)
in which the computing capabilities and basic software (e.g. operating system,
input/output software) reside.
3.5 EFB software application
Software installed on an EFB system that provides specific operational functionality.
3.6 EFB system
An EFB system comprises the hardware (including any battery, connectivity provision, I/O
devices) and software (including databases and operating system) that is needed to
support the intended EFB application(s).
3.7 EFB system supplier
The company that is responsible for developing, or for having developed the EFB system
or part of it. The EFB system supplier is not necessarily a host platform or aircraft
manufacturer.
3.8 Mounting device
A mounting device is an aircraft certified part that secures portable or installed EFB, or
EFB system components.

AMC 20-25A
3.9 Portable Electronic Device (PED)

PEDs are any kind of electronic device, typically, but not limited to, consumer electronics
that is brought on board the aircraft by crew members, passengers, or as part of the
cargo, and that is not included in the configuration of the certified aircraft. It includes all
equipment that is able to consume electrical energy. The electrical energy can be
provided from internal sources such as batteries (chargeable or non-rechargeable), or the
devices may also be connected to specific aircraft power sources.
3.10 Software application developer
The company responsible for developing, or for having developed a particular software
application.
3.11 Transmitting PED (T-PED)
PEDs that have intended radio frequency (RF) transmission capabilities.
4 SYSTEM DESCRIPTION AND CLASSIFICATION OF EFB SYSTEMS
EFB hardware are classified in two categories: portable and installed.
4.1 Portable EFB
A portable EFB is a portable EFB host platform, that is used on the flight deck, and that is
not part of the certified aircraft configuration.
Except for installed components, portable EFBs are outside the scope of this document.
Any EFB component that is either not accessible in the flight crew compartment by the
flight crew members or not removable by the flight crew, should be installed as ‘certified
equipment’ covered by a type certificate (TC), changed TC or supplemental (S)TC.
4.2 Installed EFB
Definition
Installed EFB, means an EFB host platform that is installed in the aircraft and is considered
as an aircraft part, covered, thus, by the aircraft airworthiness approval.
Complementary characteristics
An installed EFB is managed under the aircraft type design configuration.
In addition to hosting EFB applications (refer to point CAT.GEN.MPA.141 for the
definitions and characteristics of EFB applications), an installed EFB may host certified
applications, provided that the EFB meets the applicable certification specifications for
hosting such applications, including assurance that the non-certified software
applications do not adversely affect the certified application(s). For example, a robust
partitioning mechanism is one possible means to ensure the independence between
certified applications and the other types of applications.
Airworthiness approval is necessary for installed EFB systems, as well as for EFB installed
resources.

AMC 20-25A
5.1 Hardware airworthiness approval

5.1.1 Installed resources
Installed resources are the input/output components external to the EFB host
platform itself, such as an installed remote display, a control device (e.g. a
keyboard, pointing device, switches, etc.), or a docking station.
The installed resources should be dedicated to EFB functions only, or in the case of
use of resources shared with avionics, this possibility shall be part of the approved
type design. It should be demonstrated, using the appropriate level of assessment,
that the integration in the aircraft of the EFB and the EFB software applications
does not jeopardise the compliance of the aircraft installed systems and
equipment (including the shared resources) with the applicable certification
specifications such as CS 25.1302 or 25.1309.
Installed resources require an airworthiness approval.
5.1.1.1 Mounting device
The mounting device (or other securing mechanism) attaches or allows the
mounting of the EFB system. The EFB system may include more than one
mounting device if it consists of separate items (e.g. one docking station for
the EFB host platform and one cradle for the remote display).
The mounting device should not be positioned in such a way that it creates
a significant obstruction to the flight crew’s view or hinders physical access
to aircraft controls and/or displays, flight crew ingress or egress, or external
vision. The design of the mounting device should allow the user easy access
to any item of the EFB system, even if stowed, and notably to the EFB
controls and a clear view of the EFB display while in use. The following design
practices should be considered:
(a) The mounting device and associated mechanisms should not impede
the flight crew in the performance of any task (whether normal,
abnormal, or emergency) that are associated with operating any
aircraft system.
(b) When the mounting device is used to secure an EFB display (e.g.
portable EFB, installed EFB side display), the mount should be able to
be locked in position easily. If necessary, the selection of positions
should be adjustable enough to accommodate a range of flight crew
member preferences. In addition, the range of available movement
should accommodate the expected range of users’ physical abilities
(i.e. anthropometrics constraints). Locking mechanisms should be of a
low-wear type that will minimise slippage after extended periods of
normal use.
(c) Crashworthiness considerations should be taken into account in the
design of this device. This includes the appropriate restraint of any
device when in use.
(d) When the mounting device is used to secure an EFB display (e.g. a
portable EFB, an installed EFB side display), provision should be made
to secure or lock the mounting device in a position out of the way of
flight crew operations when it is not in use. When stowed, the device

AMC 20-25A
and its securing mechanism should not intrude into the flight crew
compartment space to the extent that they cause either visual or
physical obstruction of flight controls/displays and/or egress routes.
(e) Mechanical interference issues of the mounting device, either on the
side panel (side stick controller) or on the control yoke, in terms of full
and free movement under all operating conditions and non-
interference with buckles, etc. For yoke mounted devices,
(supplemental)-type-certificate-holder data should be obtained to
show that the mass inertia effect on column force has no adverse
effect on the aircraft handling qualities.
(f) Adequate means should be provided (e.g. hardware or software) to
shut down the portable EFB when its controls are not accessible by
the flight crew when strapped in the normal seated position. This
objective can be achieved through a dedicated installed resource
certified according to 5.1.1 (e.g. a button accessible from the flight
crew seated position).
5.1.1.2 Characteristics and placement of the EFB display
(a) Placement of the display
The EFB display and any other element of the EFB system should be
placed in such a way that they do not unduly impair the flight crew’s
external view during any phase of the flight. Equally, they should not
impair the view of or access to any flight-crew-compartment control
or instrument.
The location of the display unit and the other EFB system elements
should be assessed for their impact on egress requirements.
When the EFB is in use (intended to be viewed or controlled), its
display should be within 90 degrees on either side of each flight crew
member’s line of sight.
Glare and reflection on the EFB display should not interfere with the
normal duties of the flight crew or unduly impair the legibility of the
EFB data.
The EFB data should be legible under the full range of lighting
conditions expected in a flight crew compartment, including direct
sunlight.
In addition, consideration should be given to the potential for
confusion that could result from the presentation of relative
directions when the EFB is positioned in an orientation that is
inconsistent with that information. For example, it may be misleading
if the aircraft heading indicator points to the top of the display and
the display is not aligned with the aircraft longitudinal axis. This does
not apply to charts that are presented in a static way (e.g. with no HMI
mechanisation such as automatic repositioning), and that can be
considered to be similar to paper charts.
(b) Display characteristics

AMC 20-25A
Consideration should be given to the long-term degradation of a

display as a result of abrasion and ageing. AMC 25-11 (paragraph
3.16a) can be used as appropriate guidance material to assess
luminance and legibility aspects.
Users should be able to adjust the screen brightness of an EFB
independently of the brightness of other displays in the flight crew
compartment. In addition, when incorporating an automatic
brightness adjustment, it should operate independently for each EFB
in the flight crew compartment. Brightness adjustment using software
means may be acceptable providing that this operation does not
affect adversely the crew workload.
Buttons and labels should have adequate illumination for night use.
‘Buttons and labels’ refers to hardware controls located on the display
itself.
The 90-degree viewing angle on either side of each flight crew
member’s line of sight may be unacceptable for certain EFB
applications if aspects of the display quality are degraded at large
viewing angles (e.g. the display colours wash out or the displayed
colour contrast is not discernible at the installation viewing angle).
(c) Applicable specifications
In addition to the specifications of this section, each EFB system
should be evaluated against CS 23.1321, CS 25.1321, CS 27.1321, or
CS 29.1321, as applicable.
If the display is an installed resource, it should be assessed against
CS 25.1302 or in accordance with the applicable certification basis.
5.1.1.3 EFB data connectivity
Portable EFBs that have data connectivity to aircraft systems, either wired
or wireless, may receive or transmit data to and from aircraft systems,
provided the connection (hardware and software for data connection
provisions) and adequate interface protection devices are incorporated into
the aircraft type design.
Connectivity provisions for a portable EFB may allow the EFB to receive any
data from aircraft systems, but data transmission from EFBs to aircraft
systems is limited to:
(a) systems whose failures have no safety effect or a minor safety effect
at the aircraft level (e.g. printers);
(b) aircraft systems that have been certified with the purpose of providing
connectivity to non-certified devices such as PEDs or EFBs in
accordance with the limitations established in the AFM; and
(c) EFB system installed resources according to Section 5.1.1.
EFB data connectivity should be validated and verified to ensure non-
interference with and isolation from certified aircraft systems during
data transmission and reception.

AMC 20-25A
The safety assessment of the EFB data connectivity installation should

include an analysis of vulnerabilities to new threats that may be
introduced by the connection of the EFB to the aircraft systems
(malware and unauthorised access) and their effect on safety. This
assessment should be independent and should not take any credit
from the operational assessment of EFB system security, which is
intended to protect EFB systems themselves.
For aircraft systems certified for the purpose of receiving data from
PEDs or EFBs (case (b) above), their connectivity with PEDs/EFBs
should be taken into account in their demonstration of compliance
with requirements such as CS 25.1302 and 25.1309. The applicant
should in particular, conduct a safety assessment demonstrating that
the failure conditions associated with the reception of erroneous
PED/EFB data have criticalities that are not higher than minor.
Adequate design measures such as preliminary flight crew review and
acceptance of the imported parameters that mitigate the risk for using
erroneous data should be implemented if needed.
Any consequent airworthiness limitations should be included in the
AFM (please refer to 5.2.1).
5.1.1.4 Connecting cables
When cabling is installed to mate aircraft systems with an EFB,
(a) if the cable is not run inside the mount, the cable should not hang
loosely in such a way that compromises task performance and safety.
Flight crew should be able to easily secure the cables out of the way
during operations (e.g., by using cable tether straps);
(b) cables that are external to the mounting device should be of sufficient
length so that they do not obstruct the use of any movable device on
the flight crew compartment; and
(c) installed cables are considered electrical wiring interconnection
systems and, therefore, need to comply with CS-25 Subpart H (FAA
Part-25, Transport Category Airplanes) or TGM/21/07 (FAA Part-29,
Transport Category Rotorcraft).
5.1.2 Installed EFB
An installed EFB is considered to be a part of the aircraft, and, therefore, requires
a full airworthiness approval. This host platform includes the operating system
(OS).
The assessment of compliance with the airworthiness requirements would
typically include two specific areas:
(a) the safety assessment addressing failure conditions of the EFB system
hardware of any certified application installed on the EFB, and the partition
provided for uncertified applications and miscellaneous software
applications; and
(b) hardware and operating system software qualification conducted in
accordance with the necessary development assurance level (DAL) for the
system and its interfaces.

AMC 20-25A
5.2 Certification documentation

5.2.1 Aircraft flight manual
For installed EFBs and certified installed resources, the AFM section or an aircraft
flight manual supplement (AFMS) should contain:
(a) a statement of the limited scope of the airworthiness approval of EFB
provisions (e.g. these EFB provisions are only intended for EFB applications.
The airworthiness approval does not replace the operational assessment for
the use of the EFB system).
(b) the identification of the installed equipment, which may include a very brief
description of the installed system or resources; and
(c) appropriate amendments or supplements to cover any limitations
concerning:
(1) the use of the EFB host platform for the installed EFB system; and
(2) the use of the installed EFB provisions/resources for the portable EFB
system.
For this purpose, the AFM(S) should refer to any guidelines (relevant
to the airworthiness approval), intended primarily for EFB software
application developers or EFB system suppliers.
5.2.2 Guidelines for EFB software application developers (installed EFB and certified
installed resources)
TC/STC holders for EFB installed resources or installed EFBs should compile and
maintain guidelines to provide a set of limitations, considerations, and guidance to
design, develop, and integrate software applications into the installed EFB or with
certified resources for portable EFB. The guidelines should address, at least, the
following:
(a) a description of the architecture of the EFB installed components;
(b) the development assurance level (DAL) of the EFB component and any
assumptions, limitations, or risk mitigation means that are necessary to
support this;
(c) information necessary to ensure the development of a software application
that is consistent with the avionics interface and the human machine
interface that is also accurate, reliable, secure, testable, and maintainable;
(d) integration procedures between any new software application and those
already approved; and
(e) guidelines on how to integrate any new software application into the
installed platform or installed resources.
The guideline document should be available at least to the aircraft operator, its
competent authority, and EASA.
5.2.3 Guidelines for EFB system suppliers (installed resources for portable EFBs)
TC/STC holders for installed resources of portable EFBs should provide a set of
requirements and guidelines to integrate the portable EFB into the installed
resources, and to design and develop EFB software applications.

AMC 20-25A
Guidelines that are intended primarily for use by the EFB system supplier should
address, at least, the following:
(a) A description of the EFB installed resources and associated limitations, if any.
For example, the:
(1) intended function, limitations of use, etc.;
(2) characteristics of the mounting devices, display units, control and
pointing devices, printer, etc.;
(3) maximum authorised characteristics (dimensions, weight, etc.) of the
portable parts of the EFB system that is supported by the mounting
devices;
(4) architectural description of the EFB provisions, including
normal/abnormal/manual/automatic reconfigurations; and
(5) normal/abnormal/emergency/maintenance procedures including the
allowed phases of the flight.
(b) Characteristics and limitations, including safety and security considerations
concerning:
(1) the power supply;
(2) the laptop battery; and
(3) data connectivity.
The guidelines should be available at least to the operator, its competent
authority, and EASA.
[Amdt 20/12]
[Amdt 20/16]

AMC 20-29
AMC 20-29
AMC 20-29 Composite Aircraft Structure

1. PURPOSE
This AMC provides an acceptable means, but not the only means, for airworthiness certification
of composite aircraft structures. Guidance information is also presented on the closely related
design, manufacturing and maintenance aspects. This AMC primarily addresses carbon and
glass fibre reinforced plastic structures, although many aspects of this document are also
applicable to other forms of structure, e.g. metal bonded structure, wooden structure, etc.
Note: When applying this guidance to other forms of structure, additional design considerations
may be necessary and other appropriate references should also be consulted.
2. OBJECTIVE
AMC 20-29 standardises recognised good design practices common to composite aircraft
structures in one document.
For rotorcraft, AMC 20-29 complements existing AMC to CS-27 and CS-29 (referring to FAA AC
27-1B MG8 and AC 29-2C MG8).
3. APPLICABILITY
This AMC provides Acceptable Means of Compliance with the provisions of CS-23, CS-25, CS-27
and CS-29. Many of the concepts included in this AMC may also be applicable in part or in full
to other CSs. However, when using this AMC as an Acceptable Means of Compliance for these
other CSs, appropriate engineering judgement should be exercised and early agreement with
the Agency sought.
This AMC applies to: applicants for a type-certificate, restricted type-certificate or supplemental
type-certificate; certificate/approval holders; parts manufacturers; material suppliers; and
maintenance and repair organisations.
Note: The technical content of this AMC is harmonised with FAA Advisory Circular AC 20-107B,
dated 8 September 2009.
4. RELATED REGULATIONS AND GUIDANCE
a. Applicable paragraphs are listed in Appendix 1.
b. Relevant guidance considered complementary to this AMC is provided in Appendix 1.
5. GENERAL
a. The procedures outlined in this AMC provide Acceptable Means of Compliance and
Guidance Material for composite structures, particularly those that are essential in
maintaining the overall flight safety of the aircraft (“critical structure” as defined in
Appendix 2). This AMC is published to aid in the evaluation of certification programmes
for composite applications and to reflect the current status of composite technology. It
is expected that this AMC will be modified periodically to reflect the continued evolution
of composite technology and the data collected from service experience and expanding
applications.
b. There are factors unique to the specific composite materials and processes used for a
given application. For example, the environmental sensitivity, anisotropic properties, and

AMC 20-29
heterogeneous nature of composites can make the determination of structural failure

loads, modes, and locations difficult. The reliability of such evaluation depends on
repeatable structural details created by scaled manufacturing or repair processes. The
extent of testing and/or analysis may differ for a structure depending upon the criticality
to flight safety, expected service usage, the material and processes selected, the design
margins, the failure criteria, the database and experience with similar structures, and on
other factors affecting a particular structure. It is expected that these factors will be
considered when interpreting this AMC for use on a specific application.
c. Definitions of terms used in this AMC can be found in Appendix 2.
6. MATERIAL AND FABRICATION DEVELOPMENT
All composite materials and processes used in structures are qualified through enough
fabrication trials and tests to demonstrate a reproducible and reliable design. One of the
important features of composite construction is the degree of care needed in the procurement
and processing of composite materials. The final mechanical behaviour of a given composite
material may vary greatly depending on the processing methods employed to fabricate
production parts. Special care needs to be taken in controlling both the materials being
procured and how the material is processed once delivered to the fabrication facility. The CSs
(namely paragraphs 2x.603 and 2x.605) specify the need to procure and process materials
under approved material and process specifications that control the key parameters governing
performance. These paragraphs outline a need to protect structures against the degradation
possible in service. They also require that the design account for any changes in performance
(e.g., environmental and variability effects) permitted by material and process specifications.
a. Material and Process Control
(1) Specifications covering material, material processing, and fabrication procedures
are established to ensure a basis for fabricating reproducible and reliable structure.
Material specifications are required to ensure consistent material can be procured,
and batch acceptance testing or statistical process controls are used to ensure
material properties do not drift over time. Specifications covering processing
procedures should be developed to ensure that repeatable and reliable structure
can be manufactured. The means of processing qualification and acceptance tests
defined in each material specification should be representative of the expected
applicable manufacturing process. The process parameters for fabricating test
specimens should match the process parameters to be used in manufacturing
actual production parts as closely as possible. Both test and production parts must
conform to material and process specifications.
(2) Once the fabrication processes have been established, changes should undergo
additional qualification, including testing of differences, before being
implemented, (refer to Appendix 3). It is important to establish processing
tolerances, material handling and storage limits, and key characteristics, which can
be measured and tracked to judge part quality.
(3) Material requirements identified in procurement specifications should be based on
the qualification test results for samples produced using the related process
specifications. Qualification data must cover all properties important to the control
of materials (composites and adhesives) and processes to be used for production
of composite structure. Carefully selected physical, chemical, and mechanical
qualification tests are used to demonstrate the formulation, stiffness, strength,
durability, and reliability of materials and processes for aircraft applications. It is

AMC 20-29
recommended that airframe designers and manufacturers work closely with

material suppliers to properly define material requirements.
(4) To provide an adequate design database, environmental effects on critical
properties of the material systems and associated processes should be established.
In addition to testing in an ambient environment, variables should include extreme
service temperature and moisture content conditions and effects of long-term
durability. Qualification tests for environmental effects and long-term durability
are particularly important when evaluating the materials, processes, and interface
issues associated with structural bonding (refer to paragraph 6.c for related
guidance).
(5) Key characteristics and processing parameters should be specified and monitored
for in-process quality control. The overall quality control plan required by the
certifying agency should involve all relevant disciplines, i.e., engineering,
manufacturing, and quality control. A reliable quality control system should be in
place to address special engineering requirements that arise in individual parts or
areas as a result of potential failure modes, damage tolerance and flaw growth
requirements, loadings, inspectability, and local sensitivities to manufacture and
assembly.
(6) Tolerances permitted by the material and process specifications should be
substantiated by analysis supported by test evidence, or tests at the coupon,
element or sub-component level. For new production methods, repeatable
processes should be demonstrated at sufficient structural scale in a way shown to
be consistent with the material and process qualification tests and development of
the associated specifications. This will require integration of the technical issues
associated with product design and manufacturing details prior to a large
investment in structural tests and analysis correlation. It will also ensure the
relevance of quality control procedures defined to control materials and processes
as related to the product structural details.
(7) Note that the Agency does not certify materials and processes. However, materials
and processes specifications are part of the type-design subject to type-
certification. Appropriate certification credit may be given to products and
organisations using the same materials and processes in similar applications
subject to substantiation and applicability. In some cases, material and processing
information may become part of accepted shared databases used throughout the
industry. New users of shared qualification databases must control the associated
materials and processes through proper use of the related specifications and
demonstrate their understanding by performing equivalency sampling tests for key
properties. Note that materials and processes used in European Technical Standard
Order (ETSO) articles or authorisations must also be qualified and controlled.
b. Design Considerations for Manufacturing Implementation
(1) Process specifications and manufacturing documentation are needed to control
composite fabrication and assembly. The environment and cleanliness of facilities
are controlled to a level validated by qualification and proof of structure testing.
Raw and ancillary materials are controlled to specification requirements that are
consistent with material and process qualifications. Parts fabricated should meet
design drawing tolerances obtained from the production tolerances validated in
qualification, design data development, and proof of structure tests. Some key

AMC 20-29
fabrication process considerations requiring such control include: (i) material

handling and storage, (ii) laminate layup and bagging (or other alternate process
steps for non-laminated material forms and advanced processes), (iii) mating part
dimensional tolerance control, (iv) part cure (thermal management), (v) machining
and assembly, (vi) cured part inspection and handling procedures, and (vii)
technician training for specific material, processes, tooling and equipment.
(2) Substantiating data is needed for design to justify all known defects, damage and
anomalies allowed to remain in service without rework or repair. Adequate
manufacturing records support the identification and substantiation of known
defects, damage and anomalies.
(3) Additional substantiating design data is needed from new suppliers of parts
previously certificated. This may be supported by manufacturing trials and quality
assessments to ensure equivalent production and repeatability. Some destructive
inspection of critical structural details is needed for manufacturing flaws that are
not end item inspectable and require process controls to ensure reliable
fabrication.
c. Structural Bonding
Bonded structures include multiple interfaces (e.g., composite-to-composite, composite-
to-metal, or metal-to-metal), where at least one of the interfaces requires additional
surface preparation prior to bonding. The general nature of technical parameters that
govern different types of bonded structures are similar. A qualified bonding process is
documented after demonstrating repeatable and reliable processing steps such as
surface preparation. It entails understanding the sensitivity of structural performance
based upon expected variation permitted per the process. Characterisation outside the
process limits is recommended to ensure process robustness. In the case of bonding
composite interfaces, a qualified surface preparation of all previously cured substrates is
needed to activate their surface for chemical adhesion. For all bonding interfaces,
regardless if on metallic or previously cured composite substrates, a qualified surface
preparation is needed to activate their surface for chemical adhesion. Many technical
issues for bonding require cross-functional teams for successful applications. Applications
require stringent process control and a thorough substantiation of structural integrity.
(1) Many bond failures and problems in service have been traced to invalid
qualifications or insufficient quality control of production processes. Physical and
chemical tests may be used to control surface preparation, adhesive mixing,
viscosity, and cure properties (e.g., density, degree of cure, glass transition
temperature). Lap shear stiffness and strength are common mechanical tests for
adhesive and bond process qualification. Shear tests do not provide a reliable
measure of long-term durability and environmental degradation associated with
poor bonding processes (i.e., lack of adhesion). Some type of peel test has proven
more reliable for evaluating proper adhesion. Without chemical bonding, the so-
called condition of a “weak bond” exists when the bonded joint is either loaded by
peel forces or exposed to the environment over a long period of time, or both.
Adhesion failures, which indicate the lack of chemical bonding between substrate
and adhesive materials, are considered an unacceptable failure mode in all test
types. Material or bond process problems that lead to adhesion failures are solved
before proceeding with qualification tests.

AMC 20-29
(2) Process specifications are needed to control adhesive bonding in manufacturing

and repair. A “process control mentality”, which includes a combination of in-
process inspections and tests, has proven to be the most reliable means of ensuring
the quality of adhesive bonds. The environment and cleanliness of facilities used
for bonding processes are controlled to a level validated by qualification and proof
of structure testing. Adhesives and substrate materials are controlled to
specification requirements that are consistent with material and bond process
qualifications. The bonding processes used for production and repair meet
tolerances validated in qualification, design data development, and proof of
structure tests. Some key bond fabrication process considerations requiring such
control include: (i) material handling and storage, (ii) bond surface preparation, (iii)
mating part dimensional tolerance control, (iv) adhesive application and clamp-up
pressure, (v) bond line thickness control, (vi) bonded part cure (thermal
management), (vii) cured part inspection and handling procedures, and (vii) bond
technician training for specific material, processes, tooling and equipment. Bond
surface preparation and subsequent handling controls leading up to the bond
assembly and cure must be closely controlled in time and exposure to environment
and contamination.
(3) CS 23.573(a) sets the certification specification for primary composite airframe
structures, including considerations for damage tolerance, fatigue, and bonded
joints. Although this is a small aeroplane rule, the same performance standards are
normally expected for large aeroplanes and rotorcraft (via special conditions and
CRIs).
(a) For bonded joints, CS 23.573(a)(5) states:
"For any bonded joint, the failure of which would result in catastrophic loss
of the aeroplane, the limit load capacity must be substantiated by one of the
following methods:
(i) The maximum disbonds of each bonded joint consistent with the
capability to withstand the loads in paragraph (a)(3) of this section
must be determined by analysis, tests, or both. Disbonds of each
bonded joint greater than this must be prevented by design features;
or
(ii) Proof testing must be conducted on each production article that will
apply the critical limit design load to each critical bonded joint; or
(iii) Repeatable and reliable non-destructive inspection techniques must
be established that ensure the strength of each joint."
(b) These options do not supersede the need for a qualified bonding process
and rigorous quality controls for bonded structures. For example, fail safety
implied by the first option is not intended to provide adequate safety for the
systematic problem of a bad bonding process applied to a fleet of aircraft
structures. Instead, it gives fail safety against bonding problems that may
occasionally occur over local areas (e.g., insufficient local bond contact
pressure or contamination). Performing static proof tests to limit load, which
is the second option, may not detect weak bonds requiring environmental
exposure and time to degrade bonded joint strength. This issue should be
covered by adequately demonstrating that qualified bonding materials and
processes have long-term environmental durability. Finally, the third option

AMC 20-29
is open for future advancement and validation of non-destructive inspection

(NDI) technology to detect weak bonds, which degrade over time and lead
to adhesion failures. Such technology has not been reliably demonstrated at
a production scale to date.
(4) Adhesion failures are an unacceptable failure mode for bonded structure that
require immediate action by the responsible engineers to identify the specific
cause and isolate all affected parts and assemblies for directed inspection and
repair. Depending on the suspected severity of the bonding problem, an
airworthiness directive may be required to restore the affected aircraft to an
airworthy condition. Any design, manufacturing or repair details linked to the
bonding problem should also be permanently corrected.
d. Environmental Considerations
Environmental design criteria should be developed that identify the critical
environmental exposures, including humidity and temperature, to which the material in
the application under evaluation may be exposed. Service data (e.g., moisture content as
a function of time in service) can be used to ensure such criteria are realistic. In addition,
the peak temperatures for composite structure installed in close proximity to aircraft
systems that generate thermal energy need to be identified for worst-case normal
operation and system failure cases. Environmental design criteria are not required where
existing data demonstrate that no significant environmental effects, including the effects
of temperature and moisture, exist for the material system and construction details,
within the bounds of environmental exposure being considered.
(1) Experimental evidence should be provided to demonstrate that the material
design values or allowables are attained with a high degree of confidence in the
appropriate critical environmental exposures to be expected in service. It should
be realised that the worst case environment may not be the same for all structural
details (e.g., hot wet conditions can be critical for some failure modes, while cold
dry conditions may be worse for others). The effect of the service environment on
static strength, fatigue and stiffness properties and design values should be
determined for the material system through tests, e.g., accelerated environmental
tests, or from applicable service data. The maximum moisture content considered
is related to that possible during the service life, which may be a function of a given
part thickness, moisture diffusion properties and realistic environmental
exposures. The effects of environmental cycling (i.e., moisture and temperature)
should be evaluated when the application involves fluctuations or unique design
details not covered in the past. Existing test data may be used where it can be
shown to be directly applicable to the material system, design details, and
environmental cycling conditions characteristic of the application. All accelerated
test methods should be representative of real-time environmental and load
exposure. Any factors used for acceleration that chemically alter the material (e.g.,
high temperatures that cause post-cure) should be avoided to ensure behaviour
representative of real environmental exposures.
(2) Depending on the design configuration, local structural details, and selected
processes, the effects of residual stresses that depend on environment should be
addressed (e.g., differential thermal expansion of attached parts).

AMC 20-29
e. Protection of Structure
Weathering, abrasion, erosion, ultraviolet radiation, and chemical environment (glycol,
hydraulic fluid, fuel, cleaning agents, etc.) may cause deterioration in a composite
structure. Suitable protection against and/or consideration of degradation in material
properties should be provided for conditions expected in service and demonstrated by
test and/or appropriate validated experience. Where necessary, provide provisions for
ventilation and drainage. Isolation layers are needed at the interfaces between some
composite and metal materials to avoid corrosion (e.g., glass plies are used to isolate
carbon composite layers from aluminium). In addition, qualification of the special
fasteners and installation procedures used for parts made from composite materials need
to address the galvanic corrosion issues, as well as the potential for damaging the
composite (delamination and fibre breakage) in forming the fastener.
f. Design Values
Data used to derive design values must be obtained from stable and repeatable material
that conforms to mature material and representative production process specifications.
This will ensure that the permitted variability of the production materials is captured in
the statistical analysis used to derive the design values. Design values derived too early
in the material’s development stage, before raw material and composite part production
processes have matured, may not satisfy the intent of the associated rules. Laminated
material system design values should be established on the laminate level by either test
of the laminate or by test of the lamina in conjunction with a test validated analytical
method. Similarly, design values for non-laminated material forms and advanced
composite processes must be established at the scale that best represents the material
as it appears in the part or by tests of material substructure in conjunction with a test
validated analytical method.
g. Structural Details
For a specific structural configuration of an individual component (point design), design
values may be established which include the effects of appropriate design features (holes,
joints, etc.). Specific metrics that quantify the severity of composite structural damage
states caused by foreign impact damage threats are needed to perform analysis (i.e., the
equivalent of a metallic crack length). As a result, testing will often be needed to
characterise residual strength, including the structural effects of critical damage location
and combined loads. Different levels of impact damage are generally accommodated by
limiting the design strain levels for ultimate and limit combined load design criteria. In
this manner, rational analyses supported by tests can be established to characterise
residual strength for point design details.
7. PROOF OF STRUCTURE – STATIC
The structural static strength substantiation of a composite design should consider all critical
load cases and associated failure modes. It should also include effects of environment (including
residual stresses induced during the fabrication process), material and process variability, non-
detectable defects or any defects that are allowed by the quality control, manufacturing
acceptance criteria, and service damage allowed in maintenance documents of the end product.
The static strength of the composite design should be demonstrated through a programme of
component ultimate load tests in the appropriate environment, unless experience with similar
designs, material systems, and loadings is available to demonstrate the adequacy of the analysis
supported by sub-component, element and coupon tests, or component tests to accepted

AMC 20-29
lower load levels. The necessary experience to validate an analysis should include previous
component ultimate load tests with similar designs, material systems, and load cases.
a. The effects of repeated loading and environmental exposure which may result in material
property degradation should be addressed in the static strength evaluation. This can be
shown by analysis supported by test evidence, by tests at the coupon, element or sub-
component level, as appropriate, or alternatively by relevant existing data. Earlier
discussions in this AMC address the effects of environment on material properties
(paragraph 6.d) and protection of structure (paragraph 6.e). For critical loading
conditions, three approaches exist to account for prior repeated loading and/or
environmental exposure in the full-scale static test.
(1) In the first approach, the full-scale static test should be conducted on structure
with prior repeated loading and conditioned to simulate the critical environmental
exposure and then tested in that environment.
(2) The second approach relies upon coupon, element, and sub-component test data
to determine the effect of repeated loading and environmental exposure on static
strength. The degradation characterised by these tests should then be accounted
for in the full-scale static strength demonstration test (e.g., overload factors), or in
analysis of these results (e.g., showing a positive margin of safety with design
values that include the degrading effects of environment and repeated load).
(3) In practice, aspects of the first two approaches may be combined to obtain the
desired result (e.g., a full scale static test may be performed at critical operating
temperature with a load factor to account for moisture absorbed over the aircraft
structure’s life). Alternate means to account for environment using validated tests
and analyses (e.g., an equivalent temperature enhancement to account for the
effect of moisture without chemically altering the material), may be proposed by
the applicant.
b. The strength of the composite structure should be reliably established, incrementally,
through a programme of analysis and a series of tests conducted using specimens of
varying levels of complexity. Often referred to in industry as the “building block”
approach, these tests and analyses at the coupon, element, details, and sub-component
levels can be used to address the issues of variability, environment, structural
discontinuity (e.g., joints, cut-outs or other stress risers), damage, manufacturing defects,
and design or process-specific details. Typically, testing progresses from simple
specimens to more complex elements and details over time. This approach allows the
data collected for sufficient analysis correlation and the necessary replicates to quantify
variations occurring at the larger structural scales to be economically obtained. The
lessons learned from initial tests also help avoid early failures in more complex full-scale
tests, which are more costly to conduct and often occur later in a certification programme
schedule.
(1) Figures 1 and 2 provide a conceptual schematic of tests typically included in the
building block approach for a fixed wing and tail rotor blade structures,
respectively. The large quantity of tests needed to provide a statistical basis comes
from the lowest levels (coupons and elements) and the performance of structural
details are validated in a lesser number of sub-component and component tests.
Detail and subcomponent tests may be used to validate the ability of analysis
methods to predict local strains and failure modes. Additional statistical
considerations (e.g., repetitive point design testing and/or component overload

AMC 20-29
factors to cover material and process variability) will be needed when analysis
validation is not achieved. The static strength substantiation programme should
also consider all critical loading conditions for all Critical Structure. This includes an
assessment of residual strength and stiffness requirements after a predetermined
length of service, which takes into account damage and other degradation due to
the service period.
Figure 1 - Schematic diagram of building block tests for a fixed wing.
Figure 2 - Schematic diagram of building block tests for a tail rotor blade.

AMC 20-29
(2) Successful static strength substantiation of composite structures has traditionally

depended on proper consideration of stress concentrations (e.g., notch sensitivity
of details and impact damage), competing failure modes and out-of-plane loads. A
complete building block approach to composite structural substantiation
addresses most critical structural issues in test articles with increasing levels of
complexity so that many areas of reliable performance can be demonstrated prior
to the component tests. The details and sub-component testing should establish
failure criteria and account for impact damage in assembled composite structures.
Component tests are needed to provide the final validation accounting for
combined loads and complex load paths, which include some out-of-plane effects.
When using the building block approach, the critical load cases and associated
failure modes would be identified for component tests using the analytical
methods, which are supported by test validation.
c. The component static test may be performed in an ambient atmosphere if the effects of
the environment are reliably predicted by building block tests and are accounted for in
the static test or in the analysis of the results of the static test.
d. The static test articles should be fabricated and assembled in accordance with production
specifications and processes so that the test articles are representative of production
structure including defects consistent with the limits established by manufacturing
acceptance criteria.
e. The material and processing variability of the composite structure should be considered
in the static strength substantiation. This is primarily achieved by establishing sufficient
process and quality controls to manufacture structure and reliably substantiate the
required strength by test and analysis. The scatter in strength properties due to variability
in materials and processes are characterised by proper allowables or design values, which
are derived in compliance with CS 2x.613. When the detail, sub-component and
component tests show that local strains are adequately predicted and positive margins
of safety exist using a validated analysis everywhere on the structure, then proof of static
strength is said to be substantiated using analysis supported by test evidence.
Alternatively, in the absence of sufficient building block test data and analysis validation,
overloads are needed in the component test to gain proof of static strength for the
structure using an approach referred to as substantiated by tests. The overload factors
applied in this case need to be substantiated either through tests or past experience and
must account for the expected material and process variation.
f. It should be shown that impact damage that can be expected from manufacturing and
service, but not more than the established threshold of detectability for the selected
inspection procedure, will not reduce the structural strength below ultimate load
capability. This can be shown by analysis supported by test evidence, or by a combination
of tests at the coupon, element, sub-component and component levels. The realistic test
assessment of impact damage requires proper consideration of the structural details and
boundary conditions. When using a visual inspection procedure, the likely impact damage
at the threshold of reliable detection has been called barely visible impact damage (BVID).
Selection of impact sites for static strength substantiation should consider the criticality
of the local structural detail, and the ability to inspect a location. The size and shape of
impactors used for static strength substantiation should be consistent with likely impact
damage scenarios that may go undetected for the life of an aircraft. Note that it is
possible for some designs to have detectable impact damage and still meet static strength

AMC 20-29
loads and other requirements without repair (refer to allowable damage discussions in
paragraph 10.c(1)).
g. Major material and process changes on existing certified structure require additional
static strength substantiation (e.g., refer to Appendix 3).
8. PROOF OF STRUCTURE – FATIGUE AND DAMAGE TOLERANCE
The evaluation of composite structure should be based on the applicable certification
specifications identified in the type-certification basis. Such evaluation must show that
catastrophic failure due to fatigue, environmental effects, manufacturing defects, or accidental
damage will be avoided throughout the operational life of the aircraft. The nature and extent
of analysis or tests on complete structures and/or portions of the primary structure will depend
upon applicable previous fatigue/damage tolerant designs, construction, tests, and service
experience on similar structures. In the absence of experience with similar designs, Agency-
approved structural development tests of components, sub-components, and elements should
be performed (following the same principles discussed in paragraph 7.b and Appendix 3). The
following considerations are unique to the use of composite material systems and provide
guidance for the method of substantiation selected by the applicant. When establishing details
for the damage tolerance and fatigue evaluation, attention should be given to a thorough
damage threat assessment, geometry, inspectability, good design practice, and the types of
damage/degradation of the structure under consideration.
— Composite damage tolerance and fatigue performance is strongly dependent on
structural design details (e.g., skin laminate stacking sequence, stringer or frame spacing,
stiffening element attachment details, damage arrestment features, and structural
redundancy).
— Composite damage tolerance and fatigue evaluations require substantiation in
component tests unless experience with similar designs, material systems, and loadings
is available to demonstrate the adequacy of the analysis supported by coupons,
elements, and sub-component tests.
— Final static strength, fatigue, and damage tolerance substantiation may be gained in
testing a single component test article if sufficient building block test evidence exists to
ensure that the selected sequence of repeated and static loading yield results
representative of that possible in service or provide a conservative evaluation.
— Peak repeated loads are needed to practically demonstrate the fatigue and damage
tolerance of composite aircraft structure in a limited number of component tests. As a
result, metal structures present in the test article generally require additional
consideration and testing. The information contained in AMC 25.571 provides fatigue and
damage tolerance guidance for metallic structures.
a. Damage Tolerance Evaluation
(1) Damage tolerance evaluation starts with identification of structure whose failure
would reduce the structural integrity of the aircraft. A damage threat assessment
must be performed for the structure to determine possible locations, types, and
sizes of damage considering fatigue, environmental effects, intrinsic flaws, and
foreign object impact or other accidental damage (including discrete source) that
may occur during manufacture, operation or maintenance.
(a) Currently, there are very few industry standards that outline the critical
damage threats for particular composite structural applications with enough
detail to establish the necessary design criteria or test and analysis protocol

AMC 20-29
for complete damage tolerance evaluation. In the absence of standards, it is

the responsibility of individual applicants to perform the necessary
development tasks to establish such data in support of product
substantiation. Some factors to consider in development of a damage threat
assessment for a particular composite structure include part function,
location on the aircraft, past service data, accidental damage threats,
environmental exposure, impact damage resistance, durability of assembled
structural details (e.g., long-term durability of bolted and bonded joints),
adjacent system interface (e.g., potential overheating or other threats
associated with system failure), and anomalous service or maintenance
handling events that can overload or damage the part. As related to the
damage threat assessment and maintenance procedures for a given
structure, the damage tolerance capability and ability to inspect for known
damage threats should be developed.
(b) Foreign object impact is a concern for most composite structures, requiring
attention in the damage threat assessment. This is needed to identify impact
damage severity and detectability for design and maintenance. It should
include any available damage data collected from service plus an impact
survey. An impact survey consists of impact tests performed with
representative structure, which is subjected to boundary conditions
characteristic of the real structure. Many different impact scenarios and
locations should be considered in the survey, which has a goal of identifying
the most critical impacts possible (i.e., those causing the most serious
damage but are least detectable). When simulating accidental impact
damage at representative energy levels, blunt or sharp impactors of
different sizes and shapes should be selected to cause the most critical and
least detectable damage, according to the load conditions (e.g., tension,
compression or shear). Until sufficient service experience exists to make
good engineering judgments on energy and impactor variables, impact
surveys should consider a wide range of conceivable impacts, including
runway or ground debris, hail, tool drops, and vehicle collisions. This
consideration is important to the assumptions needed for use of
probabilistic damage threat assessments in defining design criteria,
inspection methods, and repeat inspection intervals for maintenance.
Service data collected over time can better define impact surveys and design
criteria for subsequent products, as well as establish more rational
inspection intervals and maintenance practice. In review of such
information, it should be realised that the most severe and critical impact
damages, which are still possible, may not be part of the service database.
(c) Once a damage threat assessment is completed, various damage types can
be classified into five categories of damage as described below (refer to
figure 3). These categories of damage are used for communication purposes
in this AMC. Other categories of damage, which help outline a specific path
to fatigue and damage tolerance substantiation, may be used by applicants
in agreement with the regulatory authorities.

AMC 20-29
Figure 3 - Schematic diagram showing design load levels versus categories of damage severity.
Category 1: Allowable damage that may go undetected by scheduled or

directed field inspection and allowable manufacturing defects. Structural
substantiation for Category 1 damage includes demonstration of a reliable
service life, while retaining ultimate load capability. By definition, such
damage is subjected to the requirements and guidance associated with
paragraph 7 of this AMC. Some examples of Category 1 damage include BVID
and allowable defects caused in manufacturing or service (e.g., small
delamination, porosity, small scratches, gouges, and minor environmental
damage) that have substantiation data showing ultimate load is retained for
the life of an aircraft structure.
Category 2: Damage that can be reliably detected by scheduled or directed
field inspections performed at specified intervals. Structural substantiation
for Category 2 damage includes demonstration of a reliable inspection
method and interval while retaining loads above limit load capability. The
residual strength for a given Category 2 damage may depend on the chosen
inspection interval and method of inspection. Some examples of Category 2
damage include visible impact damage (VID), VID (ranging in size from small
to large), deep gouges or scratches, manufacturing mistakes not evident in
the factory, detectable delamination or debonding, and major local heat or
environmental degradation that will sustain sufficient residual strength until
found. This type of damage should not grow or, if slow or arrested growth

AMC 20-29
occurs, the level of residual strength retained for the inspection interval is
sufficiently above limit load capability.
Category 3: Damage that can be reliably detected within a few flights of
occurrence by operations or ramp maintenance personnel without special
skills in composite inspection. Such damage must be in a location such that
it is obvious by clearly visible evidence or cause other indications of potential
damage that becomes obvious in a short time interval because of loss of the
part form, fit or function. Both indications of significant damage warrant an
expanded inspection to identify the full extent of damage to the part and
surrounding structural areas. In practice, structural design features may be
needed to provide sufficient large damage capability to ensure limit or near
limit load is maintained with easily detectable, Category 3 damage.
Structural substantiation for Category 3 damage includes demonstration of
a reliable and quick detection, while retaining limit or near limit load
capability. The primary difference between Category 2 and 3 damages are
the demonstration of large damage capability at limit or near limit load for
the latter after a regular interval of time, which is much shorter than the
former. The residual strength demonstration for Category 3 damage may be
dependent on the reliable short time detection interval. Some examples of
Category 3 damage include large VID or other obvious damage that will be
caught during walk-around inspection or during the normal course of
operations (e.g., fuel leaks, system malfunctions or cabin noise).
Category 4: Discrete source damage from a known incident such as flight
manoeuvres is limited. Structural substantiation for Category 4 damage
includes a demonstration of residual strength for loads specified in the
regulations. It should be noted that pressurised structure will generally have
Category 4 residual strength requirements at a level higher than shown in
figure 3. Some examples of Category 4 damage include rotor burst, bird
strikes (as specified in the regulations), tyre bursts, and severe in-flight hail.
Category 5: Severe damage created by anomalous ground or flight events,
which is not covered by design criteria or structural substantiation
procedures. This damage is in the current guidance to ensure the engineers
responsible for composite aircraft structure design and the Agency work
with maintenance organisations in making operations personnel aware of
possible damage from Category 5 events and the essential need for
immediate reporting to responsible maintenance personnel. It is also the
responsibility of structural engineers to design-in sufficient damage
resistance such that Category 5 events are self-evident to the operations
personnel involved. An interface is needed with engineering to properly
define a suitable conditional inspection based on available information from
the anomalous event. Such action will facilitate the damage characterisation
needed prior to repair. Some examples of Category 5 damage include severe
service vehicle collisions with aircraft, anomalous flight overload conditions,
abnormally hard landings, maintenance jacking errors, and loss of aircraft
parts in flight, including possible subsequent high-energy, wide-area (blunt)
impact with adjacent structure. Some Category 5 damage scenarios will not
have clearly visual indications of damage, particularly in composite
structures. However, there should be knowledge of other evidence from the

AMC 20-29
related events that ensure safety is protected, starting with a complete

report of possible damage by operations.
(d) The five categories of damage will be used as examples in subsequent
discussion in this paragraph and in paragraphs 9 and 10. Note that Category
2, 3, 4 and 5 damages all have associated repair scenarios.
(2) Structure details, elements, and sub-components of Critical Structure should be
tested under repeated loads to define the sensitivity of the structure to damage
growth. This testing can form the basis for validating a no-growth approach to the
damage tolerance requirements. The testing should assess the effect of the
environment on the flaw and damage growth characteristics and the no-growth
validation. The environment used should be appropriate to the expected service
usage. Residual stresses will develop at the interfaces between composite and
metal structural elements in a design due to differences in thermal expansion. This
component of stress will depend on the service temperature during repeated load
cycling and is considered in the damage tolerance evaluation. Inspection intervals
should be established, considering both the likelihood of a particular damage and
the residual strength capability associated with this damage. The intent of this is
to assure that structure is not exposed to an excessive period of time with residual
strength less than ultimate, providing a lower safety level than in the typical slow
growth situation, as illustrated in Figure 4. Conservative assumptions for capability
with large damage sizes that would be detected within a few flights may be needed
when probabilistic data on the likelihood of given damage sizes does not exist.
Once the damage is detected, the component is either repaired to restore ultimate
load capability or replaced.
Figure 4 - Schematic diagram of residual strength illustrating that significant accidental damage with “no-growth” should
not be left in the structure without repair for a long time.
(a) The traditional slow growth approach may be appropriate for certain
damage types found in composites if the growth rate can be shown to be
slow, stable and predictable. Slow growth characterisation should yield
conservative and reliable results. As part of the slow growth approach, an
inspection programme should be developed consisting of the frequency,

AMC 20-29
extent, and methods of inspection for inclusion in the maintenance plan.

Inspection intervals should be established such that the damage will have a
very high probability of detection between the time it becomes initially
detectable and the time at which the extent of the damage reduces the
residual static strength to limit load (considered as ultimate), including the
effects of environment. For any detected damage size that reduces the load
capability below ultimate, the component is either repaired to restore
ultimate load capability or replaced. Should functional impairment (such as
unacceptable loss of stiffness) occur before the damage becomes otherwise
critical, part repair or replacement will also be necessary.
(b) Another approach involving growth may be appropriate for certain damage
types and design features adopted for composites if the growth can be
reliably shown to be predictable and arrested before it becomes critical.
Figure 5 shows schematic diagrams for all three damage growth approaches
applied to composite structure. The arrested growth method is applicable
when the damage growth is mechanically arrested or terminated before
becoming critical (residual static strength reduced to limit load), as
illustrated in Figure 5. Arrested growth may occur due to design features
such as a geometry change, reinforcement, thickness change, or a structural
joint. This approach is appropriate for damage growth that is detectable and
found to be reliably arrested, including all appropriate dynamic effects.
Structural details, elements, and sub-components of Critical Structure,
components or full-scale structures, should be tested under repeated loads
for validating an Arrested Growth Approach. As was the case for a “no-
growth” approach to damage tolerance, inspection intervals should be
established, considering the residual strength capability associated with the
arrested growth damage size (refer to the dashed lines added to Figure 5 to
conceptually show inspection intervals consistent with the slow growth
basis). Again, this is intended to ensure that the structure does not remain
in a damaged condition with residual strength capability close to limit load
for long periods of time before repair. For any damage size that reduces load
capability below ultimate, the component is either repaired to restore
ultimate load capability or replaced.
(c) The repeated loading should be representative of anticipated service usage.
The repeated load testing should include damage levels (including impact
damage) typical of those that may occur during fabrication, assembly, and
in-service, consistent with the inspection techniques employed. The damage
tolerance test articles should be fabricated and assembled in accordance
with production specifications and processes so that the test articles are
representative of production structure.
(3) The extent of initially detectable damage should be established and be consistent
with the inspection techniques employed during manufacture and in service. This
information will naturally establish the transition between Category 1 and 2
damage types (i.e., inspection methods used by trained inspectors in scheduled
maintenance). For damage that is clearly detectable to an extent that it will likely
be found before scheduled maintenance (i.e., allowing classification as Category 3
damage), detection over shorter intervals and by untrained personnel may be
permitted. Flaw/damage growth data should be obtained by repeated load cycling
of intrinsic flaws or mechanically introduced damage. The number of cycles applied

AMC 20-29
to validate both growth and no-growth concepts should be statistically significant,

and may be determined by load and/or life considerations and a function of
damage size. The growth or no growth evaluation should be performed by analysis
supported by test evidence or by tests at the coupon, element, or sub-component
level.
Figure 5 - Illustrations of residual strength and damage size relationships for three different approaches to composite
structural damage tolerance substantiation
(4) The extent of damage for residual strength assessments should be established,
including considerations for the probability of detection using selected field
inspection procedures. The first four categories of damage should be considered
based on the damage threat assessment. In addition, Category 3 damage should
be detected in a walk-around inspection or through the normal course of
operations. Residual strength evaluation by component or sub-component testing
or by analysis supported by test evidence should be performed considering that
damage. The evaluation should demonstrate that the residual strength of the
structure will reliably be equal to or greater than the strength required for the
specified design loads (considered as ultimate), including environmental effects.
The statistical significance of reliable sub-component and detail residual strength
assessments may include conservative methods and engineering judgment. It
should be shown that stiffness properties have not changed beyond acceptable
levels.
(a) For the no-growth, slow growth, arrested growth approaches, residual
strength testing should be performed after repeated load cycling. All
probabilistic analyses applied for residual strength assessments should
properly account for the complex nature of damage defined from a thorough
damage threat assessment. Conservative damage metrics are permitted in

AMC 20-29
such analyses assuming sufficient test data on repeated load and

environmental exposure exists.
(b) Composite designs should afford the same level of fail-safe, multiple load
path structure assurance as conventional metals design. Such is also the
expectation in justifying the use of static strength allowables with a
statistical basis of 90 percent probability with 95 percent confidence.
(c) Some special residual strength considerations for bonded structure are
given in paragraph 6.c.(3).
(5) The repeated load spectrum developed for fatigue testing and analysis purposes
should be representative of the anticipated service usage. Low amplitude load
levels that can be shown not to contribute to damage growth may be omitted.
Reducing maximum load levels is generally not accepted. Variability in repeated
load behaviour should be covered by appropriate load enhancement or life scatter
factors and these factors should take into account the number of specimens
tested. The use of such factors to demonstrate reliability in component tests
should be consistent with the fatigue and damage tolerance behaviour
characterised for the materials, processes and other design details of the structure
in building block tests.
(6) An inspection programme should be developed consisting of frequency, extent,
and methods of inspection for inclusion in the maintenance plan. Inspection
intervals should be established such that the damage will be reliably detected
between the time it initially becomes detectable and the time at which the extent
of damage reaches the limits for required residual strength capability. The
potential for missed inspections should be considered.
(a) For the case of no-growth design concept, inspection intervals should be
established as part of the maintenance programme. In selecting such
intervals, the residual strength level associated with the assumed damages
should be considered. This point was illustrated in Figures 4 and 5. Note that
an acceptable inspection interval for the larger damages shown for the “no-
growth” and “arrested growth” options in Figures 4 and 5 was conceptually
shown as related to an acceptable slow growth basis in terms of the residual
strength and time below ultimate load before damage was detected and
repaired. Data on the probability of occurrence for different damage sizes
also helps define an inspection interval.
(b) A thorough composite damage threat assessment and the separation of
different damage sizes into categories, each with associated detection
methods, supports programmes using a rigorous damage tolerance
assessment to avoid conservative design criteria with very large damage
assumptions. In such cases, Category 2 damage types will require the
structural substantiation of well specified and reliable inspection methods
applied by trained inspectors at scheduled maintenance intervals (by
default, Category 1 damage is at the threshold of this evaluation). Those
damages classified as Category 3 may take advantage of shorter service time
intervals provided sufficient structural substantiation exists with
demonstrated proof that there will be early detection by untrained ramp
maintenance or operations personnel. By definition, Category 4 damage will
require residual strength substantiation to levels that complete a flight with

AMC 20-29
limited manoeuvres based on the associated regulatory loads. Due to the

nature of service events leading to Category 4 damage, suitable inspections
will need to be defined to evaluate the full extent of damage, prior to
subsequent aircraft repair and return to service. By definition, Category 5
damages do not have associated damage tolerance design criteria or related
structural substantiation tasks. Category 5 damage will require suitable
inspections based on engineering assessment of the anomalous service
event, and appropriate structural repair and/or part replacement, prior to
the aircraft re-entering service.
(7) The structure should be able to withstand static loads (considered as ultimate
loads) which are reasonably expected during a completion of the flight on which
damage resulting from obvious discrete sources occur (i.e., uncontained engine
failures, etc.). The extent of damage should be based on a rational assessment of
service mission and potential damage relating to each discrete source. Structural
substantiation will be needed for the most critical Category 4 damage as related to
the associated load cases. Some Category 4 damage may have high margins but
will likely still require suitable inspections since their detectability may not be
consistent with the substantiations validated for Category 2 damage types.
(8) The effects of temperature, humidity, and other environmental or time-related
aging factors, which may result in material property degradation, should be
addressed in the damage tolerance evaluation. Unless tested in the environment,
appropriate environmental factors should be derived and applied in the
evaluation.
b. Fatigue Evaluation
Fatigue substantiation should be accomplished by component fatigue tests or by analysis
supported by test evidence, accounting for the effects of the appropriate environment.
The test articles should be fabricated and assembled in accordance with production
specifications and processes so that the test articles are representative of production
structures. Sufficient component, sub-component, element or coupon tests should be
performed to establish the fatigue scatter and the environmental effects. Component,
sub-component, and/or element tests may be used to evaluate the fatigue response of
structure with impact damage levels typical of those that may occur during fabrication,
assembly, and in service, consistent with the inspection procedures employed. Other
allowed manufacturing and service defects, which would exist for the life of the structure,
should also be included in fatigue testing. It should be demonstrated during the fatigue
tests that the stiffness properties have not changed beyond acceptable levels.
Replacement lives should be established based on the test results. By definition,
Category 1 damage is subjected to fatigue evaluation and expected to retain ultimate
load capability for the life of the aircraft structure.
c. Combined Damage Tolerance and Fatigue Evaluation
Generally, it is appropriate for a given structure to establish both an inspection
programme and demonstrate a service life to cover all detectable and non-detectable
damage, respectively, which is anticipated for the intended aircraft usage. Extensions in
service life should include evidence from component repeated load testing, fleet leader
programmes (including NDI and destructive tear-down inspections), and appropriate
statistical assessments of accidental damage and environmental service data
considerations.

AMC 20-29
9. PROOF OF STRUCTURE – FLUTTER AND OTHER AEROELASTIC INSTABILITIES

The aeroelastic evaluations including flutter, control reversal, divergence, and any undue loss
of stability and control as a result of structural loading and resulting deformation, are required.
Flutter and other aeroelastic instabilities must be avoided through design, quality control,
maintenance, and systems interaction.
a. The evaluation of composite structure needs to account for the effects of repeated
loading, environmental exposure, and service damage scenarios (e.g., large Category 2, 3
or 4 damage) on critical properties such as stiffness, mass and damping. Some control
surfaces exposed to large damage retain adequate residual strength margins, but the
potential loss of stiffness or mass increase (e.g., sandwich panel disbond and/or water
ingression) may adversely affect flutter and other aeroelastic characteristics. This is
particularly important for control surfaces that are prone to accidental damage and
environmental degradation. Other factors such as the weight or stiffness changes due to
repair, manufacturing flaws, and multiple layers of paint need to be evaluated. There may
also be issues associated with the proximity of high temperature heat sources near
structural components (e.g., empennage structure in the path of jet engine exhaust
streams or engine bleed air pneumatics system ducting). These effects may be
determined by analysis supported by test evidence, or by tests at the coupon, element
or sub-component level.
10. CONTINUED AIRWORTHINESS
The maintenance and repair of composite aircraft structure should meet all general, design and
fabrication, static strength, fatigue/damage tolerance, flutter, and other considerations
covered by this AMC as appropriate for the particular type of structure and its application.
a. Design for Maintenance
Composite aircraft structure should be designed for inspection and repair access in a field
maintenance environment. The inspection and repair methods applied for structural
details should recognise the special documentation and training needed for critical
damage types that are difficult to detect, characterise and repair. The inspection intervals
and life limits for any structural details and levels of damage that preclude repair must
be clearly documented in the appropriate continued airworthiness documents.
b. Maintenance Practices
Maintenance manuals, developed by the appropriate organisations, should include
appropriate inspection, maintenance, and repair procedures for composite structures,
including jacking, disassembly, handling, part drying methods, and repainting instructions
(including restrictions for paint colours that increase structural temperatures). Special
equipment, repair materials, ancillary materials, tooling, processing procedures, and
other information needed for inspection or repair of a given part should be identified
since standard field practices, which have been substantiated for different aircraft types
and models, are not common.
(1) Damage Detection
(a) Procedures used for damage detection must be shown to be reliable and
capable of detecting degradation in structural integrity below ultimate load
capability. These procedures must be documented in the appropriate
sections of the instructions for continued airworthiness. This should be
substantiated in static strength, environmental resistance, fatigue, and
damage tolerance efforts as outlined in paragraphs 6, 7 and 8. Substantiated

AMC 20-29
detection procedures will be needed for all damage types identified by the
threat assessment, including a wide range of foreign object impact threats,
manufacturing defects, and degradation caused by overheating.
Degradation in surface layers (e.g., paints and coatings) that provide
structural protection against ultraviolet exposure must be detected. Any
degradation to the lightning strike protection system that affects structural
integrity, fuel tank safety, and electrical systems must also be detected.
(b) Visual inspection is the predominant damage detection method used in the
field and should be performed under prescribed lighting conditions. Visual
inspection procedures should account for access, time relaxation in impact
damage dent depth, and the colour, finish and cleanliness of part surfaces.
(2) Inspection. Visual indications of damage, which are often used for composite
damage detection, provide limited details on the hidden parts of damage that
require further investigation. As a result, additional inspection procedures used for
complete composite damage characterisation will generally be different from
those used for initial damage detection and need to be well documented. Non-
destructive inspection performed prior to repair and destructive processing steps
performed during repair must be shown to locate and determine the full extent of
the damage. In-process controls of repair quality and post-repair inspection
methods must be shown to be reliable and capable of providing engineers with the
data to determine degradation in structural integrity below ultimate load capability
caused by the process itself. Certain processing defects cannot be reliably detected
at completion of the repair (e.g., weak bonds). In such cases, the damage threat
assessment, repair design features and limits should ensure sufficient damage
tolerance.
(3) Repair. All bolted and bonded repair design and processing procedures applied for
a given structure shall be substantiated to meet the appropriate requirements. Of
particular safety concern are the issues associated with bond material
compatibilities, bond surface preparation (including drying, cleaning, and chemical
activation), cure thermal management, composite machining, special composite
fasteners, and installation techniques, and the associated in-process control
procedures. The surface layers (e.g., paints and coatings) that provide structural
protection against ultraviolet exposure, structural temperatures, and the lightning
strike protection system must also be properly repaired.
(4) Documentation and Reporting. Documentation on all repairs must be added to the
maintenance records for the specific part number. This information supports
future maintenance damage disposition and repair activities performed on the
same part. It is recommended that service difficulties, damage, and degradation
occurring to composite parts in service should be reported back to the design
approval holder to aid in continuous updates of damage threat assessments to
support future design detail and process improvements. Such information will also
support future design criteria, analysis, and test database development.
c. Substantiation of Repair
(1) When repair procedures are provided in Agency approved documents or the
maintenance manual, it should be demonstrated by analysis and/or test that the
method and techniques of repair will restore the structure to an airworthy
condition. Repairable damage limits (RDL), which outline the details for damage to

AMC 20-29
structural components that may be repaired based on existing data, must be

clearly defined and documented. Allowable damage limits (ADL), which do not
require repair, must also be clearly defined and documented. Both RDL and ADL
must be based on sufficient analysis and test data to meet the appropriate
structural substantiation requirements and other considerations outlined in this
AMC. Additional substantiation data will generally be needed for damage types
and sizes not previously considered in design development. Some damage types
may require special instructions for field repair and the associated quality control.
Bonded repair is subjected to the same structural bonding considerations as the
base design (refer to paragraph 6.c).
(2) Operators and maintenance repair organisations (MRO) wishing to complete major
repairs or alterations outside the scope of approved repair documentation should
be aware of the extensive analysis, design, process, and test substantiation
required to ensure the airworthiness of a certificated structure. Documented
records and the certification approval of this substantiation should be retained in
accordance with regulations to support any subsequent maintenance activities.
d. Damage Detection, Inspection and Repair Competency
(1) All technicians, inspectors and engineers involved in damage disposition and repair
should have the necessary skills to perform their supporting maintenance tasks on
a specific composite structural part. The continuous demonstration of acquired
skills goes beyond initial training (e.g., similar to a welder qualification). The repair
design, inspection methods, and repair procedures used will require approved
structural substantiation data for the particular composite part. Society of
Automotive Engineers International (SAE) Aerospace Information Report (AIR)
5719 outlines training for an awareness of the safety issues for composite
maintenance and repair. Additional training for specific skill building will be needed
to execute particular engineering, inspection and repair tasks.
(2) Pilots, ramp maintenance, and other operations personnel that service aircraft
should be trained to immediately report anomalous ramp incidents and flight
events that may potentially cause serious damage to composite aircraft structures.
In particular, immediate reporting is needed for those service events that are
outside the scope of the damage tolerance substantiation and standard
maintenance practices for a given structure. The immediate detection of Category
4 and 5 damages are dependent on the proper reaction of personnel that operate
and service the aircraft.
11. ADDITIONAL CONSIDERATIONS
a. Crashworthiness
(1) The crashworthiness of the aircraft is dominated by the impact response
characteristics of the fuselage. Regulations, in general, evolve based on either
experience gained through incidents and accidents of existing aircraft or in
anticipation of safety issues raised by new designs. In the case of crashworthiness,
regulations have evolved as experience has been gained during actual aircraft
operations. For example, emergency load factors and passenger seat loads have
been established to reflect dynamic conditions observed from fleet experience and
from controlled FAA and industry research. Fleet experience has not demonstrated
a need to have an aircraft level crashworthiness standard. As a result, the
regulations reflect the capabilities of traditional aluminium aircraft structure under

AMC 20-29
survivable crash conditions. This approach was satisfactory as aircraft have

continued to be designed using traditional construction methods. With the advent
of composite fuselage structure and/or the use of novel design, this historical
approach may no longer be sufficient to substantiate the same level of protection
for the passengers as provided by similar metallic designs.
(2) Airframe design should assure that occupants have every reasonable chance of
escaping serious injury under realistic and survivable crash impact conditions. A
composite design should account for unique behaviour and structural
characteristics, including major repairs or alterations, as compared with
conventional metal airframe designs. Structural evaluation may be done by test or
analysis supported by test evidence. Service experience may also support
substantiation.
(3) The crash dynamics of an aircraft and the associated energy absorption are difficult
to model and fully define representative tests with respect to structural
requirements. Each aircraft product type (i.e., large aeroplane, small aeroplane,
and rotorcraft) has unique regulations governing the crashworthiness of particular
aircraft structures. The regulations and guidance associated with each product
type should be used accordingly. The regulations for large aeroplane and rotorcraft
address some issues that go beyond those required of small aeroplanes.
(4) Special conditions are anticipated for large aeroplanes with composite fuselage
structure to address crashworthiness survivability. The impact response of a
composite fuselage structure must be evaluated to ensure the survivability is not
significantly different from that of a similar-sized aircraft fabricated from metallic
materials. Impact loads and resultant structural deformation of the supporting
airframe and floor structures must be evaluated. Four main criteria areas should
be considered in making such an evaluation.
(a) Occupants must be protected during the impact event from release of items
of mass (e.g., overhead bins).
(b) At least the minimum number of emergency egress paths must remain
following a survivable crash.
(c) The acceleration and loads experienced by occupants during a survivable
crash must not exceed critical thresholds.
(d) A survivable volume of occupant space must be retained following the
impact event.
(5) The criticality of each of these four criteria will depend on the particular crash
conditions. For example, the loads and accelerations experienced by passengers
may be higher at lower impact velocities where structural failures have not started
to occur. As a result, validated analyses may be needed to practically cover all the
crashworthiness criteria for a fuselage.
(6) Existing large aeroplane requirements also require that fuel tank structural
integrity be addressed during a survivable crash impact event as related to fire
safety (also refer to paragraph 11.b). As related to crashworthiness, composite fuel
tank structure must not fail or deform to the extent that fire becomes a greater
hazard than with metal structure.
(7) Physics and mechanics of the crashworthiness for composite structures involve
several issues. The local strength, energy absorbing characteristics, and multiple

AMC 20-29
competing failure modes need to be addressed for composite structure subjected

to a survivable crash. This is not simply achieved for airframe structures made from
anisotropic, quasi-brittle, composite materials. As a result, the accelerations and
load histories experienced by passengers and equipment on a composite aircraft
may differ significantly from that seen on a similar metallic aircraft unless specific
considerations are designed into the composite structure. In addition, care should
be taken when altering composite structure to achieve specific mechanical
behaviours. (For example, where the change in behaviour of a metallic structure
with a change in material thickness may be easily predicted, an addition or deletion
of plies to a composite laminate may also require data for the effects of laminate
stacking sequence on the failure mode and energy absorption characteristics of a
composite element).
(8) Representative structure must be included to gain valid test and analysis results.
Depending on aircraft loading (requiring investigation of various aircraft passenger
and cargo configurations), structural dynamic considerations, and progressive
failures, local strain rates and loading conditions may differ throughout the
structure. Sensitivity of the structural behaviour to reasonable impact orientation
should also be considered for large aeroplane and rotorcraft applications. This can
be addressed by analysis supported by test evidence.
(9) Considering a need for comparative assessments with metal structure and a range
of crash conditions, analysis with sufficient structural test evidence is often needed
for large aeroplane and rotorcraft applications. Analysis requires extensive
investigation of model sensitivity to modelling parameters (e.g., mesh
optimisation, representation of joints, element material input stress-strain data).
Test also requires investigation of test equipment sensitivity appropriate to
composites (e.g., filter frequencies with respect to expected pulse characteristics
in the structure). Model validation may be achieved using a building block
approach, culminating in an adequately complex test (e.g., a drop test with
sufficient structural details to properly evaluate the crashworthiness criteria).
b. Fire Protection, Flammability and Thermal Issues
(1) Fire and exposure to temperatures that exceed maximum operating conditions
require special considerations for composite airframe structure. (Refer to note
below). Requirements for flammability and fire protection of aircraft structure
attempt to minimise the hazard to occupants in the event that flammable
materials, fluids, or vapours ignite. The regulations associated with each aircraft
product type (i.e., transport, small airplane, rotorcraft) should be used accordingly.
Compliance may be shown by tests or analysis supported by test evidence. A
composite design, including repair and alterations, should not decrease the
existing level of safety relative to metallic structure. In addition, maintenance
procedures should be available to evaluate the structural integrity of any
composite aircraft structures exposed to fire and temperatures above the
maximum operating conditions substantiated during design.
Note: Aircraft cabin interiors and baggage compartments have been areas of
flammability concerns in protecting passenger safety. This revision of the AMC
does not address composite materials used in aircraft interiors and baggage
compartments. Please consult other Guidance Material for Acceptable Means of
Compliance with flammability rules for interiors.

AMC 20-29
(2) Fire protection and flammability has traditionally been considered for engine
mount structure, firewalls, and other powerplant structures that include
composite elements. Additional issues critical to passenger safety have come with
the expanded use of composites in wing and fuselage structures for large
aeroplanes. Existing regulations do not address the potential for the airframe
structure itself to be flammable. Wing and fuselage applications should consider
the effects of composite design and construction on the resulting passenger safety
in the event of in-flight fires or emergency landing conditions, which combine with
subsequent egress when a fuel-fed fire is possible.
(3) The results of fire protection and flammability testing with structural composite
parts indicate dependence upon overall design and process details, as well as the
origin of the fire and its extent. For example, the overall effects of composite
fuselage structures exposed to fire may be significantly different when the fire
originates within the cabin, where it can be controlled by limiting the structure’s
contribution to spreading the fire, than when the fire occurs exterior to the
fuselage after a crash landing, where fuel is likely to be the primary source for
maintaining and spreading the fire. The threat in each case is different, and the
approach to mitigation may also be different. In-flight fire safety addresses a fire
originating within the aircraft due to some fault, whereas post-crash fire safety
addresses a fuel fed pool fire external to the aircraft. Special conditions are
anticipated for large aeroplanes with fuselage structure subjected to both in-flight
and post-crash fire conditions. Large aeroplane wing structure will need to have
special conditions for post-crash fire conditions.
(4) For an in-flight fire in large aeroplanes, it is critical that the fire not propagate or
generate hazardous quantities of toxic by-products. In-flight fires have been
catastrophic when they can grow in inaccessible areas. Composite fuselage
structure could play a role different from traditional metal structure if the issue is
not addressed.
(5) Metallic large aeroplane fuselage and wing structures have established a
benchmark in fire protection that can be used to evaluate specific composite wing
and fuselage structural details. Exterior fire protection issues associated with
composite structure must include the effects of an exterior pool fire following a
survivable crash landing. Fuselage structure should provide sufficient time for
passenger egress, without fire penetration or the release of gasses and/or
materials that are either toxic to escaping passengers or reduce visibility (smoke
density) or could increase the fire severity. Furthermore, these considerations
must be extended to wing and fuel tank structure, which must also be prevented
from collapse and release of fuel (including consideration of the influence of fuel
load upon the structural behaviour. For large aeroplanes, the standards of
CS 25.856(b) provide the benchmark to establish the required level of safety.
(6) The exposure of composite structures to high temperatures needs to extend
beyond the direct flammability and fire protection issues to other thermal issues.
Many composite materials have glass transition temperatures, which mark the
onset of reductions in strength and stiffness that are somewhat lower than the
temperatures that can have a similar effect on equivalent metallic structure. The
glass transition temperature of most composite materials is further reduced by
moisture absorption. The reduced strength or stiffness of composites from high
temperature exposures must be understood per the requirements of particular

AMC 20-29
applications (e.g., engine or other system failures). After a system failure and/or
known fire, it may be difficult to detect the full extent of irreversible heat damage
to an exposed composite structure. As a result, composite structures exposed to
high temperatures may require special inspections, tests, and analysis for proper
disposition of heat damage. All appropriate damage threats and degradation
mechanisms need to be identified and integrated into the damage tolerance and
maintenance evaluation accordingly. Reliable inspections and test measurements
of the extent of damage that exists in a part exposed to unknown levels of high
temperatures should be documented. Particular attention should be given to
defining the maximum damages that likely could remain undetected by the
selected inspection procedures.
c. Lightning Protection
Lightning protection design features are needed for composite aircraft structures.
Current Carbon fibre composites are approximately 1,000 times less electrically
conductive than standard aluminium materials, and composite resins and adhesives are
traditionally non-conductive. Glass and aramid fibre composites are non-conductive. A
lightning strike to composite structures can result in structural failure or large area
damage, and it can induce high lightning current and voltage on metal hydraulic tubes,
fuel system tubes, and electrical wiring if proper conductive lightning protection is not
provided. Aircraft lightning protection design guidance can be found in the FAA Technical
Report “Aircraft Lightning Protection Handbook” (See Appendix 1 2.a). The lightning
protection effectiveness for composite structures should be demonstrated by tests or
analysis supported by tests. Such tests are typically performed on panels, coupons,
subassemblies, or coupons representative of the aircraft structure, or tests on full
aircraft. The lightning test waveforms and lightning attachment zones are defined in
EUROCAE ED-84 and ED-91. Any structural damage observed in standard lightning tests
should be limited to Category 1, 2 or 3, depending on the level of detection. This damage
is characterised and integrated into damage tolerance analyses and tests as appropriate.
Small simple aeroplanes certified under CS-23 for VFR use only may be certified based on
engineering assessment, according to AC 23-15A. The effects of composite structural
repairs and maintenance on the lightning protection system should be evaluated. Repairs
should be designed to maintain lightning protection.
(1) Lightning Protection for Structural Integrity
(a) The composite structural design should incorporate the lightning protection
when appropriate for the anticipated lightning attachment. The extent of
lightning protection features depends on the lightning attachment zone
designated for that area of the aircraft. Lightning protection features may
include, but are not limited to, metal wires or mesh added to the outside
surface of the composite structure where direct lightning attachment is
expected.
(b) When lightning strikes an aircraft, very high currents flow through the
airframe. Proper electrical bonding must be incorporated between
structural parts. This is difficult to achieve for moveable parts (e.g., ailerons,
rudders and elevators). The electrical bonding features must be sized to
conduct the lightning currents or they can vaporise, sending the high
currents through unintended paths such as control cables, control rods, or
hydraulic tubes. Guidance for certification of lightning protection of aircraft
structures can be found in EUROCAE ED-113.

AMC 20-29
(2) Lightning Protection for Fuel Systems

(a) Special consideration must be given to the fuel system lightning protection
for an aircraft with integral fuel tanks in a composite structure. Composite
structure with integral fuel systems must incorporate specific lightning
protection features on the external composite surfaces, on joints, on
fasteners, and for structural supports for fuel system plumbing and
components to eliminate structural penetration, arcing, sparks or other
ignition sources. AC 20-53B provides certification guidance for aircraft fuel
system lightning protection.
(b) Large aeroplane regulations for fuel system ignition prevention in CS 25.981
require lightning protection that is failure tolerant. As a result, redundant
and robust lightning protection for composite structure joints and fasteners
in fuel tank structure is needed to ensure proper protection in preventing
ignition sources.
(3) Lightning Protection for Electrical and Electronic Systems
(a) Lightning strike protection of composite structures is needed to avoid
inducing high lightning voltages and currents on the wiring for electrical and
electronic systems whose upset or damage could affect safe aircraft
operation. The consequences from a lightning strike of unprotected
composite structures can be catastrophic for electrical and electronic
systems that perform highly critical functions, such as fly-by-wire flight
controls or engine controls.
(b) Electrical shields over system wiring and robust circuit design of electrical
and electronic equipment both provide some protection against system
upset or damage due to lightning. Since most composite materials provide
poor shielding, at best, metal foil or mesh is typically added to the composite
structure to provide additional shielding for wiring and equipment. Electrical
bonding between composite structure parts and panels should be provided
for the shielding to be effective. EUROCAE ED-81 and ED-107 provide
certification guidance for aircraft electrical and electronic system lightning
protection.
[Amdt 20/6]

AMC 20-29
Appendix 1 to AMC 20-29 – Applicable CSs and Relevant Guidance

1. Applicable CSs. A list of applicable CS paragraphs is provided for subjects covered in this AMC
(see notes). In most cases, these CS paragraphs apply regardless of the type of materials used
in aircraft structures.
AMC Paragraphs CS-23 CS-25 CS-27 CS-29
1. Purpose of this AMC -------------- Not Applicable --------------
2. To Whom this AMC Applies -------------- Not Applicable --------------
3. Cancellation -------------- Not Applicable --------------
4. Related Regulations and Guidance -------------- Not Applicable --------------
5. General -------------- Not Applicable --------------
6. Material and Fabrication Development 603 603 603 603

605 605 605 605
609 609 609 609
613 613 613 613
619 619 619 619
7. Proof of Structure – Static 305 305 305 305
307 307 307 307
8. Proof of Structure – Fatigue and Damage
Tolerance 573 571 571 571
9. Proof of Structure – Flutter 629 629 629 629
10. Continued Airworthiness 1529 1529 1529 1529

App. G App. H App. H App. A
11. Additional Considerations
a. Crashworthiness 561 561 561 561
(including impact dynamics) 562 562 562 562
601 601 601 601
631 631
721 721
783 783 783 783
785 785 785 785
787 787 787 787
789 789
801 801 801
803
807 807
809 809
963 963 963
965 965 965
967 967 967 967
981

AMC 20-29
b. Fire Protection, Flammability and 609 609 609 609

Thermal Issues
853 853 853 853
855 855 855 855
859 859 859 859
861 861
863 863 863 863
865 865
867
903 903 903
1121 1121 1121 1121

1181 1181 1181
1182 1182
1183 1183 1183 1183
1185 1185 1185
1187 1187
1189 1189 1189 1189
1191 1191 1191 1191
1193 1193 1193 1193
1194 1194
1359
1365
c. Lightning Protection 581*
609 609 609 609
* see AMC 25.899 para.6
610
867
899*
954 954* 954 954
1309 981
1309 1309
1316
Notes:
(1) This list may not be all inclusive and there may be differences between certification agencies (e.g.
FAA and the Agency).
(2) Special conditions may be issued in accordance with Part-21 21.A.16B for novel and unusual design
features (e.g., new composite materials systems).
2. Guidance
FAA issues guidance providing supportive information of showing compliance with regulatory
requirements. Guidance may include the advisory circulars (AC) and policy statements (PS). In
general, an AC presents information concerning acceptable means, but not the only means, of
complying with regulations. The guidance listed below is deemed supportive to the purposes of
this AMC. These FAA documents can be located via website:
http://www.faa.gov/regulations_policies/. In addition, EUROCAE have developed industry
standards that are recognised by the Agency.
Note: Many of the FAA documents are harmonised with EASA. Applicants should confirm with
the Agency if in doubt regarding the status and acceptance of any such documents by the
Agency.
a. FAA/EUROCAE guidance documents

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

AMC 20-29
Appendix 2 to AMC 20-29 – Definitions

The following definitions are applicable to AMC 20-29 and relevant CS paragraphs only.
Allowables: Material values that are determined from test data at the laminate or lamina level on a
probability basis (e.g., A or B basis values, with 99% probability and 95% confidence, or 90% probability
and 95% confidence, respectively). The amount of data required to derive these values is governed by
the statistical significance (or basis) needed.
Anisotropic: Not isotropic; having mechanical and/or physical properties which vary with direction
relative to natural reference axes inherent in the material.
Arrested Growth Approach: A method that requires demonstration that the structure, with defined
flaws present, is able to withstand appropriate repeated loads with flaw growth which is either
mechanically arrested or terminated before becoming critical (residual static strength reduced to limit
load). This is to be associated with appropriate inspection intervals and damage detectability.
Category of Damage: One of five categories of damage based on residual strength capability, required
load level, detectability, inspection interval, damage threat and whether (or not) the event creating
damage is self-evident (see Section 8(a)(1)(c)).
Component: A major section of the airframe structure (e.g., wing, body, fin, horizontal stabiliser)
which can be tested as a complete unit to qualify the structure.
Coupon: A small test specimen (e.g., usually a flat laminate) for evaluation of basic lamina or laminate
properties or properties of generic structural features (e.g., bonded or mechanically fastened joints).
Critical Structure: A load bearing structure/element whose integrity is essential in maintaining the
overall flight safety of the aircraft. This definition was adopted for this AMC because there are
differences in the definitions of primary structure, secondary structure, and principle structural
elements (PSE) when considering the different categories of aircraft. For example, PSE are critical
structures for Large Aeroplanes.
Damage: A structural anomaly caused by manufacturing (processing, fabrication, assembly or
handling) or service usage.
Debond: Same as Disbond.
Degradation: The alteration of material properties (e.g., strength, modulus, coefficient of expansion)
which may result from deviations in manufacturing or from repeated loading and/or environmental
exposure.
Delamination: The separation of the layers of material in a laminate. This may be local or may cover
a large area of the laminate. It may occur at any time in the cure or subsequent life of the laminate
and may arise from a wide variety of causes.
Design Values: Material, structural elements, and structural detail properties that have been
determined from test data and chosen to assure a high degree of confidence in the integrity of the
completed structure. These values are most often based on allowables adjusted to account for actual
structural conditions, and used in analysis to compute margins-of-safety.
Detail: A non-generic structural element of a more complex structural member (e.g., specific design
configured joints, splices, stringers, stringer runouts, or major access holes).
Disbond: An area within a bonded interface between two adherends in which an adhesion failure or
separation has occurred. It may occur at any time during the life of the substructure and may arise

AMC 20-29
from a wide variety of causes. Also, colloquially, an area of separation between two laminae in the
finished laminate (in this case the term “delamination” is normally preferred).
Discrepancy: A manufacturing anomaly allowed and detected by the planned inspection procedure.
They can be created by processing, fabrication or assembly procedures.
Element: A generic part of a more complex structural member (e.g., skin, stringers, shear panels,
sandwich panels, joints, or splices).
Environment: External, non-accidental conditions (excluding mechanical loading), separately or in
combination, that can be expected in service and which may affect the structure (e.g., temperature,
moisture, UV radiation, and fuel).
Factor(s):
— Life (or Load) Enhancement Factor: An additional load factor and/or test duration applied to
structural repeated load tests, relative to the intended design load and life values, used to
account for material variability. It is used to develop the required level of confidence in data.
— Life Scatter Factor: Same as Life/Load Enhancement Factor.
— Overload Factor: A load factor applied to a specific structure test which is used to address
parameters (e.g., environment, a short test pyramid, etc.) not directly addressed in that test.
This factor is usually developed from lower pyramid testing addressing such parameters.
Heterogeneous: Descriptive term for a material consisting of dissimilar constituents separately
identifiable; a medium consisting of regions of unlike properties separated by internal boundaries.
Intrinsic Flaw: Defect inherent in the composite material or resulting from the production process.
Manufacturing Defect: An anomaly or flaw occurring during manufacturing that can cause varying
levels of degradation in structural strength, stiffness and dimensional stability. Those manufacturing
defects (or permissible manufacturing variability) allowed by the quality control, manufacturing
acceptance criteria are expected to meet appropriate structural requirements for the life of the
aircraft part. Other manufacturing defects that escape detection in manufacturing quality control
should be included in a damage threat assessment and must meet damage tolerance requirements
until detected and repaired.
No-Growth Approach: A method that requires demonstration that the structure, with defined flaws
present, is able to withstand appropriate repeated loads without detrimental flaw growth for the life
of the structure.
Primary Structure: The structure which carries flight, ground, or pressurisation loads, and whose
failure would reduce the structural integrity of the aircraft.
Point Design: An element or detail of a specific design which is not considered generically applicable
to other structure for the purpose of substantiation, e.g., lugs and major joints. Such a design element
or detail can be qualified by test or by a combination of test and analysis.
Slow Growth Approach: A method that requires demonstration that the structure, with defined flaws
present, is able to withstand appropriate repeated loads with slow, stable, and predictable flaw
growth for the life of the structure, or beyond appropriate inspection intervals associated with
appropriate damage detectability.
Structural Bonding: A structural joint created by the process of adhesive bonding, comprising of one
or more previously-cured composite or metal parts (referred to as adherends).

AMC 20-29
Sub-component: A major three-dimensional structure which can provide completed structural

representation of a section of the full structure (e.g., stub-box, section of a spar, wing panel, body
panel with frames).
Weak Bond: A bond line with mechanical properties lower than expected, but without any possibility
to detect that by normal NDI procedures. Such situation is mainly due to a poor chemical bonding.
[Amdt 20/6]

AMC 20-29
Appendix 3 to AMC 20-29 – Change of Composite Material and/or

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

substitutions of, or changes to, the materials and/or processes from those originally
substantiated at the time of initial certification. For example, the original material supplier may
either change its product, or cease production. Manufacturers may also find it necessary to
modify their production processes to improve efficiency or correct product deficiencies. In
either case, care must be taken to ensure that modifications and/or changes are adequately
investigated to ensure the continued adequacy of already certificated composite structure. This
appendix covers such material and/or process changes, but does not address other changes to
design (e.g., geometry, loading). The definition of the materials and processes used is required
in the specifications by Part 21.A.31. Changes to the material and process specifications are
often major changes in type design and must be addressed as such under Part-21, subpart D or
E as applicable.
2. The qualification and structural substantiation of new or modified materials and/or processes
used to produce parts of a previously certified aircraft product requires:
a. The identification of the key material and/or process parameters governing
performances;
b. The definition of the appropriate tests able to measure these parameters; and
c. The definition of pass/fail criteria for these tests.
3. ‘Qualification’ procedures developed by every manufacturer include specifications covering:
a. Physical and chemical properties,
b. Mechanical properties (coupon level), and
c. Reproducibility (by testing several batches).
4. Specifications and manufacturing quality procedures are designed to control specific materials
and processes to achieve stable and repeatable structure for that combination of materials and
processes. However, the interchangeability of alternate materials and processes for a structural
application cannot be assumed if one only considers the properties outlined in those
specifications (as it could be for materials that are much less process dependent, e.g., some
metallic material forms). A structure fabricated using new or modified materials and/or
processes, which meet the ‘qualification’ tests required for the original material and process
specifications, does not necessarily produce components that meet all the original engineering
requirements for the previously certified structure.
5. Until improvements in identifying the complex relations between key material parameters that
govern composite processing occurs, there will be a need for extensive and diverse testing that
directly interrogates material performance using a range of representative specimens of
increasing complexity in building block tests. Furthermore, failure modes may vary from one
material and/or process to another, and analytical models are sometimes insufficiently precise
to reliably predict failure without sufficient empirical data. Therefore, a step-by-step test
verification with more complex specimens may be required.
6. Classification of Material or Process Change
Material and/or process changes require appropriate classification in order to aid the
determination of the extent of investigation necessary. Some minor changes may only require

AMC 20-29
material equivalency sampling tests to be completed at the base of the test pyramid, whilst
more significant changes will require more extensive investigations, including possibly a new
structural substantiation.
a. Any of the following situations requires further investigation of possible changes to a
given composite structure:
(1) Case A: A change in one or both of the basic constituents, resin, or fibre (including
sizing or surface treatment alone) would yield an alternate material. Other changes
that result in an alternate material include changes in fabric weave style, fibre
aerial weight and resin content.
(2) Case B: Same basic constituents, but any change of the resin impregnation method.
Such changes include: (i) prepregging process (e.g., solvent bath to hot melt
coating), (ii) tow size (3k, 6k, 12k) for tape material forms with the same fibre areal
weight, (iii) prepregging machine at the same suppliers, (iv) supplier change for a
same material (licensed supplier).
(3) Case C: Same material, but modification of the processing route (if the modification
to the processing route governs eventual composite mechanical properties).
Example process changes of significance include: (i) curing cycle, (ii) bond surface
preparation, (iii) changes in the resin transfer moulding process used in fabricating
parts from dry fibre forms, (iv) tooling, (v) lay-up method, (vi) environmental
parameters of the material lay-up room, and (vii) major assembly procedures.
b. For each of the above cases, a distinction should be made between those changes
intended to be a replica of the former material/process combination (Case B and some
of Case C) and those which are “truly new material” (Case A and some of Case C). So, two
classes are proposed:
(1) “Identical materials/processes” in cases intended to create a replica structure.
(2) “Alternative materials/processes” in cases intended to create truly new structure.
c. Within the “identical materials/processes” class, a sub-classification can be made
between a change of the prepregging machine alone at the supplier and licensed
production elsewhere. For the time being, a change to a new fibre produced under a
licensed process and reputed to be a replica of the former one, will be dealt with as an
“alternative material/process”.
d. Some minor changes within the class representing identical materials/processes may not
interact with structural performances (e.g., prepreg release papers, some bagging
materials, etc.) and should not be submitted to the Agency as part of the change.
However, the manufacturers (or the supplier) should develop a proper system for
screening those changes, with adequate proficiency at all relevant decision levels. Other
minor material changes that fall under Case B may warrant sampling tests to show
equivalency only at lower levels of building block substantiation.
e. Case C changes that may yield major changes in material and structural performance
need to be evaluated at all appropriate levels of the building block tests to determine
whether the manufacturing process change yields identical or alternate materials.
Engineering judgment will be needed in determining the extent of testing based on the
proposed manufacturing change.
f. Case A (alternative material) should always be considered as an important change, which
requires structural substantiation. It is not recommended to try a sub-classification

AMC 20-29
according to the basic constituents being changed, as material behaviour (e.g., sensitivity
to stress concentrations) may be governed by interfacial properties, which may be
affected by either a fibre or a resin change.
7. Substantiation Method. Only the technical aspects of substantiation are addressed below.
a. Compliance Philosophy. Substantiation should be based on a comparability study
between the structural performances of the material accepted for type certification, and
the second material. Whatever the modification proposed for a certificated item, the
revised margins of safety should remain adequate. Any reduction in the previously
demonstrated margin should be investigated in detail.
(1) Alternative Material/Process: New design values for all relevant properties should
be determined for any alternate material/process combination. Analytical models
initially used to certify structure, including failure prediction models, should be
reviewed and, if necessary, substantiated by tests. The procurement specification
should be modified (or a new specification suited to the selected material should
be defined) to ensure key quality variations are adequately controlled and new
acceptance criteria defined. For example, changing from first to second generation
of carbon fibres may improve tensile strength properties by more than 20% and a
new acceptability threshold will be needed in the specification of the alternate
material to ensure the detection of quality variations.
(2) Identical Material: Data should be provided that demonstrates that the original
design values (whatever the level of investigation, material or design) remain valid.
Statistical methods need to be employed for data to ensure that key design
properties come from the same populations as the original material/process
combination. Calculation models including failure prediction should remain the
same. The technical content of the procurement specification (Case B) should not
need to be changed to properly control quality.
b. Testing.
(1) The extent of testing needed to substantiate a material change should address the
inherent structural behaviour of the composite and will be a function of the
airworthiness significance of the part and the material change definition. For
example, the investigation level might be restricted to the generic specimens at
the test pyramid base (refer to figures in paragraph 7) for an identical material, but
non-generic test articles from higher up the pyramid should be included for an
alternative material. Care needs to be taken to ensure that the test methods used
yield data compatible with data used to determine properties of the original
structure.
(2) The testing that may be required for a range of possible material and/or process
changes should consider all levels of structural substantiation that may be affected.
In some instances (e.g., a minor cure cycle change), possible consequences can be
assessed by tests on generic specimens only. For other changes, like those
involving tooling (e.g., from a full bag process to thermo-expansive cores), the
assessment should include an evaluation of the component itself (sometimes
called the “tool proof test”). In this case, an expanded NDI procedure should be
required for the first items to be produced. This should be supplemented – if
deemed necessary – by “cut up” specimens from a representative component, for
physical or mechanical investigations.

AMC 20-29
c. Number of Batches.
(1) The purpose for testing a number of batches is the demonstration of an acceptable
reproducibility of material characteristics. The number of batches required should
take into account: material classification (identical or alternative), the investigation
level (non-generic or generic specimen) the source of supply, and the property
under investigation. Care should be taken to investigate the variation of both basic
material and the manufacturing process.
(2) Existing references (e.g., The Composite Materials Handbook (CMH-17) Volumes 1
and 3, FAA Technical Report DOT/ FAA/AR-03/19), addressing composite
qualification and equivalence and the building block approach, provide more
detailed guidance regarding batch and test numbers and the appropriate statistical
analysis up to laminate level. Changes at higher pyramid levels, or those associated
with other material forms, e.g., braided VARTM (Vacuum-Assisted Resin Transfer
Moulding) structure, may require use of other statistical procedures or engineering
methods.
d. Pass/Fail Criteria. Target pass/fail criteria should be established as part of the test
programme. For strength considerations for instance, a statistical analysis of test data
should demonstrate that new design values derived for the second material provide an
adequate margin of safety. Therefore, provision should be made for a sufficient number
of test specimens to allow for such analysis. At the non-generic level, when only one test
article is used to assess a structural feature, the pass criteria should be a result acceptable
with respect to design ultimate loads. In the cases where test results show lower margins
of safety, certification documentation will need to be revised.
e. Other Considerations. For characteristics other than static strength (all those listed in
AMC 20-29, paragraphs 8, 9, 10 and 11), the substantiation should also ensure an
equivalent level of safety.
[Amdt 20/6]

AMC 20-42
AMC 20-42
AMC 20-42 Airworthiness information security risk assessment

1. PURPOSE
(a) This AMC describes an acceptable means, but not the only means, to show compliance
with the applicable rules for the certification of products and parts. Compliance with this
AMC is not mandatory and, therefore, an applicant may elect to use an alternative means
of compliance. However, any alternative means of compliance must meet the relevant
requirements and be accepted by EASA.
(b) This AMC recognises as an acceptable means of compliance the following European
Organisation for Civil Aviation Equipment (EUROCAE) and Radio Technical Commission
for Aeronautics (RTCA) documents:
— EUROCAE ED-202A, Airworthiness Security Process Specification, dated June 2014 /
RTCA DO-326A, dated August 2014;
— EUROCAE ED-203A, Airworthiness Security Methods and Considerations, dated
June 2018 / RTCA DO-356, dated June 2018;
— EUROCAE ED-204, Information Security Guidance for Continuing Airworthiness,
dated June 2014 / RTCA DO-355, dated June 2014.
(c) This AMC establishes guidance to use ED-202A, 203A and 204 in the different contexts of
the initial and continued airworthiness of products and parts.
(d) The possibility to give credit for products developed using previous versions of
EUROCAE ED/RTCA DO documents may be discussed with and accepted by EASA.
Note: EUROCAE ED is hereinafter referred to as ‘ED’ and RTCA DO is hereinafter referred to as
‘DO’. Where the notation ‘ED-XXX/DO-XXX’ appears in this document, the referenced
documents are recognised as being equivalent.
2. APPLICABILITY
This AMC applies to manufacturers of products and parts, and to design approval holders (DAHs)
that apply for:
— the type certification of a new product (i.e. an aircraft, engine or propeller);
— a supplemental type certificate (STC) to an existing type-certified product;
— a change to a product;
— the approval of a new item of equipment or a change to equipment to be used in an ETSO
article. In such a case, an ETSO article may contain one or more security measures. Those
security measures may be assigned a security assurance level (SAL). Credit can be taken
for those security measures and their associated SALs by the design organisation approval
holder (DOAH), depending on the information system security risk assessment of the
product;
— the certification of other systems or equipment that provide air service information
whose certification is required by a national regulation;

AMC 20-42
— the approval of products and parts of information systems that are subject to potential
information security threats and that could result in unacceptable safety risks.
3. REPLACEMENT
Reserved.
4. GENERAL PRINCIPLES
(a) The information systems of the products, parts or equipment identified in Section 2
should be assessed against any potential intentional unauthorised electronic interaction
(IUEI) security threat and vulnerability that could result in an unsafe condition. This risk
assessment is referred to as a ‘product information security risk assessment’ (PISRA) and
is further described in Section 5 of this AMC.
(b) The result of this assessment, after any necessary means of mitigation have been
identified, should be that either the systems of the product or part have no identifiable
vulnerabilities, or those vulnerabilities cannot be exploited to create a hazard or generate
a failure that would have an effect that is deemed to be unacceptable against the
certification specification and the acceptable means of compliance including industry
standards for the product or part considered.
(c) When a risk needs to be mitigated, the applicant should demonstrate, as described in
Section 5, that the means of mitigation provide sufficient grounds for evaluating that the
residual risk is acceptable. The means of mitigation should be provided to the operators
in a timely manner.
(d) Once the overall risk has been deemed to be acceptable, the applicant should, if
necessary, develop instructions as described in Section 9, to maintain the information
security risk of the systems of the product or part at an acceptable level, after the entry
into service of the product or part.
5. PRODUCT INFORMATION SECURITY RISK ASSESSMENT
(a) The general product information security risk assessment (PISRA) should cover the
following aspects:
(i) determination of the security environment for the information security of the
product1;
(ii) identification of the assets;
(iii) identification of the attack paths;
(iv) assessment of the safety consequences of the threat to the affected assets;
(v) evaluation, by considering the existing security protection means, of the level of
threat that would have an impact on safety;
(vi) determination of whether the risks, which are the result of the combination of the
severities and the potentiality to attack (or, inversely, the difficulty of attacking),
are acceptable:
If they are acceptable, preparation of the justification for certification, including
the means to maintain the risk at an acceptable level (see Section 9);
If they are not acceptable,
1 To address the assumptions about external factors like organisations, processes, etc., see reference in ED-202A.

AMC 20-42
(A) analysis of the proposed means of mitigation to ensure an acceptable level

of safety,
(B) implementation of means of mitigation,
(C) evaluation of the effectiveness of the means of mitigation as in Section 8
with respect to the level of risk (combination of the level of threat and
severity of the threat condition);
(vii) iteration from point (vi) until all the residual risks are acceptable.
(b) The process for the Security Risk Assessment identified in ED-202A Section 2.1.1 is an
acceptable means of compliance for performing the PISRA for products and parts under
Annex I (Part 21) to Regulation (EU) No 748/20121. Guidance material for the PISRA can
be found in ED-203A.
6. RISK ACCEPTABILITY
Acceptable/Unacceptable Risk: whether or not a risk is unacceptable depends on the context
and the criteria that are considered for the certification of the affected product or part. The risk
may be acceptable in some cases and unacceptable in others. For example, a threat condition
that has a potential major safety effect, as defined in CS xx.1309, may be not acceptable in the
context of CS-25 products depending on the level of threat and the associated threat scenario.
The same safety risk may be acceptable for products that are certified under CS-29.
7. REPORTING
The operator of a product or part should report any information security occurrences to the
designer of this product or part or the aircraft TC/STC holder, in a manner that would allow a
further impact analysis and corrective actions, if appropriate. If this impact analysis identifies
the potential for an unsafe condition, the designer of that product or part should report it to
the competent authority in a timely manner. For example, for organisations to which Regulation
(EU) No 748/2012 applies, the reporting should be done in accordance with point 21.A.3A of
Annex I (Part 21) to that Regulation.
8. VALIDATION AND VERIFICATION OF THE SECURITY PROTECTION
If information security risks that are identified during the product information security risk
assessment (PISRA) need to be mitigated, security verification should be used to evaluate the
effectiveness of the means of mitigation.
(a) This verification should be performed by a combination of analysis, security-oriented
robustness testing, inspections, and reviews; and
(b) When necessary, by security testing that addresses information security from the
perspective of a potential adversary.
9. INSTRUCTIONS FOR THE CONTINUED PROTECTION OF PRODUCT AND PART INFORMATION
SECURITY
The applicant should identify the information security assets and protection mechanisms to be
addressed by the Instructions for Continued Airworthiness (ICA) of the product or part (for
example, physical and operational security procedures, auditing and monitoring of the security
effectiveness, key management procedures that are used as assumptions in the security
1 Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the airworthiness and environmental
certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisations
(OJ L 224, 21.8.2012, p. 1) (https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1574094487050&uri=CELEX:32012R0748).

AMC 20-42
assurance process), and develop the appropriate procedures to maintain the security
effectiveness after the product or part enters into service.
When an in-service occurrence is reported, the applicant should consider the possibility that it
originated from an IUEI and should take any required corrective action accordingly. If an IUEI
has generated an unsafe condition, then information about the occurrence, the investigation
results and the recovery actions should be reported to EASA in accordance with point 21.A.3A
of Annex I (Part 21) to Regulation (EU) No 748/2012.
According to Article 2(7) of Regulation (EU) No 376/20141, an occurrence is defined as any
safety-related event which endangers, or which, if not corrected or addressed, could endanger
an aircraft, its occupants or any other person, and includes, in particular, any accident or serious
incident. Article 4 of the same Regulation requires the applicant to report to EASA any
occurrence that represents a significant risk to aviation safety.
The applicant should also assess the impact of new threats that were not foreseen during
previous product information security risk assessments (PISRAs) of the systems and parts of the
product. If the assessment identifies an unacceptable threat condition, the applicant should
notify the operators and the competent authority in a timely manner of the need and the means
to mitigate the new risk (or the absence of a risk).
Guidance on continued airworthiness can be found in EUROCAE ED-203A/RTCA DO-356A and
ED-204/RTCA DO-355.
10. DEFINITIONS
The terminology used in this AMC is consistent with the glossary provided in document
EUROCAE ER 013 AERONAUTICAL INFORMATION SYSTEM SECURITY GLOSSARY.
[Amdt 20/18]
1 Regulation (EU) No 376/2014 of the European Parliament and of the Council of 3 April 2014 on the reporting, analysis and follow-up of
occurrences in civil aviation, amending Regulation (EU) No 996/2010 of the European Parliament and of the Council and repealing
Directive 2003/42/EC of the European Parliament and of the Council and Commission Regulations (EC) No 1321/2007 and (EC)
No 1330/2007 (OJ L 122, 24.4.2014, p. 18) (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014R0376).

AMC 20-115D
AMC 20-115D
AMC 20-115D Airborne Software Development Assurance Using

EUROCAE ED-12 and RTCA DO-178
1. PURPOSE
a. This AMC describes an acceptable means, but not the only means, for showing
compliance with the applicable airworthiness regulations with regard to the software
aspects of airborne systems and equipment in the domain of product certification or
European technical standard orders (ETSOs) authorisation. Compliance with this AMC is
not mandatory and therefore an applicant may elect to use an alternative means of
compliance (AltMoC). However, the AltMoC must meet the relevant requirements,
ensure an equivalent level of software safety as this AMC, and be approved by the
European Aviation Safety Agency (EASA) on a product or ETSO article basis.
b. This AMC recognises the following European Organisation for Civil Aviation Equipment
(EUROCAE) and Radio Technical Commission for Aeronautics (RTCA) documents:
1. EUROCAE ED-12C, Software Considerations in Airborne Systems and Equipment
Certification, 1 January 2012, and RTCA DO-178C, Software Considerations in
Airborne Systems and Equipment Certification, 13 December 2011;
2. EUROCAE ED-215, Software Tool Qualification Considerations, 1 January 2012, and
RTCA DO-330, Software Tool Qualification Considerations, 13 December 2011;
3. EUROCAE ED-216, Formal Methods Supplement to ED-12C and ED-109A,
1 January 2012, and RTCA DO-333, Formal Methods Supplement to DO-178C and
DO-278A, 13 December 2011;
4. EUROCAE ED-217, Object-Oriented Technology and Related Techniques
Supplement to ED-12C and ED-109A, 1 January 2012, and RTCA DO-332, Object-
Oriented Technology and Related Techniques Supplement to DO-178C and DO-
278A, 13 December 2011; and
5. EUROCAE ED-218, Model-Based Development and Verification Supplement to ED-
12C and ED-109A, 1 January 2012, and RTCA DO-331, Model-Based Development
and Verification Supplement to DO-178C and DO-278A, 13 December 2011.
Note: EUROCAE ED is hereinafter referred to as ‘ED’; RTCA DO is hereinafter referred to
as ‘DO’. Where the notation ‘ED-XXX/DO-XXX’ appears in this document, the referenced
documents are recognised as being equivalent.
c. This AMC identifies the following as supporting documents:
— ED-94C, Supporting Information for ED-12C and ED-109A, 1 January 2012; and
— DO-248C, Supporting Information for DO-178C and DO-278A, 13 December 2011.
ED-94C/DO-248C contains a collection of frequently asked questions (FAQs) and
discussion papers (DPs) compiled and approved by the authors of ED-12C and DO-178C
to provide clarification of the guidance contained in ED-12C/DO-178C.
d. References to the use of ED-12C/DO-178C in this AMC include the use of ED-215/DO-330
and supplements ED-216/DO-333, ED-217/DO-332 and ED-218/DO-331, as applicable.

AMC 20-115D
e. This AMC establishes guidance for using existing ED-12B/DO-178B processes for new
software development.
f. This AMC also establishes guidance for transitioning to ED-12C/DO-178C when making
modifications to software previously approved using ED-12/DO-178, ED-12A/DO-178A,
or ED-12B/DO-178B.
2. APPLICABILITY
This AMC applies to applicants, design approval holders (DAHs), and developers of airborne
systems and equipment containing software to be installed on type-certified aircraft, engines,
and propellers, or to be used in ETSO articles.
3. REPLACEMENT
This AMC replaces and cancels AMC 20-115C, Software Considerations in Airborne Systems and
Equipment Certification, 12 September 2013.
4. BACKGROUND
a. ED-12C/DO-178C, Appendix A, Section 3, provides a summary of the differences between
ED-12C/DO-178C and ED-12B/DO-178B. The EUROCAE and RTCA Inc. documents listed in
subparagraph 1.b. of this AMC provide guidance for establishing software life cycle
planning, development, verification, configuration management, quality assurance and
certification liaison processes to be used in the development of software for airborne
systems. The guidance provided in these documents is in the form of:
1. objectives for software life cycle processes;
2. activities that provide a means for satisfying the objectives; and
3. descriptions of the evidence indicating that the objectives have been satisfied.
b. The technical content of this AMC is, as far as practicable, harmonised with Federal
Aviation Administration (FAA) AC 20-115D, which is also based on ED-12C/DO-178C.
5. USING ED-12B/DO-178B PROCESSES AND PROCEDURES FOR NEW SOFTWARE DEVELOPMENT
a. Applicants who have established software development assurance processes using ED-
12B/DO-178B may continue to use those processes (including tool qualification
processes) for new software development and certification projects, provided that the
following criteria are met:
1. The software development assurance processes are shown to have no known
process deficiencies, such as those discovered during internal or external audits or
reviews, or identified in open problem reports (OPRs), resulting in non-satisfaction
of one or more ED-12B/DO-178B objectives. Evidence of resolution and closure of
all process-related OPRs and of all process-related audit or review findings may be
requested.
2. The processes were previously used to develop software that was used in a
certified product at a software level at least as high as the software level of the
software to be developed.
3. If model-based development (MBD), object-oriented technology (OOT), or formal
methods (FMs) are to be used, existing processes incorporating these methods
should have been evaluated and found to be acceptable by EASA on a previous
certified project. These processes should have been developed in accordance with

AMC 20-115D
EASA guidance specific to the technique, such as that contained in an associated

certification review item (CRI) or a published certification memorandum (CM).
4. If configuration data is used, as defined in ED-12C/DO-178C under ‘Parameter data
item’, existing processes for such data should have been evaluated and found to
be acceptable by EASA on a previous certified project. In the absence of processes
for using configuration data, the applicant should establish new processes for using
PDIs in accordance with ED-12C/DO-178C.
5. There are no significant changes to the software processes described in the plans
or to the software development environment. This should be supported through
analysis of the changes to the previously accepted software development
processes and environment.
6. The applicant does not intend to declare the proposed software as having satisfied
ED-12C/DO-178C.
b. If the criteria of subparagraph 5.a. are not met, the applicant should upgrade their
processes and develop the new software using ED-12C/DO-178C; tool qualification
processes should be addressed in accordance with Section 12.2 of ED-12C/DO-178C and
paragraph 10(c) of this AMC.
c. Applicants or developers should establish new software life cycle processes in accordance
with ED-12C/DO-178C.
6. USING EUROCAE ED-12C AND RTCA DO-178C
ED-12C/DO-178C is an acceptable means of compliance (AMC) with regard to the software
aspects of product certification or ETSOs authorisation. When using ED-12C/DO-178C, the
following should apply:
a. The applicant should satisfy all of the objectives associated with the software level
assigned to the software, and develop all of the associated life cycle data to demonstrate
compliance with the applicable objectives, as listed in the Annex A tables of ED-12C/DO-
178C and, where applicable, of ED-215/DO-330, ED-216/DO-333, ED-217/DO-332, and
ED-218/DO-331. The applicant should plan and execute activities that satisfy each
objective.
b. The applicant should submit to EASA the life cycle data specified in Section 9.3 of ED-
12C/DO-178C, and Section 9.0 a. of ED-215/DO-330, as applicable to tool qualification. It
is the applicant’s responsibility to perform the planned activities and produce the life
cycle data necessary to satisfy all the applicable objectives.
c. Section 9.4 of ED-12C/DO-178C specifies the software life cycle data related to the type
design of the certified product. However, not all of the specified data applies to all
software levels; specifically the design description and the source code are not part of
the type design data for Level D software.
d. The applicant should make available to EASA, upon request, any of the data described in
Section 11 of ED-12C/DO-178C, applicable tool qualification data, data outputs from any
applicable supplements, and any other data needed to substantiate the satisfaction of all
the applicable objectives.
e. EASA may publish an AMC to specific certification specifications (CSs), stating the
required relationship between the criticality of the software-based systems and the
software levels, as defined in ED-12C/DO-178C. Such AMC takes precedence over the
application of Section 2.3 of ED-12C/DO-178C.

AMC 20-115D
7. RESERVED
8. GUIDANCE APPLICABLE TO ED-12B/DO-178B OR ED-12C/DO-178C
a. The use of supplements with ED-12C/DO-178C
The applicant should apply the guidance of supplements to ED-216/DO-333, ED-217/DO-
332 and ED-218/DO-331 when incorporating the addressed software development
techniques. If the applicant intends to use multiple software development techniques
together, more than one supplement applies. The applicant should not use supplements
as stand-alone documents.
1. When using one or more supplements, the applicant’s plan for software aspects of
certification (PSAC) should describe:
a. how the applicant applies ED-12C/DO-178C and the supplement(s) together;
and
b. how the applicant addresses the applicable ED-12C/DO-178C objectives and
those added or modified by the supplement(s): which objectives from which
documents apply to which software components, and how the applicant’s
planned activities satisfy all the applicable objectives.
2. If the applicant intends to use any techniques addressed by the supplements to
develop a qualified tool (for tool qualification levels (TQLs) 1, 2, 3, and 4 only), then
the tool qualification plan (TQP) should describe:
a. based on supplement analysis, which tool qualification objectives are
affected by the use of the technique(s); and
b. how the planned activities satisfy the added or modified objectives.
3. The intent of this subparagraph is to provide clarification of Section MB.6.8.1 of
ED-218/DO-331. If the applicant uses models as defined in Section MB.1.0 of ED-
218/DO-331 as the basis for developing software, the applicant should apply the
guidance of ED-218/DO-331. When applying Section MB.6.8.1 of ED-218/DO-331,
the applicant should do the following:
a. identify which review and analysis objectives are planned to be satisfied by
simulation alone or in combination with reviews and analyses; all other
objectives should be satisfied by reviews and analyses, as described in
Section MB.6.3 of ED-218/DO-331; and
b. for each identified objective, justify in detail how the simulation activity,
alone or in combination with reviews and analyses, fully satisfies the specific
review and analysis objective.
b. Guidance on field-loadable software (FLS)
This Section supplements ED-12C/DO-178C and ED-12B/DO-178B. The applicant should
use this guidance in addition to ED-12C/DO-178C and ED-12B/DO-178B when using FLS
in their project.
1. As the developer, the applicant should provide the necessary information to
support the system-level guidance identified in items a, b, c and d of ED-12C/DO-
178C, Section 2.5.5, and items a, b, c and d of ED-12B/DO-178B, Section 2.5.
2. The FLS should be protected against corruption or partial loading at an integrity
level appropriate for the FLS software level.

AMC 20-115D
3. The FLS part number, when loaded in the airborne equipment, should be verifiable
by appropriate means.
4. Protection mechanisms should be implemented to prevent inadvertent enabling of
the field-loading function during cruising or any other safety-critical phase.
c. Guidance on user-modifiable software (UMS)
This Section supplements ED-12C/DO-178C and ED-12B/DO-178B. The applicant should
use this guidance in addition to ED-12C/DO-178C and ED-12B/DO-178B when using UMS
in their project.
1. As the developer, the applicant should provide the necessary information to
support the system-level guidance identified in items a, b, c and f of ED-12C/DO-
178C, Section 2.5.2, and items a and b of ED-12B/DO-178B, Section 2.4.
2. The modifiable part of the software should be developed at a software level at
least as high as the software level assigned to that software.
9. MODIFYING AND REUSING SOFTWARE APPROVED USING ED-12/DO-178, ED-12A/DO-178A,
OR ED-12B/DO-178B
a. EASA previously approved the software for many airborne systems using ED-12/DO-178,
ED-12A/DO-178A, or ED-12B/DO-178B as a means of compliance. In this AMC, reference
to legacy software includes the previously approved software or component(s) that
makes up the software used in legacy systems. In this subparagraph, it is described how
to demonstrate compliance with the software aspects of certification for an application
that includes modifications to legacy software or the use of unmodified legacy software.
b. Figure 1 presents a flow chart for using legacy software. The applicant should use the flow
chart while following the procedures in this subparagraph if the applicant modifies or
reuses legacy software. Although these procedures apply to the majority of projects, the
applicant should coordinate with EASA any cases that do not follow this flow.

AMC 20-115D
Figure 1 — Legacy software process flow chart
Intent to use software

previously shown to satisfy
ED-12, ED-12A, or ED-12B. Conduct a CIA.
See 9(b)(4).
Evaluate software usage

history, SDs, ADs, OPRs, etc.
See 9(b)(1). Will Determine tool
there be new software Yes qualification
tools or changes to tools? requirements.
See 9(b)(5). See Section 10.
Correct process
Is the deficiencies and
software usage history No document plan for No
acceptable? resolving related
See 9(b)(1). software deficiencies.
See 9(b)(1). Did you
upgrade the Yes
Yes
software baseline to
ED-12C IAW paragraph
9(b)(2)(a), (b), or (c)?
See 9(b)(6).
Is the
software developed using No
No
ED-12B?
See 9(b)(2).
If MBD,
Yes OOT, or FM will No
be used, do processes support
the technique IAW applicable
guidance?
See 9(b)(7)(a).
Is the Is the
ED-12B ED-12 or Yes
Yes
software level ED-12A software level Yes
acceptable? acceptable?
See 9(b)(2). See 9(b)(2).
Have
No No the software plans No
and environment been
properly maintained?
Upgrade software baseline Upgrade software baseline See 9(b)(7)(b).
including all processes & including all processes &
procedures using ED-12B or use procedures using ED-12C
ED-12C and ED-215. and ED-215. Yes
See 9(b)(2)(c). See 9(b)(2)(a) or (b).
Do you want
to declare equivalence to Yes
ED-12C?
See 9(b)(7)(c).
No Upgrade software baseline

Is including all processes &
the legacy system Yes procedures using ED-12C
software to be modified? and ED-215.
See 9(b)(3). See 9(b)(9).
Change software and

Acronyms associated life cycle data using the
No
ADs — airworthiness directives same ED-12 version as the original
CIA — change impact analysis approval. For configuration
FMs — formal methods data/PDI, use an approved process or Change software and
Original approval basis or IAW — in accordance with establish new process using ED-12C. associated life cycle data using
baseline upgrade to ED-12C MBD — model-based development See 9(b)(8)(a) & (b). ED-12C, Section 12.1, and applicable
acceptable as approval basis. OOT — object-oriented technology supplements.
See 9(b)(3)(a) or (b). OPRs — open problem reports See 9(b)(6) & (9).
PDI — parameter data item
SDs — service difficulties
Note: references to RTCA documents are intentionally omitted for formatting purposes.

AMC 20-115D
1. The applicant should assess the legacy software to be modified or reused for its
usage history from previous installations. If the software has safety-related service
difficulties, airworthiness directives, or OPRs with a potential safety impact on the
proposed installation, the applicant should establish plans to resolve all related
software deficiencies. Prior to modifying or reusing the legacy software, the
applicant should correct any related development process deficiencies, such as
those discovered during internal or external audits or reviews, or identified in OPRs
resulting in non-satisfaction of one or more ED-12B/DO-178B objectives. Evidence
of resolution and closure of all process-related OPRs and of all process-related
audit or review findings may be requested.
2. The system safety process assigns the minimum development assurance level
based on the severity classifications of failure conditions for a given function. The
ED-12B/DO-178B software levels are consistent with the ED-12C/DO-178C
software levels. However, ED-12/DO-178 and ED-12A/DO-178A were published
prior to the establishment of the software levels addressed in ED-12B/DO-178B
and ED-12C/DO-178C. The applicant should use Table 1 to determine whether their
legacy software level satisfies the software level assigned by the system safety
process for the proposed installation. A ‘✓’ in the intersection of the row and
column indicates that the legacy software level is acceptable. For example, legacy
software with development assurance for ED-12A/DO-178A software Level 2 can
be considered to satisfy software Levels B, C, and D. A blank indicates that the
software level is not acceptable. Therefore, the ED-12A/DO-178A software
developed for software Level 2 would not be acceptable where software Level A is
required.
Table 1 — Software level relationships
Assigned Legacy software level per Legacy software level per Legacy software Level
software ED-12B ED-12A per ED-12
level A B C D 1 2 3 Critical Essential Non-Essential
A ✓ ✓ ✓
B ✓ ✓ ✓ ✓ ✓
C ✓ ✓ ✓ ✓ ✓ ✓ ✓
D ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
a. If the legacy software was developed at software level ‘Essential’ using ED-
12/DO-178 and was previously accepted by the certification authority as
acceptable for software Level B, it remains acceptable for the new project.
If the ED-12/DO-178 legacy software was not previously assessed, or the
software level is not acceptable, then the applicant should upgrade the
software development baseline, including all processes and procedures (as
well as tool qualification processes), using Section 12.1.4 of ED-12C/DO-
178C, and ED-215/DO-330.
b. If the legacy software was developed using ED-12A/DO-178A, and the
software level is not acceptable, the applicant should upgrade the software
development baseline, including all processes and procedures (as well as
tool qualification processes), using Section 12.1.4 of ED-12C/DO-178C, and
ED-215/DO-330.

AMC 20-115D
c. If the legacy software was developed using ED-12B/DO-178B, and the

software level is not acceptable, the applicant should upgrade the software
development baseline, including all processes and procedures (as well as
tool qualification processes), using Section 12.1.4 of ED-12B/DO-178B or ED-
12C/DO-178C, and ED-215/DO-330.
3. If the criteria of 9(b)(1) and 9(b)(2) are satisfied and modifications to the software
are not required, then:
a. the original approval may serve as the basis for the software in the
installation approval of the proposed system; and
b. if the applicant upgraded the software development baseline using ED-
12C/DO-178C and updated all processes and procedures, as well as tool
qualification processes, to ED-12C/DO-178C and ED-215/DO-330, then the
applicant may declare their software as equivalent to satisfying ED-12C/DO-
178C; however, the applicant cannot declare their unmodified tools as
equivalent to satisfying ED-12C/DO-178C and ED-215/DO-330. The applicant
should make all subsequent modifications to all their software and tools
using their processes and procedures that satisfy ED-12C/DO-178C and ED-
215/DO-330.
4. If modifications to the software are required, the applicant should conduct a
software change impact analysis (CIA) to determine the extent of the
modifications, the impact of those modifications, and what verification is required
to ensure that the modified software performs its intended function and continues
to satisfy the identified means of compliance. The applicant should:
a. identify the software changes to be incorporated and conduct a CIA
consisting of one or more analyses associated with the software change, as
identified in ED-12C/DO-178C, Section 12.1;
b. conduct the verification, as indicated by the CIA; and
c. summarise the results of the CIA in the plan for software aspects of
certification (PSAC) or in the software accomplishment summary (SAS).
5. If new software tools or modifications to tools are needed, please refer to
paragraph 10 of this AMC to determine the tool qualification requirements.
6. If the applicant upgraded the software baseline to ED-12C/DO-178C in accordance
with subparagraph 9(b)(2), they should make all modifications to the software
using ED-12C/DO-178C, Section 12.1. If the applicant wants to declare their
software as equivalent to satisfying ED-12C/DO-178C, the applicant’s equivalence
declaration applies to both modified and unmodified software and is valid even if
the applicant uses unmodified tools that have not been qualified using ED-12C/DO-
178C. However, the applicant cannot declare their unmodified tools as equivalent
to satisfying ED-12C/DO-178C and ED-215/DO-330. All subsequent modifications
to all their software and tools are to be made using processes and procedures
satisfying ED-12C/DO-178C and ED-215/DO-330.
7. If the applicant wants to use their existing processes to make modifications to their
legacy software using the version of ED-12/DO-178 (i.e. ED-12/DO-178, ED-
12A/DO-178A, or ED-12B/DO-178B) used for the original software approval, the
applicant may do so, provided that all of the following conditions are met:

AMC 20-115D
a. If MBD, OOT, or FMs are to be used, existing processes incorporating these

methods should have been evaluated and found to be acceptable by EASA
on a previous certified project. These processes should have been developed
in accordance with EASA guidance specific to the technique, such as that
contained in an associated CRI or a published CM.
b. The applicant has maintained, and can still use, the software plans,
processes, and life cycle environment, including improvements to processes
or to the life cycle environment as captured in revised plans.
c. The applicant does not intend to declare the proposed software as satisfying
ED-12C/DO-178C.
8. If the conditions of subparagraph 9(b)(7) are satisfied:
a. the applicant may accomplish all modifications to the software using the
same ED-12/DO-178 version as for the original approval. However, the
applicant may not declare their software as equivalent to satisfying ED-
12C/DO-178C; and
b. if configuration data is used, as defined under ‘Parameter data item’ in
ED-12C/DO-178C, the applicant may use existing processes for such data if
the processes were evaluated and found to be acceptable by EASA on a
previous certified project; in the absence of processes for using
configuration data, the applicant should establish new processes for using
parameter data items (PDIs) in accordance with ED-12C/DO-178C.
9. If any of the conditions of subparagraph 9(b)(7) is not satisfied, the applicant
should update all their processes and procedures, as well as tool qualification
processes, using ED-12C/DO-178C and ED-215/DO-330, and make all modifications
to the software using ED-12C/DO-178C, Section 12.1. If the applicant wants to
declare their software as equivalent to satisfying ED-12C/DO-178C, their
declaration applies to both the modified and unmodified software and is valid even
if the applicant uses unmodified tools that have not been qualified using
ED-12C/DO-178C and ED-215/DO-330. However, the applicant cannot declare
their unmodified tools as equivalent to satisfying ED-12C/DO-178C and ED-
215/DO-330. The applicant should make all subsequent modifications to all their
software and tools using their processes and procedures that satisfy ED-12C/DO-
178C and ED-215/DO-330.
10. TOOL QUALIFICATION
Sections 12.2 of ED-12C/DO-178C and ED-215/DO-330 provide an acceptable method for tool
qualification. ED-215/DO-330 contains its own complete set of objectives, activities, and life
cycle data for tool qualification.
a. If the applicant’s legacy software was previously approved using ED-12/DO-178 or ED-
12A/DO-178A, and the applicant intends to use a new or modified tool for modifications
to the legacy software, they should use the criteria of ED-12C/DO-178C, Section 12.2 to
determine whether tool qualification is needed. If the applicant needs to qualify the tool,
they should use the software level assigned by the system safety assessment for
determining the required TQL, and should use ED-215/DO-330 for the applicable
objectives, activities, and life cycle data. The applicant may declare their qualified tool as
satisfying ED-215/DO-330, but not the legacy software as equivalent to satisfying
ED-12C/DO-178C.

AMC 20-115D
b. If the applicant’s legacy software was previously approved using ED-12B/DO-178B, and
they do not intend to declare equivalence to satisfying ED-12C/DO-178C, the applicant
can either:
1. use their ED-12B/DO-178B tool qualification processes for qualifying new or
modified tools in support of modifications to ED-12B/DO-178B legacy software, or
2. update their tool qualification processes and qualify the tool using ED 215/DO-330,
referring to Table 2 of this document for determining the required TQL; the
applicant may then declare their qualified tool as satisfying ED-215/DO-330.
c. If the applicant’s legacy software was previously approved using ED-12B/DO-178B, the
applicant intends to declare equivalence to satisfying ED-12C/DO-178C, and has ED-
12B/DO-178B legacy tools that need to be qualified, the applicant should follow the
guidance of this subparagraph.
1. ED-12C/DO-178C establishes five levels of tool qualification based on the tool use
and its potential impact on the software life cycle processes (see Section 12.2.2
and Table 12-1 of ED-12C/DO-178C). However, ED-12C/DO-178C does not address
the use of tools previously qualified according to the ED-12B/DO-178B criteria. For
a tool previously qualified as an ED-12B/DO-178B development tool or verification
tool, the applicant should use Table 2 below to determine the correlation between
the ED-12B/DO-178B tool qualification type and the ED-12C/DO-178C tool criteria
and TQLs.
Table 2 — Correlation between ED-12B/DO-178B tool qualification type
and ED-12C/DO-178C tool criteria and TQLs
ED-12B/DO-178B Software ED-12C/DO-178C ED-12C/ED-215

Tool Qualification Type Level Tool Criteria TQL
Development A 1 TQL-1
Development B 1 TQL-2
Development C 1 TQL-3
Development D 1 TQL-4
Verification A, B 2 TQL-4
Verification C, D 2 TQL-5
Verification All 3 TQL-5
2. Development tools previously qualified using ED-12B/DO-178B

a. If the ED-12B/DO-178B software level assigned to the tool correlates with or
exceeds the required TQL established by ED-12C/DO-178C, the applicant
may continue to use their ED-12B/DO-178B tool qualification processes. If
there are changes to the tool’s operational environment or to the tool itself,
then the applicant should conduct a tool CIA in accordance with Section
11.2.2 or 11.2.3 of ED-215/DO-330, respectively, and perform changes using
their ED-12B/DO-178B tool qualification processes.
b. If the ED-12B/DO-178B software level assigned to the tool does not satisfy
the required TQL, the applicant should update their tool qualification
processes and requalify the tool using ED-215/DO-330.

AMC 20-115D
c. The applicant may declare their tool as equivalent to satisfying ED-215/DO-

330 if all the changes to the tool and to their tool qualification processes
satisfy ED-215/DO-330.
3. Verification tools previously qualified using ED-12B/DO-178B
a. If TQL-5 is required, and the applicant’s verification tool was previously
qualified using
ED-12B/DO-178B:
i. the applicant may continue to use their ED-12B/DO-178B tool
qualification process; and
ii. If there are changes to the tool or the tool’s operational environment,
the applicant should conduct a tool CIA and reverify the tool using
their ED-12B/DO-178B tool qualification processes or requalify the
tool using ED-215/DO-330.
b. If TQL-4 is required, the applicant should requalify their verification tool
using
ED-215/DO-330.
c. The applicant may declare their tool as equivalent to satisfying ED-215/DO-
330 if all changes to the tool (if applicable) and to their tool qualification
processes satisfy
ED-215/DO-330.
11. RELATED REGULATORY, ADVISORY, AND INDUSTRY MATERIAL
a. Related EASA CSs
1. Decision No. 2003/14/RM of the Executive Director of the Agency of 14 November
2003 on certification specifications, including airworthiness codes and acceptable
means of compliance for normal, utility, aerobatic and commuter category
aeroplanes (‘CS-23’).
2. Decision No. 2003/2/RM of the Executive Director of the Agency of 17 October
means of compliance, for large aeroplanes (‘CS-25’).
2003 on certification specifications for small rotorcraft (‘CS-27’).
2003 on certification specifications for large rotorcraft (‘CS-29’).
means of compliance, for engines (‘CS-E’).
means of compliance, for propellers (‘CS-P’).
means of compliance, for European Technical Standard Orders (‘CS-ETSO’).

AMC 20-115D

means of compliance, for auxiliary power units (‘CS-APU’).
2003 on general acceptable means of compliance for airworthiness of products,
parts and appliances (‘AMC-20’).
b. FAA advisory circulars (ACs)
1. AC 23.1309-1E, System Safety Analysis and Assessment for Part 23 Airplanes, 17
November 2011.
2. AC 27.1309A, Equipment, Systems, and Installations (included in AC 27-1B,
Certification of Normal Category Rotorcraft), 4 February 2016.
3. AC 29.1309A, Equipment, Systems, and Installations (included in AC 29-2C,
Certification of Transport Category Rotorcraft), 4 February 2016.
c. Industry documents
1. EUROCAE ED-12, Software Considerations in Airborne Systems and Equipment
Certification, May 1982 (no longer in print).
2. EUROCAE ED-12A, Software Considerations in Airborne Systems and Equipment
Certification, October 1985 (no longer in print).
3. EUROCAE ED-12B, Software Considerations in Airborne Systems and Equipment
Certification, 1 December 1992.
4. EUROCAE ED-12C, Software Considerations in Airborne Systems and Equipment
Certification, 1 January 2012.
5. EUROCAE ED-94C, Supporting Information for ED-12C and ED-109A,
1 January 2012.
6. EUROCAE ED-215, Software Tool Qualification Considerations, 1 January 2012.
7. EUROCAE ED-216, Formal Methods Supplement to ED-12C and ED-109A,
1 January 2012.
8. EUROCAE ED-217, Object-Oriented Technology and Related Techniques
Supplement to ED-12C and ED-109A, 1 January 2012.
9. EUROCAE ED-218, Model-Based Development and Verification Supplement to ED-
12C and ED-109A, 1 January 2012.
10. RTCA DO-178, Software Considerations in Airborne Systems and Equipment
Certification, January 1982 (no longer in print).
11. RTCA DO-178A, Software Considerations in Airborne Systems and Equipment
Certification, 1 March 1985 (no longer in print).
12. RTCA DO-178B, Software Considerations in Airborne Systems and Equipment
13. RTCA DO-178C, Software Considerations in Airborne Systems and Equipment
14. RTCA DO-248C, Supporting Information for DO-178C and DO-278A,
13 December 2011.

AMC 20-115D
15. RTCA DO-297, Integrated Modular Avionics (IMA) Development Guidance and
Certification Considerations, 8 November 2005.
16. RTCA DO-330, Software Tool Qualification Considerations, 13 December 2011.
17. RTCA DO-331, Model-Based Development and Verification Supplement to DO-
178C and DO-278A, 13 December 2011.
18. RTCA DO-332, Object-Oriented Technology and Related Techniques Supplement to
DO-178C and DO-278A, 13 December 2011.
19. RTCA DO-333, Formal Methods Supplement to DO-178C and DO-278A,
13 December 2011.
12. AVAILABILITY OF DOCUMENTS
1. EASA CSs and AMC are available at: www.easa.europa.eu.
2. FAA ACs are available at: www.faa.gov.
3. EUROCAE are available on payment at:
European Organisation for Civil Aviation Equipment
102 rue Etienne Dolet, 92240 Malakoff, France
Telephone: +33 1 40 92 79 30; Fax +33 1 46 55 62 65
Email: [email protected], website: www.eurocae.net.
4. RTCA documents are available on payment at:
RTCA, Inc.
1150 18th Street NW, Suite 910, Washington DC 20036, USA
Email: [email protected], website: www.rtca.org.
[Amdt 20/14]
GM1 to AMC 20-115D — Software change impact analyses (CIAs)

a. These practices provide complementary information to ED-12C/DO-178C and ED-12B/DO-178B,

Sections 12.1.1, 12.1.2, and 12.1.3, and AMC 20-115D, subparagraph 9(b)(4). The applicant may
use these practices when they need to conduct a software CIA.
b. A CIA identifies the released software baseline upon which the proposed software is to be built,
providing:
1. a summary of the changes and the impact of those changes;
2. a listing and descriptions of the problem reports to be corrected as part of the intended
change and/or change requests related to those changes; and
3. a listing of new functions to be activated and/or implemented.
c. A CIA addresses changes to the following items, where applicable:
1. the software level;
2. the development or verification environment;
3. the software processes;

AMC 20-115D
4. the tools (e.g. when a new tool version is introduced or a tool’s use is modified);
5. the processor or other hardware components and interfaces;
6. the configuration data, especially when activating or deactivating functions;
7. the software interface characteristics and input/output (I/O) requirements; and
8. the software requirements, design, architecture, and code components, where such
changes are not limited to the modified life cycle data, but should also consider the items
affected by the change.
d. For each applicable item of subparagraph 13(c) above, a CIA describes the resulting impact of
the change(s) and identifies the activities to be performed to satisfy ED-12C/DO-178C or ED-
12B/DO-178B and continue to satisfy the requirements for safe operation.
[Amdt 20/14]
GM2 to AMC 20-115D — Clarification of data coupling and control

coupling
These practices provide complementary information to ED-94C/DO-248C FAQ#67 for satisfying

objective A-7 (8) of ED-12C/DO-178C and ED-12B/DO-178B.
a. Data coupling analysis is of a different type and purpose than control coupling analysis. Both
analyses are necessary to satisfy said objective.
b. Although they support a verification objective, data coupling and control coupling analyses rely
on good practices in the software design phase, for example, through the specification of the
interfaces (I/O) and of the dependencies between components.
[Amdt 20/14]
GM3 to AMC 20-115D — Error-handling at design level

a. These practices provide complementary information to ED-12C/DO-178C and ED-12B/DO-178B,

Sections 6.3.2, 6.3.3, and 6.3.4. Section 6.3.4.f., and identifies potential sources of errors that
require specific activities focused at the source code review level. However, in order to protect
against foreseeable unintended software behaviour, it is beneficial and recommended to
handle these sources of error at the design level.
b. The possibility of unintended software behaviour may be reduced by considering the following
activities:
1. identification of foreseeable sources of software errors, which include:
a. runtime exceptions or errors, such as fixed/floating-point arithmetic overflow,
stack/heap overflow, division by zero, or counter and timer overrun/wrap-around;
b. data/memory corruption or timing issues, such as those caused by a lack of
partitioning or improper interrupt management or cache management; and
c. features leading to unpredictable programme execution, such as dynamic
allocation, out-of-order execution, or resource contention;
2. for each foreseeable source of software error, identification of the associated mitigation;

AMC 20-115D
3. specification of protection mechanisms in the software requirements (high-level or low-

level requirements) which should in particular include the specification of error-handling
mechanisms; and
4. for software Levels A and B, it is recommended that consideration be given to
incorporating runtime protection mechanisms since reliance on probabilistic approaches
or static analyses alone may not be appropriate; it may be a good practice to implement
such runtime protection mechanisms for the other software levels as well.
c. The use of FMs in accordance with ED-216/DO-333 may enhance the detection of runtime
errors.
[Amdt 20/14]

AMC 20-128A
AMC 20-128A
AMC 20-128A Design Considerations for Minimizing Hazards Caused

by Uncontained Turbine Engine and Auxiliary Power Unit Rotor
Failure
ED Decision 2003/12/RM
1 PURPOSE.
This acceptable means of compliance (AMC) sets forth a method of compliance with the
requirements of CS 23.901(f), 23.903(b)(1), 25.903(d)(1) and 25A903(d)(1)of the EASA
Certification Specifications (CS) pertaining to design precautions taken to minimise the hazards
to an aeroplane in the event of uncontained engine or auxiliary power unit (APU) rotor failures.
The guidance provided within this AMC is harmonised with that of the Federal Aviation
Administration (FAA) and is intended to provide a method of compliance that has been found
acceptable. As with all AMC material, it is not mandatory and does not constitute a regulation.
2 RESERVED
3 APPLICABILITY.
This AMC applies to CS-23 and CS-25 aeroplanes.
4 RELATED DOCUMENTS.
Paragraphs 23.903, and 25.903 of the CS and other paragraphs relating to uncontained engine
failures.
a. Related Joint Aviation Requirements. Sections which prescribe requirements for the
design, substantiation and certification relating to uncontained engine debris include:
§ 23.863, 25.863 Flammable fluid fire protection
§ 25.365 Pressurised compartment loads
§ 25.571 Damage-tolerance and fatigue evaluation of structure
§ 25.963 Fuel tanks: general
§ 25.1189 Shut-off means
§ 25.1461 Equipment containing high energy rotors
CS-APU Auxiliary Power Units
NOTE: The provisions of § 25.1461 have occasionally been used in the approval of APU
installations regardless of protection from high energy rotor disintegration. However, the
more specific requirements of CS 25.903(d)(1) and associated guidance described within
this AMC take precedence over the requirements of CS 25.1461.
b. Other Documents
ISO 2685:1992 Aircraft – Environmental conditions and test procedures for airborne
equipment – Resistance to fire in designated fire zones
AC 20–135 Powerplant Installation and Propulsion System Component Fire Protection
Test Methods, Standards, and Criteria.
c. Society of Automotive Engineers (SAE) Documents.

AIR1537 Report on Aircraft Engine Containment, October, 1977.
AIR4003 Uncontained Turbine Rotor Events Data Period 1976 through 1983.

AMC 20-128A
AIR4770 Uncontained Turbine Rotor Events Data Period 1984 (Draft) through 1989.
These documents can be obtained from the Society of Automotive Engineers, Inc., 400
Commonwealth Drive, Warrendale, Pennsylvania, 15096.
5 BACKGROUND.
Although turbine engine and APU manufacturers are making efforts to reduce the probability
of uncontained rotor failures, service experience shows that uncontained compressor and
turbine rotor failures continue to occur. Turbine engine failures have resulted in high velocity
fragment penetration of adjacent structures, fuel tanks, fuselage, system components and
other engines on the aeroplane. While APU uncontained rotor failures do occur, and to date the
impact damage to the aeroplane has been minimal, some rotor failures do produce fragments
that should be considered. Since it is unlikely that uncontained rotor failures can be completely
eliminated, CS-23 and CS-25 require that aeroplane design precautions be taken to minimise
the hazard from such events.
a. Uncontained gas turbine engine rotor failure statistics are presented in the Society of
Automotive Engineers (SAE) reports covering time periods and number of uncontained
events listed in the table shown below. The following statistics summarise 28 years of
service experience for fixed wing aeroplanes and do not include data for rotorcraft and
APUs:
No. of Events
Report No. Period Total Category 3 Category 4
AIR1537 1962–75 275 44 5
AIR4003 1976–83 237 27 3
AIR4770 (Draft) 1984–89 164 22 7
TOTAL 676 93 15
The total of 676 uncontained events includes 93 events classified in Category 3 and 15
events classified in Category 4 damage to the aeroplane. Category 3 damage is defined
as significant aeroplane damage with the aeroplane capable of continuing flight and
making a safe landing. Category 4 damage is defined as severe aeroplane damage
involving a crash landing, critical injuries, fatalities or hull loss.
During this 28 year period there were 1,089.6 million engine operating hours on
commercial transports. The events were caused by a wide variety of influences classed
as environmental (bird ingestion, corrosion/erosion, foreign object damage (FOD)),
manufacturing and material defects, mechanical, and human factors (maintenance and
overhaul, inspection error and operational procedures).
b. Uncontained APU rotor failure statistics covering 1962 through 1993 indicate that there
have been several uncontained failures in at least 250 million hours of operation on
transport category aeroplanes. No Category 3 or 4 events were reported and all failures
occurred during ground operation. These events were caused by a wide variety of
influences such as corrosion, ingestion of de-icing fluid, manufacturing and material
defects, mechanical, and human factors (maintenance and overhaul, inspection error and
operational procedures).
c. The statistics in the SAE studies indicate the existence of many different causes of failures
not readily apparent or predictable by failure analysis methods. Because of the variety of
causes of uncontained rotor failures, it is difficult to anticipate all possible causes of
failure and to provide protection to all areas. However, design considerations outlined in

AMC 20-128A
this AMC provide guidelines for achieving the desired objective of minimising the hazard
to an aeroplane from uncontained rotor failures. These guidelines, therefore, assume a
rotor failure will occur and that analysis of the effects of this failure is necessary. These
guidelines are based on service experience and tests but are not necessarily the only
means available to the designer.
6 TERMINOILOGY.
a. Rotor. Rotor means the rotating components of the engine and APU that analysis, test,
and/or experience has shown can be released during uncontained failure. The engine or
APU manufacturer should define those components that constitute the rotor for each
engine and APU type design. Typically rotors have included, as a minimum, discs, hubs,
drums, seals, impellers, blades and spacers.
b. Blade. The airfoil sections (excluding platform and root) of the fan, compressor and
turbine.
c. Uncontained Failure. For the purpose of aeroplane evaluations in accordance with this
AMC, uncontained failure of a turbine engine is any failure which results in the escape of
rotor fragments from the engine or APU that could result in a hazard. Rotor failures which
are of concern are those where released fragments have sufficient energy to create a
hazard to the aeroplane.
d. Critical Component. A critical component is any component whose failure would
contribute to or cause a failure condition which would prevent the continued safe flight
and landing of the aeroplane. These components should be considered on an individual
basis and in relation to other components which could be damaged by the same fragment
or by other fragments from the same uncontained event.
e. Continued Safe Flight and Landing. Continued safe flight and landing means that the
aeroplane is capable of continued controlled flight and landing, possibly using emergency
procedures and without exceptional pilot skill or strength, with conditions of considerably
increased flightcrew workload and degraded flight characteristics of the aeroplane.
f. Fragment Spread Angle. The fragment spread angle is the angle measured, fore and aft
from the centre of the plane of rotation of an individual rotor stage, initiating at the
engine or APU shaft centreline (see Figure 1).

AMC 20-128A
FIGURE 1 – ESTIMATED PATH OF FRAGMENTS
g. Impact Area. The impact area is that area of the aeroplane likely to be impacted by
uncontained fragments generated during a rotor failure (see Paragraph 9).
h. Engine and APU Failure Model. A model describing the size, mass, spread angle, energy
level and number of engine or APU rotor fragments to be considered when analysing the
aeroplane design is presented in Paragraph 9.
7 DESIGN CONSIDERATIONS.
Practical design precautions should be used to minimise the damage that can be caused by
uncontained engine and APU rotor fragments. The most effective methods for minimising the
hazards from uncontained rotor fragments include location of critical components outside the
fragment impact areas or separation, isolation, redundancy, and shielding of critical aeroplane
components and/or systems. The following design considerations are recommended:
a. Consider the location of the engine and APU rotors relative to critical components,
systems or areas of the aeroplane such as:
(1) Any other engine(s) or an APU that provides an essential function;
(2) Pressurised sections of the fuselage and other primary structure of the fuselage,
wings and empennage;
(3) Pilot compartment areas;
(4) Fuel system components, piping and tanks;
(5) Control systems, such as primary and secondary flight controls, electrical power
cables, wiring, hydraulic systems, engine control systems, flammable fluid shut-off
valves, and the associated actuation wiring or cables;

AMC 20-128A
(6) Any fire extinguisher system of a cargo compartment, an APU, or another engine
including electrical wiring and fire extinguishing agent plumbing to these systems;
(7) Engine air inlet attachments and effects of engine case deformations caused by fan
blade debris resulting in attachment failures;
(8) Instrumentation essential for continued safe flight and landing;
(9) Thrust reverser systems where inadvertent deployment could be catastrophic; and
(10) Oxygen systems for high altitude aeroplanes, where these are critical due to
descent time.
b. Location of Critical Systems and Components. Critical aeroplane flight and engine control
cables, wiring, flammable fluid carrying components and lines (including vent lines),
hydraulic fluid lines and components, and pneumatic ducts should be located to minimise
hazards caused by uncontained rotors and fan blade debris. The following design
practices should be considered:
(1) Locate, if possible, critical components or systems outside the likely debris impact
areas.
(2) Duplicate and separate critical components or systems, or provide suitable
protection if located in debris impact areas.
(3) Protection of critical systems and components can be provided by using airframe
structure or supplemental shielding.
These methods have been effective in mitigating the hazards from both single and
multiple small fragments within the ± 15 impact area. Separation of multiplicated
critical systems and components by at least a distance equal to the 1/2 blade
fragment dimension has been accepted for showing minimisation from a single
high energy small fragment when at least one of the related multiplicated critical
components is shielded by significant structure such as aluminium lower wing
skins, pylons, aluminium skin of the cabin pressure vessel, or equivalent structures.
Multiplicated critical systems and components positioned behind less significant
structures should be separated by at least a distance equal to the 1/2 blade
fragment dimension, and at least one of the multiplicated critical systems should
be:
(i) Located such that equivalent protection is provided by other inherent
structures such as pneumatic ducting, interiors, bulkheads, stringers, or
(ii) Protected by an additional shield such that the airframe structure and shield
material provide equivalent shielding.
(4) Locate fluid shut-offs and actuation means so that flammable fluid can be isolated
in the event of damage to the system.
(5) Minimise the flammable fluid spillage which could contact an ignition source.
(6) For airframe structural elements, provide redundant designs or crack stoppers to
limit the subsequent tearing which could be caused by uncontained rotor
fragments.
(7) Locate fuel tanks and other flammable fluid systems and route lines (including vent
lines) behind aeroplane structure to reduce the hazards from spilled fuel or from

AMC 20-128A
tank penetrations. Fuel tank explosion-suppression materials, protective shields or

deflectors on the fluid lines, have been used to minimise the damage and hazards.
c. External Shields and Deflectors. When shields, deflection devices or aeroplane structure
are proposed to be used to protect critical systems or components, the adequacy of the
protection, including mounting points to the airframe structure, should be shown by
testing or validated analyses supported by test data, using the fragment energies supplied
by the engine or APU manufacturer or those defined in Paragraph 9. For protection
against engine small fragments, as defined in Paragraph 9, no quantitative validation as
defined in Paragraph 10 is required if equivalency to the penetration resistant structures
listed (e.g. pressure cabin skins, etc.) is shown.
8 ACCEPTED DESIGN PRECAUTIONS.
Design practices currently in use by the aviation industry that have been shown to reduce the
overall risk, by effectively eliminating certain specific risks and reducing the remaining specific
risks to a minimum level, are described within this paragraph of the AMC. Aeroplane designs
submitted for evaluation by the regulatory authorities will be evaluated against these proven
design practices.
a. Uncontrolled Fire.
(1) Fire Extinguishing Systems. The engine/APU fire extinguishing systems currently in
use rely on a fire zone with a fixed compartment air volume and a known air
exchange rate to extinguish a fire. The effectiveness of this type of system along
with firewall integrity may therefore be compromised for the torn/ruptured
compartment of the failed engine/APU. Protection of the aeroplane following this
type of failure relies on the function of the fire warning system and subsequent fire
switch activation to isolate the engine/APU from airframe flammable fluid (fuel and
hydraulic fluid) and external ignition sources (pneumatic and electrical). Fire
extinguishing protection of such a compromised system may not be effective due
to the extent of damage. Continued function of any other engine, APU or cargo
compartment fire warning and extinguisher system, including electrical wiring and
fire extinguishing agent plumbing, should be considered as described in
Paragraph 7.
(2) Flammable Fluid Shut-off Valve. As discussed above, shut-off of flammable fluid
supply to the engine may be the only effective means to extinguish a fire following
an uncontained failure, therefore the engine isolation/flammable fluid shut-off
function should be assured following an uncontained rotor failure. Flammable fluid
shut-off valves should be located outside the uncontained rotor impact area. Shut-
off actuation controls that need to be routed through the impact area should be
redundant and appropriately separated in relation to the one-third disc maximum
dimension.
(3) Fire Protection of Critical Functions. Flammable fluid shut-off and other critical
controls should be located so that a fire (caused by an uncontained rotor event)
will not prevent actuation of the shut- off function or loss of critical aeroplane
functions. If shut-off or other critical controls are located where a fire is possible
following an uncontained rotor failure (e.g. in compartments adjacent to fuel
tanks) then these items should meet the applicable fire protection guidelines such
as ISO 2685:1992 or AC 20-135.
(4) Fuel Tanks. If fuel tanks are located in impact areas, the following precautions
should be implemented:

AMC 20-128A
(i) Protection from the effects of fuel leakage should be provided for any fuel
tanks located above an engine or APU and within the one-third disc and
intermediate fragment impact areas. Dry bays or shielding are acceptable
means. The dry bay should be sized based on analysis of possible fragment
trajectories through the fuel tank wall and the subsequent fuel leakage from
the damaged fuel tank so that fuel will not migrate to an engine, APU or
other ignition source during either – flight or ground operation. A minimum
drip clearance distance of 10 inches (254 mm) from potential ignition
sources of the engine nacelle, for static conditions, has been acceptable (see
Figure 2).

AMC 20-128A
FIGURE 2 – DRY BAY SIZING DETERMINATION EXAMPLE
(ii) Fuel tank penetration leak paths should be determined and evaluated for
hazards during flight and ground phases of operation. If fuel spills into the

AMC 20-128A
airstream away from the aeroplane no additional protection is needed.

Additional protection should be considered if fuel could spill, drain or
migrate into areas housing ignition sources, such as engine or APU inlets or
wheel wells. Damage to adjacent systems, wiring etc., should be evaluated
regarding the potential that an uncontained fragment will create both an
ignition source and fuel source. Wheel brakes may be considered as an
ignition source during take-off and initial climb. Protection of the wheel wells
may be provided by airflow discharging from gaps or openings, preventing
entry of fuel, a ventilation rate precluding a combustible mixture or other
provisions indicated in CS 23.863 and CS 25.863.
(iii) Areas of the aeroplane where flammable fluid migration is possible that are
not drained and vented and have ignition sources or potential ignition
sources should be provided with a means of fire detection and suppression
and be explosion vented or equivalently protected.
b. Loss of Thrust.
(1) Fuel Reserves. The fuel reserves should be isolatable such that damage from a disc
fragment will not result in loss of fuel required to complete the flight or a safe
diversion. The effects of fuel loss, and the resultant shift of centre of gravity or
lateral imbalance on aeroplane controllability should also be considered.
(2) Engine Controls. Engine control cables and/or wiring for the remaining
powerplants that pass through the impact area should be separated by a distance
equal to the maximum dimension of a one- third disc fragment or the maximum
extent possible.
(3) Other Engine Damage. Protection of any other engines from some fragments
should be provided by locating critical components, such as engine accessories
essential for proper engine operation (e.g., high pressure fuel lines, engine controls
and wiring, etc.), in areas where inherent shielding is provided by the fuselage,
engine or nacelle (including thrust reverser) structure (see Paragraph 7).
c. Loss of Aeroplane Control
(1) Flight Controls. Elements of the flight control system should be adequately
separated or protected so that the release of a single one-third disc fragment will
not cause loss of control of the aeroplane in any axis. Where primary flight controls
have duplicated (or multiplicated) elements, these elements should be located to
prevent all elements in any axis being lost as a result of the single one- third disc
fragment. Credit for maintaining control of the aeroplane by the use of trim
controls or other means may be obtained, providing evidence shows that these
means will enable the pilot to retain control.
(2) Emergency Power. Loss of electrical power to critical functions following an
uncontained rotor event should be minimised. The determination of electrical
system criticality is dependent upon aeroplane operations. For example,
aeroplanes approved for Extended Twin Engine Operations (ETOPS) that rely on
alternate power sources such as hydraulic motor generators or APUs may be
configured with the electrical wiring separated to the maximum extent possible
within the one-third disc impact zone.
(3) Hydraulic Supply. Any essential hydraulic system supply that is routed within an
impact area should have means to isolate the hydraulic supply required to maintain

AMC 20-128A
control of the aeroplane. The single one-third disc should not result in loss of all
essential hydraulic systems or loss of all flight controls in any axis of the aeroplane.
(4) Thrust reverser systems. The effect of an uncontained rotor failure on inadvertent
in-flight deployment of each thrust reverser and possible loss of aeroplane control
shall be considered. The impact area for components located on the failed engine
may be different from the impact area defined in Paragraph 6. If uncontained
failure could cause thrust reverser deployment, the engine manufacturer should
be consulted to establish the failure model to be considered. One acceptable
method of minimisation is to locate reverser restraints such that not all restraints
can be made ineffective by the fragments of a single rotor.
d. Passenger and Crew Incapacitation.
(1) Pilot Compartment. The pilot compartment of large aeroplanes should not be
located within the ± 15° spread angle of any engine rotor stage or APU rotor stage
that has not been qualified as contained, unless adequate shielding, deflectors or
equivalent protection is provided for the rotor stage in accordance with Paragraph
7c. Due to design constraints inherent in smaller CS-23 aeroplanes, it is not
considered practical to locate the pilot compartment outside the ±15° spread
angle. Therefore for other aeroplanes (such as new CS-23 commuter category
aeroplanes) the pilot compartment area should not be located within the ±5°
spread angle of any engine rotor stage or APU rotor stage unless adequate
shielding, deflectors, or equivalent protection is provided for the rotor stage in
accordance with Paragraph 7c of this AMC, except for the following:
(i) For derivative CS-23 category aeroplanes where the engine location has
been previously established, the engine location in relation to the pilot
compartment need not be changed.
(ii) For non-commuter CS-23 category aeroplanes, satisfactory service
experience relative to rotor integrity and containment in similar engine
installations may be considered in assessing the acceptability of installing
engines in line with the pilot compartment.
(iii) For non-commuter new CS-23 category aeroplanes, where due to size
and/or design considerations the ± 5° spread angle cannot be adhered to,
the pilot compartment/engine location should be analysed and accepted in
accordance with Paragraphs 9 and 10.
(2) Pressure Vessel. For aeroplanes that are certificated for operation above 41,000
feet, the engines should be located such that the pressure cabin cannot be affected
by an uncontained one- third or intermediate disc fragment. Alternatively, it may
be shown that rapid decompression due to the maximum hole size caused by
fragments within the ± 15° zone and the associated cabin pressure decay rate will
allow an emergency descent without incapacitation of the flightcrew or
passengers. A pilot reaction time of 17 seconds for initiation of the emergency
decent has been accepted. Where the pressure cabin could be affected by a one-
third disc or intermediate fragments, design precautions should be taken to
preclude incapacitation of crew and passengers. Examples of design precautions
that have been previously accepted are:
(i) Provisions for a second pressure or bleed down bulkhead outside the impact
area of a one- third or intermediate disc fragment.

AMC 20-128A
(ii) The affected compartment in between the primary and secondary bulkhead
was made inaccessible, by operating limitations, above the minimum
altitude where incapacitation could occur due to the above hole size.
(iii) Air supply ducts running through this compartment were provided with non-
return valves to prevent pressure cabin leakage through damaged ducts.
NOTE: If a bleed down bulkhead is used it should be shown that the rate of pressure
decay and minimum achieved cabin pressure would not incapacitate the crew, and
the rate of pressure decay would not preclude a safe emergency descent.
e. Structural Integrity. Installation of tear straps and shear ties within the uncontained fan
blade and engine rotor debris zone to prevent catastrophic structural damage has been
utilised to address this threat.
9. ENGINE AND APU FAILURE MODEL.
The safety analysis recommended in Paragraph 10 should be made using the following engine
and APU failure model, unless for the particular engine/APU type concerned, relevant service
experience, design data, test results or other evidence justify the use of a different model.
a. Single One-Third Disc fragment. It should be assumed that the one-third disc fragment
has the maximum dimension corresponding to one-third of the disc with one-third blade
height and a fragment spread angle of ± 3°. Where energy considerations are relevant,
the mass should be assumed to be one-third of the bladed disc mass and its energy, the
translational energy (i.e., neglecting rotational energy) of the sector travelling at the
speed of its c.g. location as defined in Figure 3.
b. Intermediate Fragment. It should be assumed that the intermediate fragment has a
maximum dimension corresponding to one-third of the bladed disc radius and a fragment
spread angle of ± 5°. Where energy considerations are relevant, the mass should be
assumed to be 1/30 of the bladed disc mass and its energy the transitional energy
(i.e. neglecting rotational energy) of the piece travelling at rim speed (see Figure 4).

AMC 20-128A
FIGURE 3 – SINGLE ONE-THIRD ROTOR FRAGMENT

AMC 20-128A
FIGURE 4 – INTERMEDIATE FRAGMENT
c. Alternative Engine Failure Model. For the purpose of the analysis, as an alternative to the
engine failure model of Paragraphs 9a and b, the use of a single one-third piece of disc
having a fragment spread angle ± 5° would be acceptable, provided the objectives of
Paragraph 10c are satisfied.
d. Small Fragments. It should be assumed that small fragments (shrapnel) range in size up
to a maximum dimension corresponding to the tip half of the blade airfoil (with exception
of fan blades) and a fragment spread angle of ± 15°. Service history has shown that
aluminium lower wing skins, pylons, and pressure cabin skin and equivalent structures
typically resist penetration from all but one of the most energetic of these fragments. The
effects of multiple small fragments should also be considered. Penetration of less
significant structures such as fairings, empennage, control surfaces and unpressurised
unpressurized skin has typically occurred at the rate of 2½ percent of the number of
blades of the failed rotor stage. Refer to paragraph 7b and 7c for methods of minimisation
of the hazards. Where the applicant wishes to show compliance by considering the
energy required for penetration of structure (or shielding) the engine manufacturer
should be consulted for guidance as to the size and energy of small fragments within the
impact area.
For APUs, where energy considerations are relevant, it should be assumed that the mass
will correspond to the above fragment dimensions and that it has a translational energy
level of one percent of the total rotational energy of the original rotor stage.
e. Fan Blade Fragment. It should be assumed that the fan blade fragment has a maximum
dimension corresponding to the blade tip with one-third the blade airfoil height and a
fragment spread angle of ± 15°. Where energy considerations are relevant the mass

AMC 20-128A
should be assumed to be corresponding to the one-third of the airfoil including any part
span shroud and the transitional energy (neglecting rotational energy) of the fragment
travelling at the speed of its c.g. location as defined in Figure 5. As an alternative, the
engine manufacturer may be consulted for guidance as to the size and energy of the
fragment.
FIGURE 5 – FAN BLADE FRAGMENT DEFINITION
f. Critical Engine Speed. Where energy considerations are relevant, the uncontained rotor
event should be assumed to occur at the engine or APU shaft red line speed.
g. APU Failure Model. For all APU's, the installer also needs to address any hazard to the
aeroplane associated with APU debris (up to and including a complete rotor where
applicable) exiting the tailpipe. Paragraphs 9g(1) or (2) below or applicable service history
provided by the APU manufacturer may be used to define the size, mass, and energy of
debris exiting that tailpipe. The APU rotor failure model applicable for a particular APU
installation is dependent upon the provisions of CS-APU that were utilised for receiving
approval:

AMC 20-128A
(1) For APU's where rotor integrity has been demonstrated in accordance with CS-
APU, i.e. without specific containment testing, Paragraphs 9a, b, and d, or
Paragraphs 9c and 9d apply.
(2) For APU rotor stages qualified as contained in accordance with CS-APU, historical
data shows that in-service uncontained failures have occurred. These failure
modes have included bi-hub, overspeed, and fragments missing the containment
ring which are not addressed by the CS-APU containment test. In order to address
these hazards, the installer should use the APU small fragment definition of
Paragraph 9d or substantiated in-service data supplied by the APU manufacturer.
10 SAFETY ANALYSIS.
The numerical assessment requested in Paragraph 10c(3) is derived from methods previously
prescribed in ACJ No. 2 to CS 25.903(d)(1). The hazard ratios provided are based upon evaluation
of various configurations of large aeroplanes, made over a period of time, incorporating
practical methods of minimising the hazard to the aeroplane from uncontained engine debris.
a. Analysis. An analysis should be made using the engine/APU model defined in Paragraph
9 to determine the critical areas of the aeroplane likely to be damaged by rotor debris
and to evaluate the consequences of an uncontained failure. This analysis should be
conducted in relation to all normal phases of flight, or portions thereof.
NOTE: APPENDIX 1 provides additional guidance for completion of the numerical analysis
requested by this paragraph.
(1) A delay of at least 15 seconds should be assumed before start of the emergency
engine shut down. The extent of the delay is dependent upon circumstances
resulting from the uncontained failure including increased flightcrew workload
stemming from multiplicity of warnings which require analysis by the flightcrew.
(2) Some degradation of the flight characteristics of the aeroplane or operation of a
system is permissible, provided the aeroplane is capable of continued safe flight
and landing. Account should be taken of the behaviour of the aeroplane under
asymmetrical engine thrust or power conditions together with any possible
damage to the flight control system, and of the predicted aeroplane recovery
manoeuvre.
(3) When considering how or whether to mitigate any potential hazard identified by
the model, credit may be given to flight phase, service experience, or other data,
as noted in Paragraph 7.
b. Drawings. Drawings should be provided to define the uncontained rotor impact threat
relative to the areas of design consideration defined in Paragraphs 7a(1) through (10)
showing the trajectory paths of engine and APU debris relative to critical areas. The
analysis should include at least the following:
(1) Damage to primary structure including the pressure cabin, engine/APU mountings
and airframe surfaces.
NOTE: Any structural damage resulting from uncontained rotor debris should be
considered catastrophic unless the residual strength and flutter criteria of ACJ
25.571(a) subparagraph 2.7.2 can be met without failure of any part of the
structure essential for completion of the flight. In addition, the pressurised
compartment loads of CS 25.365(e)(1) and (g) must be met.

AMC 20-128A
(2) Damage to any other engines (the consequences of subsequent uncontained

debris from the other engine(s), need not be considered).
(3) Damage to services and equipment essential for safe flight and landing (including
indicating and monitoring systems), particularly control systems for flight, engine
power, engine fuel supply and shut-off means and fire indication and extinguishing
systems.
(4) Pilot incapacitation, (see also paragraph 8 d(1)).
(5) Penetration of the fuel system, where this could result in the release of fuel into
personnel compartments or an engine compartment or other regions of the
aeroplane where this could lead to a fire or explosion.
(6) Damage to the fuel system, especially tanks, resulting in the release of a large
quantity of fuel.
(7) Penetration and distortion of firewalls and cowling permitting a spread of fire.
(8) Damage to or inadvertent movement of aerodynamic surfaces (e.g.. flaps, slats,
stabilisers, ailerons, spoilers, thrust reversers, elevators, rudders, strakes, winglets,
etc.) and the resultant effect on safe flight and landing.
c. Safety Analysis Objectives. It is considered that the objective of minimising hazards will
have been met if:
(1) The practical design considerations and precautions of Paragraphs 7 and 8 have
been taken;
(2) The safety analysis has been completed using the engine/APU model defined in
Paragraph 9;
(3) For CS-25 large aeroplanes and CS-23 commuter category aeroplanes, the
following hazard ratio guidelines have been achieved:
(i) Single One-Third Disc Fragment. There is not more than a 1 in 20 chance of
catastrophe resulting from the release of a single one-third disc fragment as
defined in Paragraph 9a.
(ii) Intermediate Fragment. There is not more than a 1 in 40 chance of
catastrophe resulting from the release of a piece of debris as defined in
Paragraph 9b.
(iii) Multiple Disc Fragments. (Only applicable to any duplicated or multiplicated
system when all of the system channels contributing to its functions have
some part which is within a distance equal to the diameter of the largest
bladed rotor, measured from the engine centreline). There is not more than
1 in 10 chance of catastrophe resulting from the release in three random
directions of three one-third fragments of a disc each having a uniform
probability of ejection over the 360° (assuming an angular spread of ±3°
relative to the plane of the disc) causing coincidental damage to systems
which are duplicated or multiplicated.
NOTE: Where dissimilar systems can be used to carry out the same function (e.g.
elevator control and pitch trim), they should be regarded as duplicated (or
multiplicated) systems for the purpose of this subparagraph provided control can
be maintained.

AMC 20-128A
The numerical assessments described above may be used to judge the relative
values of minimisation. The degree of minimisation that is feasible may vary
depending upon aeroplane size and configuration and this variation may prevent
the specific hazard ratio from being achieved. These levels are design goals and
should not be treated as absolute targets. It is possible that any one of these levels
may not be practical to achieve.
(4) For newly designed non-commuter CS-23 aeroplanes the chance of catastrophe is
not more than twice that of Paragraph 10(c)(3)(i), (ii) and (iii) for each of these
fragment types.
(5) A numerical risk assessment is not requested for the single fan blade fragment,
small fragments, and APU and engine rotor stages which are qualified as contained.
d. APU Analysis For APU's that are located where no hazardous consequences would result
from an uncontained failure, a limited qualitative assessment showing the relative
location of critical systems/components and APU impact areas is all that is needed. If
critical systems/components are located within the impact area, more extensive analysis
is needed. For APUs which have demonstrated rotor integrity only, the failure model
outlined in Paragraph 9g(1) should be considered as a basis for this safety assessment.
For APU rotor stages qualified as contained per CS–APU, the aeroplane safety analysis
may be limited to an assessment of the effects of the failure model outlined in Paragraph
9g(2).
e. Specific Risk The aeroplane risk levels specified in Paragraph 10c, resulting from the
release of rotor fragments, are the mean values obtained by averaging those for all rotors
on all engines of the aeroplane, assuming a typical flight. Individual rotors or engines need
not meet these risk levels nor need these risk levels be met for each phase of flight if
either:
(1) No rotor stage shows a higher level of risk averaged throughout the flight greater
than twice those stated in Paragraph 10c.
NOTE: The purpose of this Paragraph is to ensure that a fault which results in
repeated failures of any particular rotor stage design, would have only a limited
effect on aeroplane safety.

AMC 20-128A
FIGURE 6 – ALL NON-CONTAINMENTS BY PHASE OF FLIGHT
(2) Where failures would be catastrophic in particular portions of flight, allowance is

made for this on the basis of conservative assumptions as to the proportion of
failures likely to occur in these phases. A greater level of risk could be accepted if
the exposure exists only during a particular phase of flight e.g., during take-off. The
proportional risk of engine failure during the particular phases of flight is given in
SAE Papers referenced in Paragraph 4d. See also data contained in the CAA paper
"Engine Non-Containments – The CAA View", which includes Figure 6. This paper
is published in NASA Report CP-2017, "An Assessment of Technology for Turbo-jet
Engine Rotor Failures", dated August 1977.

AMC 20-128A
Appendix 1 to AMC 20-128A User’s Manual

ED Decision 2003/12/RM
RISK ANALYSIS METHODOLOGY for UNCONTAINED ENGINE/APU FAILURE

INDEX
1.0 GENERAL
2.0 SCOPE
3.0 FUNDAMENTAL COMPONENTS OF A SAFETY AND RISK ANALYSIS
4.0 ASSUMPTIONS
5.0 PLOTTING
6.0 METHODOLOGY – PROBABILITY ASSESSMENT
7.0 RESULTS ASSESSMENT
FIGURE 1 EXAMPLE – HAZARD TREE
FIGURE 2 EXAMPLE – SYSTEM LOADING MATRIX
FIGURE 3 TRI-SECTOR ROTOR BURST
FIGURE 4 TYPICAL LAYOUT OF SYSTEMS IN ROTOR PLANE
FIGURE 5 TRAJECTORY RANGE PLOTTING
FIGURE 6 TYPICAL TRAJECTORY PLOTTING
FIGURE 7 DEFINITION – THREAT WINDOW
FIGURE 8 SAMPLE ROTOR STAGE PLOTTING CHART
1.0 GENERAL
1.1 The design of aeroplane and engine systems and the location of the engines relative to
critical systems and structure have a significant impact on survivability of the aeroplane
following an uncontained engine failure. CS 23.903(b)(1) and 25.903(d)(1) of the EASA
Certification Specifications (CS) require that design precautions be taken to minimise the
hazard to the aeroplane due to uncontained failures of engine or auxiliary power unit
(APU). AMC 20-128A provides guidance for demonstrating compliance with these
requirements.
1.2 As a part of this compliance demonstration, it is necessary to quantitatively assess the
risk of a catastrophic failure in the event of an uncontained engine failure. This User’s
Manual describes an acceptable method for this purpose.
1.3 The objective of the risk analysis is to measure the remaining risk after prudent and
practical design considerations have been taken. Since each aeroplane would have
unique features which must be considered when applying the methods described in this
manual, there should be some flexibility in the methods and procedures.
1.4 It is a preferred approach to use these methods throughout the development of an
aeroplane design to identify problem areas at an early stage when appropriate design
changes are least disruptive. It is also advisable to involve the European Aviation Safety
Agency (EASA) in this process at an early stage when appropriate interpretation of the
methodology and documentation requirements can be established.
1.5 It should be noted that although the risk analysis produces quantitative results, subjective
assessments are inherent in the methods of the analysis regarding the criticality of
specific types of aeroplane component failures. Assumptions for such assessments
should be documented along with the numerical results.

AMC 20-128A
1.6 Aeroplane manufacturers have each developed their own method of assessing the effects
of rotor failure, as there are many ways to get to the same result. This User’s Manual
identifies all the elements that should be contained in an analysis, so that it can be
interpreted by a person not familiar with such a process.
1.7 The intent of this manual therefore is to aid in establishing how an analysis is prepared,
without precluding any technological advances or existing proprietary processes.
1.8 AMC 20-128A makes allowance for the broad configuration of the aeroplane as such
damage to the structure due to rotor failure generally allows for little flexibility in design.
System lay-out within a rotor burst zone, however, can be optimized.
1.9 Damage to structure, which may involve stress analysis, generally can be analyzed
separately, and later coordinated with simultaneous system effects.
1.10 For an analysis of the effects on systems due to a rotor failure the aeroplane must be
evaluated as a whole; and a risk analysis must specifically highlight all critical cases
identified which have any potential to result in a catastrophe.
1.11 Such an analysis can then be used to establish that reasonable precautions have been
taken to minimise the hazards, and that the remaining hazards are an acceptable risk.
1.12 A safety and a risk analysis are interdependent, as the risk analysis must be based on the
safety analysis.
The safety analysis therefore is the starting point that identifies potential hazardous or
catastrophic effects from a rotor failure and is the basic tool to minimise the hazard in
accordance with the guidelines of AMC 20-128A.
1.13 The risk analysis subsequently assesses and quantifies the residual risk to the aeroplane.
2.0 SCOPE
The following describes the scope of analyses required to assess the aeroplane risk levels
against the criteria set forth in Paragraph 10 of AMC 20-128A.
2.1 Safety
Analysis is required to identify the critical hazards that may be numerically analyzed
(hazards remaining after all practical design precautions have been taken).
Functional criticality will vary by aeroplane and may vary by flight phase.
Thorough understanding of each aeroplane structure and system functions is required to
establish the criticality relative to each fragment trajectory path of the theoretical failure.
Assistance from experts within each discipline is typically required to assure accuracy of
the analysis in such areas as effects of fuel tank penetration on leakage paths and ignition
hazards, thrust level control (for loss of thrust assessment), structural capabilities (for
fuselage impact assessment), aeroplane controllability (for control cables impact
assessment), and fuel asymmetry.
2.2 Risk
For each remaining critical hazard, the following assessments may be prepared using the
engine/APU failure models as defined in Paragraph 9 of AMC 20-128A:
a. Flight mean risk for single 1/3 disc fragment.
b. Flight mean risk for single intermediate fragment.

AMC 20-128A
c. Flight mean risk for alternate model (when used as an alternate to the 1/3 disc
fragment and intermediate fragment).
d. Multiple 1/3 disc fragments for duplicated or multiplicated systems.
e. Specific risk for single 1/3 disc fragment and single intermediate fragment.
f. Specific risk for any single disc fragment that may result in catastrophic structural
damage.
The risk level criteria for each failure model are defined in Paragraph 10 of AMC 20-128A.
3.0 FUNDAMENTAL COMPONENTS OF A SAFETY AND RISK ANALYSIS
3.1 The logical steps for a complete analysis are:
a. Establish at the design definition the functional hazards that can arise from the
combined or concurrent failures of individual systems, including multiplicated
systems and critical structure.
b. Establish a Functional Hazard Tree (see Figure 1), or a System Matrix (see Figure 2)
that identifies all system interdependencies and failure combinations that must be
avoided (if possible) when locating equipment in the rotor burst impact area.
In theory, if this is carried out to the maximum, no critical system hazards other
than opposite engine or fuel line hits would exist.
c. Establish the fragment trajectories and trajectory ranges both for translational and
spread risk angles for each damage. Plot these on a chart or graph, and identify the
trajectory ranges that could result in hazardous combinations (threats) as per the
above system matrix or functional hazard analysis.
d. Apply risk factors, such as phase of flight or other, to these threats, and calculate
the risk for each threat for each rotor stage.
e. Tabulate, summarize and average all cases.
3.2 In accordance with AMC 20-128A the risk to the aeroplane due to uncontained rotor
failure is assessed to the effects, once such a failure has occurred.
The probability of occurrence of rotor failure, as analyzed with the probability methods
of AMC 25.1309 (i.e. probability as a function of critical uncontained rotor failure rate and
exposure time), does not apply.
3.3 The total risk level to the aeroplane, as identified by the risk analysis, is the mean value
obtained by averaging the values of all rotor stages of all engines of the aeroplane,
expressed as Flight Mean Risk.
4.0 ASSUMPTIONS
4.1 The following conservative assumptions, in addition to those in Paragraphs 10(a)(1), (2)
and (3) of AMC 20-128A, have been made in some previous analyses. However, each
aeroplane design may have unique characteristics and therefore a unique basis for the
safety assessment leading to the possibility of different assumptions. All assumptions
should be substantiated within the analysis:
a. The 1/3 disc fragment as modeled in Paragraph 9(a) of the AMC 20-128A travels
along a trajectory path that is tangential to the sector centroid locus, in the
direction of rotor rotation (Refer to Figure 3).

AMC 20-128A
The sector fragment rotates about its centroid without tumbling and sweeps a path
equal to twice the greatest radius that can be struck from the sector centroid that
intersects its periphery.
The fragment is considered to possess infinite energy, and therefore to be capable
of severing lines, wiring, cables and unprotected structure in its path, and to be
undeflected from its original trajectory unless deflection shields are fitted.
However, protective shielding or an engine being impacted may be assumed to
have sufficient mass to stop even the most energetic fragment.
b. The probability of release of debris within the maximum spread angle is uniformly
distributed over all directions.
c. The effects of severed electrical wiring are dependent on the configuration of the
affected system. In general, severed wiring is assumed to not receive inadvertent
positive voltage for any significant duration.
d. Control cables that are struck by a fragment disconnect.
e. Hydraulically actuated, cable driven control surfaces, which do not have
designated “fail to” settings, tend to fail to null when control cables are severed.
Subsequent surface float is progressive and predictable.
f. Systems components are considered unserviceable if their envelope has been
touched. In case of an engine being impacted, the nacelle structure may be
regarded as engine envelope, unless damage is not likely to be hazardous.
g. Uncontained events involving in-flight penetration of fuel tanks will not result in
fuel tank explosion.
h. Unpowered flight and off-airport landings, including ditching, may be assumed to
be not catastrophic to the extent validated by accident statistics or other accepted
factors.
i. Damage to structure essential for completion of flight is catastrophic (Ref. AMC 20-
128A, Paragraph 10.b(1)).
j. The flight begins when engine power is advanced for takeoff and ends after landing
when turning off the runway.
5.0 PLOTTING
5.1 Cross-section and plan view layouts of the aeroplane systems in the ranges of the rotor
burst impact areas should be prepared, either as drawings, or as computer models
These layouts should plot the precise location of the critical system components,
including fuel and hydraulic lines, flight control cables, electric wiring harnesses and
junction boxes, pneumatic and environmental system ducting, fire extinguishing; critical
structure, etc.
5.2 For every rotor stage a plane is developed. Each of these planes contains a view of all the
system components respective outer envelopes, which is then used to generate a cross-
section. See Figure 4.
5.3 Models or drawings representing the various engine rotor stages and their fore and aft
deviation are then generated.
5.4 The various trajectory paths generated for each engine rotor stage are then
superimposed on the cross-section layouts of the station planes that are in the range of

AMC 20-128A
that potential rotor burst in order to study the effects (see Figure 5). Thus separate plots
are generated for each engine rotor stage or rotor group.
To reduce the amount of an analysis the engine rotor stages may also be considered as
groups, as applicable for the engine type, using the largest rotor stage diameter of the
group.
5.5 These trajectory paths may be generated as follows and as shown in Figure 6:
a. Two tangent lines T1 are drawn between the locus of the centroid and the target
envelope.
b. At the tangent line touch points, lines N1 and N2 normal to the tangent lines, are
drawn with the length equal to the radius of the fragment swept path (as also
shown in Figure 1).
c. Tangent lines T2 are drawn between the terminal point of the normal lines and the
locus of the centroid. The angle between these two tangent lines is the
translational risk angle.
5.6 The entry and exit angles are then calculated.
5.7 The initial angle of intersection and the final angle of intersection are recorded, and the
trajectories in between are considered to be the range of trajectories in which this
particular part would be impacted by a rotor sector, and destroyed (i.e. the impact area).
The intersections thus recorded are then entered on charts in tabular form so that the
simultaneous effects can be studied. Refer to Figure 8.
Thus it will be seen that the total systems’ effects can be determined and the worst cases
identified.
5.9 If a potentially serious multiple system damage case is identified, then a more detailed
analysis of the trajectory range will be carried out by breaking the failure case down into
the specific fore-aft spread angle, using the individual rotor stage width instead of
combined groups, if applicable.
6.0 METHODOLOGY – PROBABILITY ASSESSMENT
6.1 Those rotor burst cases that have some potential of causing a catastrophe are evaluated
in the analysis in an attempt to quantify an actual probability of a catastrophe, which will,
in all cases, depend on the following factors:
a. The location of the engine that is the origin of the fragment, and its direction of
rotation.
b. The location of critical systems and critical structure.
c. The rotor stage and the fragment model.
d. The translational trajectory of the rotor fragment,
e. The specific spread angle range of the fragment.
f. The specific phase of the flight at which the failure occurs.
g. The specific risk factor associated with any particular loss of function.
6.2 Engine Location

AMC 20-128A
The analysis should address the effects on systems during one flight after a single rotor
burst has occurred, with a probability of 1.0. As the cause may be any one of the engines,
the risk from each engine is later averaged for the number of engines.
The analysis trajectory charts will then clearly show that certain system damage is unique
to rotor fragments from a particular engine due to the direction of rotation, or, that for
similar system damage the trajectory range varies considerably between engines.
A risk summary should table each engine case separately with the engine location
included.
6.3 Rotor Element
The probability of rotor failure is assumed to be 1.0 for each of all rotor stages. For the
analysis the individual risk(s) from each rotor stage of the engine should be assessed and
tabled.
6.4 Translational Risk Angle
The number of degrees of included arc (out of 360) at which a fragment intersects the
component/structure being analyzed. Refer to Figure 6 and Figure 7.
6.5 Trajectory Probability (P)
The probability of a liberated rotor fragment leaving the engine case is equal over 360 ,
thus the probability P of that fragment hitting a system component is the identified
Translational Risk Angle ɸ in degrees °, divided by 360, i.e.
𝑃 = 𝜙/360
or
𝜙1 − 𝜙2
360
6.6 Spread Angle
If the failure model of the analysis assumes a (fore and aft) spread of ± 5°, then the spread
angle is a total of 10°. If a critical component can only be hit at a limited position within
that spread, then the exposure of that critical component can then be factored according
to the longitudinal position within the spread angle, e.g.:
𝜓2 − 𝜓1
𝑠𝑝𝑟𝑒𝑎𝑑 𝑎𝑛𝑔𝑙𝑒
If a component can only be hit at the extreme forward range of +4° to +5°, then the factor
is .1 (for one degree out of 10).
6.7 Threat Window
The definition of a typical threat window is shown in Figure 7.
6.8 Phase of Flight
Certain types of system damage may be catastrophic only during a specific portion of the
flight profile, such as a strike on the opposite engine during take-off after V1 (i.e. a
probability of 1.0), while with altitude a straight-ahead landing may be possible under
certain favourable conditions (e.g. a probability of less than 1.0). The specific case can
then be factored accordingly.

AMC 20-128A
6.8.1 The most likely time for an uncontained rotor failure to occur is during take-off,
when the engine is under highest stress. Using the industry accepted standards for
the percentage of engine failures occurring within each flight phase, the following
probabilities are assumed:
Take-off before V1 35%
V1 to first power reduction 20%
Climb 22%
Cruise 14%
Descent 3%
Approach 2%
Landing/Reverse 4%
6.8.2 The flight phase failure distribution above is used in the calculations of catastrophic
risk for all cases where this risk varies with flight phase.
𝐷𝑝 = 𝑃 𝑓𝑙𝑖𝑔ℎ𝑡 𝑝ℎ𝑎𝑠𝑒 %
100
6.9 Other Risk Factors
Risks such as fire, loss of pressurization, etc., are individually assessed for each case
where applicable, using conservative engineering judgment. This may lead to a
probability of catastrophe (i.e., risk factor) smaller than 1.0.
6.9.1 The above probabilities and factors are used in conjunction with the critical
trajectory range defined to produce a probability of the specific event occurring
from any random rotor burst.
This value is then factored by the "risk" factor assessed for the case, to derive a
calculated probability of catastrophe for each specific case.
Typical conditional probability values for total loss of thrust causing catastrophic
consequences are:
Phase Dp Risk
T.O.–V1 to first power reduction 0.20 1.0
Climb 0.22 0.4
Cruise 0.14 0.2
Descent 0.03 0.4
Approach 0.02 0.4
6.10 All individual case probabilities are then tabled and summarised.
6.11 The flight mean values are obtained by averaging those for all discs or rotor stages on all
engines across a nominal flight profile.
The following process may be used to calculate the flight mean value for each Failure
Model:
a. Establish from the table in Figure 8 the threat windows where, due to combination
of individual damages, a catastrophic risk exists.
b. For each stage case calculate the risk for all Critical Hazards

AMC 20-128A
c. For each stage case apply all risk factors, and, if applicable, factor for Flight Phase-
Failure distribution
d. For each engine, average all stages over the total number of engine stages
e. For each aeroplane, average all engines over the number of engines.
7.0 RESULTS ASSESSMENT
7.1 An applicant may show compliance with CS 23.903(b)(1) and CS 25.903(d)(1) using
guidelines set forth in AMC 20-128A. The criteria contained in the AMC may be used to
show that:
a. Practical design precautions have been taken to minimise the damage that can be
caused by uncontained engine debris, and
b. Acceptable risk levels, as specified in AMC 20-128A, Paragraph 10, have been
achieved for each critical Failure Model.
7.2 The summary of the applicable risk level criteria is shown in Table 1 below.
Table 1 Summary of Acceptable Risk Level Criteria
Requirement Criteria
Average 1/3 Disc Fragment 1 in 20
Average Intermediate Fragment 1 in 40
Average Alternate Model 1 in 20 @ ± 5 degree Spread Angle
Multiple Disc Fragments 1 in 10
Any single fragment (except for structural damage) 2 x corresponding average criterion

AMC 20-128A
EXAMPLE – HAZARD TREE

FIGURE 1
LOC COMPONENT DAMAGE TO SYSTEM LOADED DETAIL

LEFT AILERON CABLES/SURFACE HYDRAULIC POWER #1 & #3
RIGHT AILERON CABLES/SURFACE HYDRAULIC POWER #2 & #3
LEFT SPOILER - OUTBD CONTROL/SURFACE HYDRAULIC POWER #1
MULTI-FUNCTION
RIGHT SPOILER - OUTBD CONTROL/SURFACE HYDRAULIC POWER #1
MULTI-FUNCTION
LEFT FLAP-OUTBD TRACK/SURFACE ELECTRICAL POWER AC BUS1
AC ESS
RIGHT FLAP-OUTBD TRACK/SURFACE ELECTRICAL POWER AC BUS1
AC ESS

AMC 20-128A
LEFT RUDDER CABLE HYDRAULIC POWER #1,#2&#3

RIGHT RUDDER CABLE HYDRAULIC POWER #1,#2&#3
LEFT ELEVATOR CABLES HYDRAULIC POWER #1 & #3
Note 1
RIGHT ELEVATOR CABLES HYDRAULIC POWER #2 & #3
Note 1
CHAN1 PITCH TRIM CONTROL/POWER ELECTRICAL POWER AC BUS1
Note 2 DC BUS1
CHAN2 PITCH TRIM CONTROL/POWER ELECTRICAL POWER AC ESS
Note 2 DC ESS
FLIGHT CONTROLS – SYSTEM LOADING

Note 1:
Same fragment path must not sever:
ON-SIDE cables + OFF-SIDE hydraulic system + HYDRAULIC PWR #3
e.g.: Left elevator cable and HYDRAULIC PWR #2 and #3 or,
Right elevator cable and HYDRAULIC PWR # 1 and # 3
Note 2:
Same fragment path must not sever:
— Both CHAN1 and CHAN2 circuits
— ON-SIDE control circuit + OFF-SIDE power circuit
— OFF-SIDE control circuit + ON-SIDE power circuit
EXAMPLE – SYSTEM LOADING MATRIX

FIGURE 2

AMC 20-128A
TRI-SECTOR ROTOR BURST

FIGURE 3

AMC 20-128A
TYPICAL LAYOUT OF SYSTEMS IN ROTOR PLANE

FIGURE 4

AMC 20-128A
TRAJECTORY RANGE PLOTTING

FIGURE 5

AMC 20-128A
TYPICAL TRAJECTORY PLOTTING

FIGURE 6

AMC 20-128A
DEFINITION - THREAT WINDOW

FIGURE 7

AMC 20-128A

AMC 20-136
AMC 20-136
AMC 20-136 Aircraft Electrical and Electronic System Lightning

Protection
1. PURPOSE
a. This Acceptable Means of Compliance (AMC) provides the means and Guidance Material
(GM) on how aircraft electrical and electronic systems can be protected from the effects
of lightning. This AMC describes a means, but not the only means, to demonstrate
compliance with the following Certification Specifications: CS 23.1306, CS 25.1316, CS
27.1316, and CS 29.1316, Electrical and electronic system lightning protection, as they
pertain to aircraft type certification or supplemental type certification.
b. This AMC is not mandatory and does not constitute a regulation. In using the means
described in this AMC, it must be followed in all important respects.
c. The verb ‘must’ is used to indicate mandatory requirements when following the guidance
in this AMC in its entirety. The terms ‘should’ and ‘recommend’ are used when following
the guidance is recommended but not required to comply with this AMC.
2. APPLICABILITY
This AMC applies to all applicants for a new Type Certificate (TC) or a change to an existing TC
when the certification basis contains either CS 23.1306, or CS 25.1316, or CS 27.1316, or CS
29.1316.
3. SCOPE
a. AMC 20-136 provides the AMC and GM for complying with CS 23.1306, CS 25.1316, CS
27.1316, and CS 29.1316 for the effects on electrical and electronic systems due to
lightning transients induced or conducted onto equipment and wiring.
b. CS 23.1306, CS 25.1316, CS 27.1316, and CS 29.1316 are also applicable to the effects on
aircraft electrical and electronic systems when lightning directly attaches to equipment,
components, or wiring. This AMC addresses the functional aspects of these effects on
aircraft electrical and electronic equipment, components, or wiring. However, this AMC
does not address lightning effects such as burning, eroding, and blasting of aircraft
equipment, components, or wiring. For demonstrating compliance for these effects, we
recommend using EUROCAE ED-113, Aircraft Lightning Direct Effects Certification.
c. For information on fuel ignition hazards, see AMC 25.954 and FAA AC 20-53, Protection
of Aircraft Fuel Systems Against Fuel Vapor Ignition Caused By Lightning. This AMC does
not address lightning zoning methods, lightning environment definition, or lightning test
methods. For information on lightning zoning methods and lightning environment
definition, see EUROCAE ED-91 and ED-84A. For information on Fuel Structural Lightning
Protection, see EUROCAE policy ER-002. For information on lightning test methods, see
EUROCAE ED-105A, Aircraft Lightning Test Methods, or ED-14G, Section 22, Lightning
Induced Transient Susceptibility, and Section 23, Lightning Direct Effects.

AMC 20-136
4. RELATED MATERIAL
a. European Aviation Safety Agency (EASA) (in this document also referred to as the
‘Agency’)
1. Certification Specifications CS-23: 23.867, 23.901, 23.954, 23.1301, 23.1306,
23.1309, 23.1529.
25.1316, 25.1529.
27.1316, 27.1529.
29.1316, 29.1529.
Copies of these CSs can be requested from the European Aviation Safety Agency, Postfach
10 12 53, D-50452 Cologne, Germany; telephone +49 221 8999 000; fax: +49 221 8999
099; Website: http://easa.europa.eu/official-publication/
b. Title 14 of the Code of Federal Regulations (14 CFR)
Copies of the following 14 CFR sections can be requested from the Superintendent of
Documents, Government Printing Office, Washington, D.C. 20402-9325. Telephone 202-
512-1800, fax 202-512-2250. Copies can also be requested from the Government Printing
Office (GPO) via the electronic CFR Internet website at www.access.gpo.gov/ecfr/.
Part 23, Airworthiness Standards: Normal, Utility, Acrobatic, and Commuter Category
Airplanes
§ 23.867 Electrical bonding and protection against lightning and static electricity
§ 23.901 Installation
§ 23.954 Fuel system lightning protection
§ 23.1301 Function and installation
§ 23.1309 Equipment, systems, and installations
§ 23.1306 Electrical and electronic system lightning protection
§ 23.1529 Instructions for continued airworthiness
Part 25, Airworthiness Standards: Transport Category Airplanes

§ 25.581 Lightning protection

AMC 20-136
Part 27, Airworthiness Standards: Normal Category Rotorcraft

§ 27.610 Lightning and static electricity protection
Part 29, Airworthiness Standards: Transport Category Rotorcraft

§ 29.610 Lightning and static electricity protection
c. FAA Advisory Circular
1. AC 20-155, SAE Documents to Support Aircraft Lightning Protection Certification.
2. AC 21-16, RTCA Document DO-160 Versions D, E, F, and G, Environmental
Conditions and Test Procedures for Airborne Equipment.
3. AC 23-17, Systems and Equipment Guide for Certification of Part 23 Airplanes and
Airships.
4. AC 23.1309-1E, System Safety Analysis and Assessment for Part 23 Airplanes.
5. AC 27-1B, Certification of Normal Category Rotorcraft.
6. AC 29-2C, Certification of Transport Category Rotorcraft.
Copies of these ACs are available at
http://www.faa.gov/regulations_policies/advisory_circulars.
d. Industry documents
Note: The industry documents referenced in this section refer to the current revisions or
regulatory authorities accepted revisions.
1. European Organization for Civil Aviation Equipment (EUROCAE). Copies of the
following documents can be requested from EUROCAE, 102 rue Etienne Dolet,
92240 Malakoff. Telephone: +33 1 40 92 79 30, Fax: +33 1 46 55 62 65,
Website: http://www.eurocae.net.
EUROCAE ED-79A, Guidelines for Development of Civil Aircraft and Systems.

AMC 20-136
EUROCAE ED-14G, Environmental Conditions and Test Procedures for Airborne

Equipment.
EUROCAE ED-84A, Aircraft Lightning Environment and Related Test Waveforms
EUROCAE ED-91, Aircraft Lightning Zoning
EUROCAE ED-105A, Aircraft Lightning Test Methods.
EUROCAE ED-113, Aircraft Lightning Direct Effects Certification.
2. RTCA. You can get copies of RTCA/DO-160G, Environmental Conditions and Test
Procedures for Airborne Equipment, from RTCA, Inc., 1150 18th Street NW, Suite
910, Washington, D.C. 20036. Telephone: +1 202 833 9339, Fax +1 202 833 9434,
Website: http://www.rtca.org.
This document is technically equivalent to EUROCAE ED-14G. Anywhere there is a
reference to RTCA/DO-160G, EUROCAE ED-14G may be used.
3. SAE International. You can get copies of the following documents from SAE
Customer Service, 400 Commonwealth Drive, Warrendale, PA 15096-0001.
Telephone: +1 724 776 4970, Fax: 724-776-0790, Website: www.sae.org.
ARP 4754A, Guidelines for Development of Civil Aircraft and Systems. This
document is technically equivalent to EUROCAE ED-79A. Anywhere there is a
reference to ARP 4754A, EUROCAE ED-79A may be used.
ARP 4761, Guidelines and Methods for Conducting the Safety Assessment Process
on Civil Airborne Systems and Equipment.
ARP 5412B, Aircraft Lightning Environment and Related Test Waveforms. This
document is technically equivalent to EUROCAE ED-84A. Anywhere there is a
reference to ARP 5412A, EUROCAE ED-84A may be used.
ARP 5414A, Aircraft Lightning Zoning. This document is technically equivalent to
EUROCAE ED-91. Anywhere there is a reference to ARP 5414A, EUROCAE ED-91 may
be used.
ARP 5415A, User’s Manual for Certification of Aircraft Electrical/Electronic Systems
for the Indirect Effects of Lightning.
ARP 5416A, Aircraft Lightning Test Methods. This document is technically
equivalent to EUROCAE ED-105A. Anywhere there is a reference to ARP 5416A,
EUROCAE ED-105A may be used.
ARP 5577, Aircraft Lightning Direct Effects Certification. This document is
technically equivalent to EUROCAE ED-113. Anywhere there is a reference to ARP
5577, EUROCAE ED-113 may be used.
5. BACKGROUND
a. Regulatory Applicability. The certification specifications for aircraft electrical and
electronic system lightning protection are based on the aircraft’s potential for lightning
exposure and the consequences of system failure. The regulations require lightning
protection of aeroplane/rotorcraft electrical and electronic systems with catastrophic,
hazardous, or major failure conditions for aeroplane/rotorcraft certificated under CS-25
and 29. The requirements also apply to CS-23 aeroplanes and CS-27 rotorcraft approved
for operations under instrument flight rules. Those CS-23 aeroplanes and CS-27 rotorcraft

AMC 20-136
approved solely for operations under visual flight rules require lightning protection of
electrical or electronic systems having catastrophic failure conditions.
b. Regulatory Requirements. Protection against the effects of lightning for aircraft electrical
and electronic systems, regardless of whether these are ‘indirect’ or ‘direct’ effects of
lightning, are addressed under CS 23.1306, 25.1316, 27.1316, and 29.1316. The terms
‘indirect’ and ‘direct’ are often used to classify the effects of lightning. However, the
regulations do not, and are not intended to, differentiate between the effects of
lightning. The focus is to protect aircraft electrical and electronic systems from effects of
lightning. The regulations listed in this paragraph introduce several terms which are
further explained below, including:
1. System. A system can include equipment, components, parts, wire bundles,
software, and firmware. Electrical and electronic systems consist of pieces of
equipment connected by electrical conductors, all of which are required to
perform one or more functions.
2. Function. The specific action of a system, equipment, and flight crew performance
aboard the aircraft that, by itself, provides a completely recognizable operational
capability. For example, “display aircraft heading to the pilots” is a function. One
or more systems may perform a specific function or one system may perform
multiple functions.
3. Adverse Effect. A lightning effect resulting in system failure, malfunction, or
misleading information to a degree that is unacceptable for the specific aircraft
function or system addressed in the system lightning protection regulations.
4. Timely Manner. The meaning of “in a timely manner” depends upon the function
performed by the system being evaluated, the specific system design, interaction
between that system and other systems, and interaction between the system and
the flight crew. The definition of “in a timely manner” must be determined for each
specific system and for specific functions performed by the system. The applicable
definition should be included in the certification plan for review and approval by
the certification authorities.
6. STEPS FOR DEMONSTRATING COMPLIANCE
a. The following seven steps describe how compliance with CS 23.1306, CS 25.1316,
CS 27.1316, and CS 29.1316 may be demonstrated:
1. Identify the systems to be assessed.
2. Determine the lightning strike zones for the aircraft.
3. Establish the aircraft lightning environment for each zone.
4. Determine the lightning transient environment associated with the systems.
5. Establish Equipment Transient Design Levels (ETDLs) and aircraft Actual Transient
Levels (ATLs).
6. Verify compliance with the requirements.
7. Take corrective measures, if needed.
b. Lightning considerations
The steps above should be performed to address lightning transients induced in electrical
and electronic system wiring and equipment, and lightning damage to aircraft external

AMC 20-136
equipment and sensors that are connected to electrical and electronic systems, such as
radio antennas and air data probes. Additional guidance on lightning protection against
lightning damage for external equipment and sensor installations can be found in
EUROCAE ED-113.
c. Identify the systems to be assessed
1. General. The aircraft systems requiring lightning assessment should be identified.
Address any lightning-related electrical or electronic system failure that may cause
or contribute to an adverse effect on the aircraft. The effects of a lightning strike,
therefore, should be assessed in a manner that allows for the determination of the
degree to which the aircraft and/or its systems’ safety may be influenced. This
assessment should cover:
a. all normal aircraft operating modes, phases of flight, and operating
conditions; and
b. all lightning-related failure conditions and their subsequent effects on
aircraft operations and the flight crew.
2. Safety assessment. A safety assessment related to lightning effects should be
conducted to establish and classify the system failure condition. Based on the
failure condition classification established by the safety assessment, the systems
should be assigned appropriate lightning certification levels, as shown in Table 1.
The failure condition classifications and terms used in this AMC are consistent with
those used in AC 23.1309-1E, System Safety Analysis and Assessment for CS-23
Aeroplanes, and AMC 25.1309, System Safety Analysis and Assessment for CS-25
Aeroplanes. Further guidance on processes for conducting safety assessments can
be found in those AC/AMC and in AC 27-1B, Certification of Normal Category
Rotorcraft, AC 29-2C, Certification of Transport Category Rotorcraft, EUROCAE ED-
79A, Guidelines for Development of Civil Aircraft and Systems, and ARP 4761,
Guidelines and Methods for Conducting the Safety Assessment Process on Civil
Airborne Systems and Equipment. The specific aircraft safety assessment related
to lightning effects required by CS 23.1306, CS 25.1316, CS 27.1316 and CS 29.1316
takes precedence over the more general safety assessment process described in
AC 23.1309-1E, AMC 25.1309, AC 27-1B, and AC 29-2C. Lightning effects on
electrical and electronic systems are generally assessed independently from other
system failures that are unrelated to lightning, and do not need to be considered
in combination with latent or active failures unrelated to lightning.
Table 1 — Lightning failure conditions and certification levels
Lightning Requirement Provisions From: Failure Condition System Lightning

CS 23.1306, CS 25.1316, CS 27.1316, CS 29.1316 Certification Level
(a) Each electrical and electronic system that performs a Catastrophic A
function for which failure would prevent the
continued safe flight and landing of the aircraft.
(b) Each electrical and electronic system that performs a Hazardous B

function for which failure would reduce the capability
of the aircraft or the ability of the flight crew to Major C
respond to an adverse operating condition.

AMC 20-136
a. Level A systems. The system safety assessment should consider effects of

lightning-related failures or malfunctions on systems with lower failure
classification that may affect the function of Level A systems. The applicant
should demonstrate that any system with wiring connections to a Level A
system will not adversely affect the functions with catastrophic failure
conditions performed by the Level A system when the aircraft is exposed to
lightning. Redundancy alone cannot protect against lightning because the
lightning-generated electromagnetic fields, conducted currents and induced
currents in the aircraft can simultaneously induce transients in all electrical
wiring on an aircraft.
b. Level B or C systems. Simultaneous and common failures due to lightning
exposure generally do not have to be assumed for Level B or C systems
incorporating redundant, spatially separated installations in the aircraft. This
is because aircraft transfer function tests and in-service experience have
shown these redundant and spatially separated installations are not
simultaneously exposed to the maximum lightning-induced transients. For
example, redundant external sensors may mitigate direct lightning
attachment damage if there is acceptable separation between the sensors
to prevent damage to multiple sensors so that the function is maintained.
Therefore, simultaneous loss of all of these redundant and spatially
separated Level B or C systems due to lightning exposure does not need to
be considered. However, if multiple Level B or C systems are designed and
installed within the same location in the aircraft, or share a common wiring
connection, then the combined failure due to lightning exposure should be
assessed to determine if the combined failures are catastrophic. If so, these
systems should be designated as Level A systems.
c. Failure conditions. The safety assessment may show that some systems have
different failure conditions in different phases of flight. Therefore, different
lightning requirements may have to be applied to the system for different
phases of flight. For example, an automatic flight control system may have a
catastrophic failure condition for autoland, while automatic flight control
system operations in cruise may have a hazardous failure condition.
d. Determine the lightning strike zones for the aircraft
The purpose of lightning zoning is to determine those areas of the aircraft likely to experience lightning
channel attachment and those structures that may conduct lightning current between lightning attachment
points. The lightning attachment zones for the aircraft configuration, should be determined, since the zones
will be dependent upon the aircraft’s geometry, materials, and operational factors. Lightning attachment
zones often vary from one aircraft type to another.
Note: EUROCAE ED-91 provides guidance to determine the lightning attachment zones for the aircraft.
e. Establish the aircraft lightning environment for each zone

Zones 1 and 2 identify where lightning is likely to attach and, as a result, the entrance and exit points for
current flow through the aircraft. The appropriate voltage waveforms and current components to apply in
those zones should be identified. By definition, Zone 3 areas carry lightning current flow between initial (or
swept stroke) attachment points, so they may include contributions from all of the current components. The
Agency accepts analysis to estimate Zone 3 current levels that result from the external environment. The
external lightning environment is:
1. caused by the lightning flash interacting with the exterior of the aircraft; and
2. represented by combined waveforms of the lightning current components at the aircraft surface.

AMC 20-136
Note: EUROCAE ED-84A provides guidance for selecting the lightning waveforms and their applications.
f. Determine the lightning transient environment associated with the systems

1. The lightning environment, as seen by electrical and electronic systems, consists of
voltages and currents produced by lightning current flowing through the aircraft.
The voltages and currents that appear at system wiring interfaces result from
aperture coupling, structural voltages, or conducted currents resulting from direct
attachments to equipment and sensors.
2. Determine the lightning voltage and current transient waveforms and amplitudes
that can appear at the electrical and electronic equipment interface circuits for
each system identified in paragraph 6.c. The lightning transients may be
determined in terms of the wire bundle current, or the open circuit voltage and the
short circuit current appearing at system wiring and equipment interface circuits.
The voltage and current transient waveforms and amplitudes are dependent upon
the loop impedances of the system and its interconnecting wiring.
g. Establish Equipment Transient Design Levels (ETDLs) and aircraft Actual Transient
Levels (ATLs)
The regulations in CS 23.1306, CS 25.1316, CS 27.1316, and CS 29.1316 define
requirements in terms of functional effects that are performed by aircraft electrical and
electronic systems. From a design point of view, lightning protection for systems is shared
between protection incorporated into the aircraft structure and wiring, and protection
incorporated into the equipment. Therefore, requirement allocations for the electrical
and electronic system lightning protection can be based on the concept of ETDLs and
ATLs.
1. Determine and specify the ETDLs for the electrical and electronic equipment that
make up the systems to be assessed. The ETDLs set qualification test levels for the
systems and equipment. They define the voltage and current amplitudes and
waveforms that the systems and equipment must withstand without any adverse
effects. The ETDLs for a specific system depend on the anticipated system and
wiring installation locations on the aircraft, the expected shielding performance of
the wire bundles and structure, and the system criticality.
2. The ATLs are the voltage and current amplitudes and waveforms actually
generated on the aircraft wiring when the aircraft is exposed to lightning, as
determined by aircraft test, analysis, or similarity. The difference between an ETDL
and an ATL is the margin. Figure 1 shows the relationship among the ATL and the
ETDL. The aircraft, interconnecting wiring, and equipment protection should be
evaluated to determine the most effective combination of ATLs and ETDLs that will
provide acceptable margin. Appropriate margins to account for uncertainties in the
verification techniques may be required as mentioned in paragraph 8.i. of this
AMC.

AMC 20-136
3. Typically, the applicant should specify the ETDLs prior to aircraft certification
lightning tests or analyses to determine the aircraft ATLs. Therefore, the expected
aircraft transients must be based upon results of lightning tests on existing aircraft,
engineering analyses, or knowledgeable estimates. These expected aircraft
lightning transient levels are termed Transient Control Levels (TCLs). The TCLs
voltage and current amplitudes and waveforms should be specified based upon the
expected lightning transients that would be generated on wiring in specific areas
of the aircraft. The TCLs should be equal to or greater than the maximum expected
aircraft ATLs. The TCLs for a specific wire bundle depend on the configuration of
the aircraft, the wire bundle, and the wire bundle installation. The aircraft lightning
protection should be designed to meet the specified TCLs.
h. Verify compliance with the requirements
1. The applicant should demonstrate that the systems comply with the applicable
requirements of CS 23.1306, CS 25.1316, CS 27.1316, or CS 29.1316.
2. The applicant should demonstrate that the ETDLs exceed the ATLs by the margin
established in their certification plan.
3. Verification may be accomplished by tests, analyses, or by demonstrating similarity
with previously certified aircraft and systems. The certification process for Level A
systems is contained in paragraph 8. The certification process for Level B and C
systems is contained in paragraph 9.
4. The applicant should submit their certification plan in the early stages of the
programme to the Agency for review. Experience shows that, particularly with
aircraft using new technology or those that have complex systems, early
agreement on the certification plan benefits both the applicant and the Agency.
The plan should define acceptable ways to resolve critical issues during the

AMC 20-136
certification process. Analyses and test results during the certification process may
warrant modifications to the design or verification methods. When significant
changes are necessary, the certification plan should be updated accordingly. The
plan may include the items listed in Table 2.
i. Take corrective measures
If tests and analyses show that the system did not meet the pass/fail criteria, review the
aircraft, installation or system design and improve protection against lightning.
Table 2 — Items recommended for a lightning certification plan
Item Discussion
Description of Describe the systems’ installation, including unusual or unique features; the system failure
systems condition classifications; the operational aspects; lightning attachment zones; lightning
environment; preliminary estimate of ETDLs and TCLs; and acceptable margins between ETDLs
and ATLs.
Description of Describe how to verify compliance. Typically, the verification method chosen includes similarity,
compliance method analytical procedures, and tests. If using analytical procedures, describe how to verify them.
(See paragraph 8.d.)
Acceptance criteria Determine the pass/fail criteria for each system by analysing how safe the system is. During this
safety analysis, assess the aircraft in its various operational states; account for the failure and
disruption modes caused by the effects of lightning.
Test plans Each test undertaken as part of the demonstration of compliance should be appropriately
planned. The applicant can decide if test plans are separate documents or part of the
compliance plan. Test plans should state the test sequence.
7. EFFECTS OF TRANSIENTS
Lightning causes voltage and current transients to appear on equipment circuits. Equipment circuit impedances and
configurations will determine whether lightning transients are primarily voltage or current. These transient voltages
and currents can degrade system performance permanently or temporarily. The two primary types of degradation
are component damage and system functional upset.
a. Component damage
This is a permanent condition in which transients alter the electrical characteristics of a circuit. Examples of
devices that may be susceptible to component damage include:
1. active electronic devices, especially high-frequency transistors, integrated circuits,

microwave diodes, and power supply components;
2. passive electrical and electronic components, especially those of very low power
or voltage rating;
3. electro-explosive devices, such as squibs and detonators;
4. electromechanical devices, such as indicators, actuators, relays, and motors; and
5. insulating materials (for example, insulating materials in printed circuit boards and
connectors) and electrical connections that can burn or melt.
b. System functional upset
1. Functional upset is mainly a system problem caused by electrical transients. It may
permanently or momentarily upset a signal, circuit, or a system component, which
can adversely affect system performance enough to compromise flight safety. A
functional upset is a change in digital or analogue state that may or may not require
manual reset. In general, functional upset depends on circuit design and operating
voltages, signal characteristics and timing, and system and software configuration.

AMC 20-136
2. Systems or devices that may be susceptible to functional upset include computers

and data/signal processing systems; electronic engine and flight controls; and
power generating and distribution systems.
8. LEVEL A SYSTEM LIGHTNING CERTIFICATION
Figure 2 illustrates a process that the applicant can use to demonstrate that their Level A system
complies with CS 23.1306, CS 25.1316, CS 27.1316, and CS 29.1316.
a. Identify Level A systems Level A systems should be identified as described in paragraph
6.c. The detailed system performance pass/fail criteria should be defined. The Agency
should concur on this criterion before the applicant begins testing or analysing their Level
A system. Specific equipment, components, sensors, power systems and wiring
associated with each Level A system should be identified in order to perform the ETDL
verification mentioned in paragraphs 8.g and 8.h.

AMC 20-136
Figure 2 — Typical compliance process for Level A systems
Note: Numbers in parentheses refer to sections in this AMC.

AMC 20-136
b. Establish the system’s ETDLs

Establish the aircraft system’s ETDLs from an evaluation of expected lightning transient
amplitudes and waveforms for the system installation, structure and wiring configuration
on a specific aircraft. ETDLs that exceed the ATLs by an acceptable margin should be
established. In general, the ETDLs for equipment in a complex system will not be the same
for all wire bundles connecting them to other equipment in the system. The applicant
may use results of lightning tests on existing similar aircraft, engineering analyses, or
knowledgeable estimates to establish the appropriate system’s ETDLs. While specific
aircraft configurations and system installations may lead to ETDLs that have amplitudes
and waveforms different than those defined in EUROCAE ED-14G, Section 22, ETDLs are
often specified using the information from Section 22. The ETDLs must exceed the ATLs
by an acceptable margin.
c. Determine the ATLs using aircraft tests
See SAE ARP 5415A, User’s Manual for Certification of Aircraft Electrical/Electronic
Systems Against the Indirect Effects of Lightning, and EUROCAE ED-105A for guidance on
how to determine the ATLs.
d. Determine the ATLs using analysis
See SAE ARP 5415A for guidance on how to analyse aircraft to determine the ATLs.
Acceptance of the analysis method choosen will depend on the accuracy of the method.
The applicant should confirm their analysis method accuracy using experimental data,
and gain agreement of their analysis approach from the Agency.
e. Determine the ATLs using similarity
1. Theuse of similarity to determine the ATLs may be used when:
a. there are only minor differences between the previously certified aircraft
and system installation and the aircraft and system installation to be
certified; and
b. there is no unresolved in-service history of problems related to lightning
strikes to the previously certified aircraft.
2. If significant differences are found that will affect the aircraft ATLs, the applicant
should perform more tests and analyses to resolve the open issues.
3. To use similarity, the applicant should assess the aircraft, wiring, and system
installation differences that can adversely affect the system’s susceptibility. When
assessing a new installation, consider the differences affecting the internal
lightning environment of the aircraft and its effects on the system. The assessment
should cover:
a. aircraft type, equipment locations, airframe construction, structural
materials, and apertures that could affect attenuation of the external
lightning environment;
b. system wiring size, length, and routing; wire types (whether parallel or
twisted wires), connectors, wire shields, and shield terminations;
c. lightning protection devices such as transient suppressors and lightning
arrestors; and
d. grounding and bonding.

AMC 20-136
4. Similarity cannot be used for a new aircraft design with new systems.
f. Determine the transient levels using ED-14G, Section 22, Guidance for Level A displays
only
1. The applicant may select ETDLs for their Level A display system using guidance in
this section, without specific aircraft test or analysis. Level A displays involve
functions for which the pilot will be in the loop through pilot–system information
exchange. Level A display systems typically include the displays; symbol
generators; data concentrators; sensors (such as attitude, air data, and heading
sensors); interconnecting wiring; and associated control panels.
2. This approach should not be used for other Level A systems, such as control
systems, because failures and malfunctions of those systems can more directly and
abruptly contribute to a catastrophic failure event than display system failures and
malfunctions. Therefore, other Level A systems require a more rigorous lightning
transient compliance verification programme.
3. Information in Table 3 should be used to evaluate aircraft and system installation
features in order to select the appropriate ETDLs for the system. Table 3 defines
test levels for ETDLs, based on EUROCAE ED-14G, Section 22, Tables 22-2 and 22-
3. The applicant should provide the Agency with a description of their aircraft and
display system installation features and compare these to the information in Table
3 to substantiate the ETDL selected for their aircraft and Level A display system
installation. When selecting ETDLs using guidance provided in Table 3, an
acceptable margin between the anticipated ATLs for display system installations is
incorporated in the selected ETDLs.
Table 3 — Equipment transient design levels — Level A displays
EUROCAE ED-14G
Section 22 Display system installation location
Level
Level 5 Use this level when the equipment under consideration, its associated wire bundles, or
other components connected by wiring to the equipment are in aircraft areas exposed
to very severe lightning transients. These areas are:
— areas with composite materials whose shielding is not very effective;
— areas where there is no guarantee of structural bonding; and
— other open areas where there is little shielding.
The applicant can also use this level to cover a broad range of installations.
The applicant may need higher ETDLs when there are high current density regions on
mixed conductivity structures (such as wing tips, engine nacelle fin, etc.) because the
system wiring may divert some of the lightning current. If the applicant is the system
designer, measures should be applied to reduce the need for higher ETDLs.
Level 4 Use this level when the equipment under consideration, its associated wire bundles, or
other components connected by wiring to the equipment are in aircraft areas exposed
to severe lightning transients. These areas are defined as outside the fuselage (such as
wings, fairings, wheel wells, pylons, control surfaces, etc.).

AMC 20-136
Level 3 Use this level when the equipment under consideration, its associated wire bundles,
and other components connected by wiring to the equipment are entirely in aircraft
areas with moderate lightning transients. We define these areas as the inside metal
aircraft structure or composite aircraft structure whose shielding without
improvements is as effective as metal aircraft structure. Examples of such areas are
avionics bays not enclosed by bulkheads, cockpit areas, and locations with large
apertures (that is, doors without electromagnetic interference (EMI) gaskets, windows,
access panels, etc.).
Current-carrying conductors in these areas (such as hydraulic tubing, control cables,
wire bundles, metal wire trays, etc.) are not necessarily electrically grounded at
bulkheads. When few wires exit the areas, either use a higher level (that is, Level 4 or 5)
for these wires or offer more protection for these wires.
and other components connected by wiring to the equipment are entirely in partially
protected areas. We define these areas as the inside of a metallic or composite aircraft
structure whose shielding is as effective as metal aircraft structure, if you take measures
to reduce the lightning coupling to wires.
Wire bundles in these areas pass through bulkheads, and have shields that end at the
bulkhead connector. When a few wires exit these areas, use either a higher level (that
is, Level 3 or 4) or provide more protection for these wires. Install wire bundles close to
the ground plane to take advantage of other inherent shielding from metallic structures.
Current-carrying conductors (such as hydraulic tubing, control cables, metal wire trays,
etc.) are electrically grounded at all bulkheads.
and other components connected by wiring to the equipment are entirely in well-
protected aircraft areas. We define these areas as electromagnetically enclosed.
g. Verify the system’s ETDLs using system qualification tests

1. The applicant should identify the equipment, components, sensors, power systems, and wiring
associated with the Level A system undergoing ETDL verification tests, specifically considering the
system functions whose failures have catastrophic consequences. For complex Level A systems, the
system configuration may include redundant equipment, multiple power sources, multiple sensors
and actuators, and complex wire bundles. Define the system configuration used for the ETDL
verification tests. The applicant should obtain an EASA approval of their system configuration for
ETDL verification tests.
2. Verify the ETDLs using single stroke, multiple stroke, and multiple burst tests on the system wire
bundles. Use waveform sets and test levels for the defined ETDLs. Demonstrate that the system
operates within the defined pass/fail criteria during these tests. No equipment damage should occur
during these system tests or during single stroke pin injection tests using the defined ETDLs. EUROCAE
ED-14G, Section 22, provides acceptable test procedures and waveform set definitions. In addition,
EUROCAE ED-105A provides acceptable test methods for complex and integrated systems.
3. Evaluate any system effects observed during the qualification tests to ensure they do not adversely
affect the system’s continued performance. The Level A system performance should be evaluated for
functions for which failures or malfunctions would prevent the continued safe flight and landing of
the aircraft. Other functions performed by the system for which failures or malfunctions would
reduce the capability of the aircraft or the ability of the flight crew to respond to an adverse operating
condition should be evaluated using the guidance in Chapter 10. The applicant should obtain an EASA
approval of their evaluation.
h. Verify the system’s ETDLs using existing system data (similarity)

1. The applicant may base their ETDL verification on similarity to previously certified systems without
performing more tests. This may be done when:
a. there are only minor differences between the previously certified system and installation and
the system and installation to be certified;

AMC 20-136
b. there are no unresolved in-service system problems related to lightning strikes on the
previously certified system; and
c. the previously certified system ETDLs were verified by qualification tests.
2. To use similarity to previously certified systems, the applicant should assess the differences between
the previously certified system and installation and the system and installation to be certified that
can adversely affect the system’s susceptibility. The assessment should cover:
a. system interface circuits;
b. wire size, routing, arrangement (parallel or twisted wires), connector types, wire shields, and
shield terminations;
c. lightning protection devices such as transient suppressors and lightning arrestors;
d. grounding and bonding; and
e. system software, firmware, and hardware.
3. If the applicant is unsure how the differences will affect the systems and installations, they should
perform more tests and analyses to resolve the open issues.
4. The applicant should assess every system, even if it uses equipment and installation techniques that
have a previous certification approval.
5. The use of similarity should not be used for a new aircraft design with new systems.
i. Verify compliance with the requirements

The applicant should compare the verified system ETDLs with the aircraft ATLs and determine if an acceptable
margin exists between the ETDLs and the ATLs. Margins account for uncertainty in the verification method.
As confidence in the verification method increases, the margin can decrease. An ETDL exceeding the ATL by
a factor of two is an acceptable margin for Level A systems, if this margin is verified by aircraft test or by
analysis supported by aircraft tests. For Level A display systems where the ETDLs are determined using
guidance provided in Table 3, an acceptable margin is already incorporated in the selected ETDLs. For other
verification methods, the margin should be agreed upon with the Agency.
j. Take corrective measures

1. When a system fails to meet the certification requirements, corrective actions should be selected.
Any changes or modifications made to the aircraft, system installation or the equipment may require
more testing and analysis.
2. To meet the certification requirements, the applicant may need to repeat system qualification
testing, or aircraft testing and analysis (in whole or in part). This may include modification to the
system or installation to get certification. The applicant should review these changes or modifications
with the Agency to determine if they are significant. If these changes or modifications are significant,
the applicant should update their lightning certification plan accordingly. The updated certification
plan should be resubmitted to the Agency for review.
9. LEVEL B AND C SYSTEM LIGHTNING CERTIFICATION

a. Identify Level B and C systems
1. The applicant should identify their Level B and C systems as described in paragraph 6.c.
2. The applicant should define the detailed system performance pass/fail criteria. They should obtain
the Agency’s concurrence on this criterion before starting tests or analyses of Level B and C systems.
3. Figure 3 illustrates a process the applicant can use to demonstrate that their Level B and C systems
comply with the CS requirements.

AMC 20-136
Figure 3 — Typical compliance process for Level B and C systems
Note: Numbers in parentheses refer to sections in this AMC.
b. Establish the ETDLs

1. ATLs determined during aircraft tests or analyses performed for Level A systems to establish the
appropriate ETDLs for Level B and C systems.
2. Alternatively, the applicant may use the definitions in EUROCAE ED-14G, Section 22, to select the
appropriate ETDLS for their Level B and C systems. The following should be considered when selecting
an appropriate level:
a. Use EUROCAE ED-14G, Section 22, Level 3 for most Level B systems.
b. For Level B systems and associated wiring installed in aircraft areas with more severe lightning
transients, use EUROCAE ED-14G, Section 22, Level 4 or 5 as appropriate to the environment.
Examples of aircraft areas with more severe lightning transients are those external to the
fuselage, areas with composite structures showing poor shielding effectiveness, and other
open areas.
c. Use EUROCAE ED-14G, Section 22, Level 2 for most Level C systems.

AMC 20-136
d. For Level C systems installed in aircraft areas with more severe lightning transients, use
EUROCAE ED-14G, Section 22, Level 3. Examples of aircraft areas with more severe lightning
transients are those external to the fuselage, areas with composite structures showing poor
shielding effectiveness, and other open areas.
e. The applicant should provide the Agency with a description of their aircraft and system
installation features to substantiate the EUROCAE ED-14G, Section 22, levels selected for their
system.
c. Verify the system’s ETDLs using equipment qualification tests

1. Equipment qualification tests should be performed using the selected test levels and single stroke,
multiple stroke, and multiple burst waveform sets. It should be demonstrated that the equipment
operates within the defined pass/fail criteria during these tests. No equipment damage should occur
during these equipment qualification tests or during single stroke pin injection tests using the defined
ETDLs. EUROCAE ED-14G, Section 22, provides acceptable test procedures and waveform set
definitions.
2. Any equipment effects observed during the qualification tests should be evaluated to ensure that
they do not adversely affect the system’s continued performance. The applicant should obtain the
Agency’s approval of their evaluation.
3. Multiple stroke and multiple burst testing is not required if an analysis shows that the equipment is
not susceptible to upset, or that the equipment may be susceptible to upset but a reset capability
exists so that the system recovers in a timely manner.
d. Verify the system’s ETDLs using existing equipment data (similarity)

1. ETDLs may be verified by similarity to previously certified systems without performing more tests.
The applicant may do this when:
a. there are only minor differences between the previously certified system and installation and
the system and installation to be certified;
b. there are no unresolved in-service system problems related to lightning strikes on the
previously certified system; and
c. the previously certified system ETDLs were verified by qualification tests.
2. The assessment should cover:
a. equipment interface circuits;
b. wire size, routing, arrangement (parallel or twisted wires), connector types,

wire shields, and shield terminations;
c. lightning protection devices such as transient suppressors and lightning
arrestors;
d. grounding and bonding; and
e. equipment software, firmware, and hardware.
3. If significant differences are found that will affect the systems and installations, the
applicant should perform more tests and analyses to resolve the open issues.
e. Verify compliance with the requirements
The applicant should demonstrate that the Level B and C systems meet their defined
acceptance criteria during the qualification tests at the selected system ETDLs.
f. Take corrective measures
When a system fails to meet the certification requirements, the applicant should decide
on corrective actions. If they change or modify the system or installation, equipment
qualification testing may need to be repeated. The applicant should review these changes
or modifications with the Agency to determine if they are significant. If these changes or

AMC 20-136
modifications are significant, the applicant should update their lightning certification plan
accordingly. The updated certification plan should be resubmitted to the Agency for
review.
10. MAINTENANCE AND SURVEILLANCE
a. The applicant should identify the minimum maintenance required for the aircraft
electrical and electronic system lightning protection in the Instructions for Continued
Airworthiness (ICA). The applicant should define the requirements for periodic and
conditional maintenance and surveillance of lightning protection devices or features to
ensure acceptable protection performance while the aircraft is in service. Avoid using
devices or features that may degrade with time because of corrosion, fretting, flexing
cycles, or other causes. Alternatively, identify when to inspect or replace these devices.
b. The applicant should define the inspection techniques and intervals needed to ensure
that the aircraft and system lightning protection remains effective in service. Also,
identify built-in test equipment, resistance measurements, continuity checks of the entire
system, or other means to determine the system’s integrity periodically and
conditionally.
c. See SAE ARP 5415A for more information on aircraft lightning protection maintenance
and surveillance.
[Amdt 20/13]

AMC 20-136
Appendix 1 to AMC 20-136 Definitions and acronyms

a. Definitions
Actual Transient Level (ATL): The level of transient voltage or current that appears at the
equipment interface circuits because of the external environment. This level may be less than
or equal to the transient control level, but should not be greater.
Aperture: An electromagnetically transparent opening.
Attachment point: A point where the lightning flash contacts the aircraft.
Component damage: A condition in which transients permanently alter the electrical
characteristics of a circuit. Because of this, the component can no longer perform to its
specifications.
Continued safe flight and landing: The aircraft can safely abort or continue a take-off, or
continue controlled flight and landing, possibly using emergency procedures. The aircraft must
do this without requiring exceptional pilot skill or strength. Some aircraft damage may occur
because of the failure condition or on landing. For large aeroplanes, the pilot must be able to
land safely at a suitable airport.
For CS-23 aeroplanes, it is not necessary to land at an airport. For rotorcraft, the rotorcraft must
continue to cope with adverse operating conditions, and the pilot must be able to land safely at
a suitable site.
Direct effects: Physical damage to the aircraft or electrical and electronic systems. Direct
attachment of lightning to the system’s hardware or components causes the damage. Examples
of direct effects include tearing, bending, burning, vaporisation, or blasting of aircraft surfaces
and structures, and damage to electrical and electronic systems.
Equipment Component of an electrical or electronic system with interconnecting electrical
conductors.
Equipment Transient Design Level (ETDL): The peak amplitude of transients to which
equipment is qualified.
External environment: The natural lightning environment, outside the aircraft, for design and
certification purposes. See EUROCAE ED-84A, which reference documents that provide
additional guidance on aircraft lightning environment and related waveforms.
Indirect effects: Electrical transients induced by lightning in aircraft electrical or electronic
circuits.
Internal environment: The potential fields and structural voltages inside the aircraft produced
by the external environment.
Lightning flash: The total lightning event. It may occur in a cloud, among clouds, or between a
cloud and the ground. It can consist of one or more return strokes, plus intermediate or
continuing currents.
Lightning strike: Attachment of the lightning flash to the aircraft.
Lightning strike zones: Aircraft surface areas and structures that are susceptible to lightning
attachment, dwell time, and current conduction. See EUROCAE ED-91, which references
documents that provide additional guidance on aircraft lightning zoning.

AMC 20-136
Lightning stroke (return stroke): A lightning current surge that occurs when the lightning leader
(the initial current charge) makes contact with the ground or another charge centre. A charge
centre is an area of high potential of opposite charge.
Margin: The difference between the equipment transient design levels and the actual transient
level.
Multiple burst: A randomly spaced series of bursts of short duration, low amplitude current
pulses, with each pulse characterised by rapidly changing currents. These bursts may result as
the lightning leader progresses or branches, and are associated with the cloud-to-cloud and
intra-cloud flashes. The multiple bursts appear most intense when the initial leader attaches to
the aircraft. See EUROCAE ED-84A.
Multiple stroke: Two or more lightning return strokes during a single lightning flash. See
EUROCAE ED-84A.
Transient Control Level (TCL): The maximum allowable level of transients that appear at the
equipment interface circuits because of the defined external environment.
b. Acronyms
AC: Advisory Circular
AMC: Acceptable Means of Compliance
ARP: Aerospace Recommended Practice
ATL: Actual Transient Level
CS: Certification Specification
ETDL: Equipment Transient Design Level
EASA: European Aviation Safety Agency
EUROCAE: European Organization for Civil Aviation Equipment
FAA: Federal Aviation Administration
ICA: Instructions for Continued Airworthiness
TCL: Transient Control Level
[Amdt 20/13]

AMC 20-152A
AMC 20-152A
AMC 20-152A Development Assurance for Airborne Electronic

Hardware (AEH)
1 PURPOSE
1.1 This AMC describes an acceptable means, but not the only means, for showing compliance with
the applicable airworthiness regulations for the electronic hardware aspects of airborne systems and
equipment in product certification or ETSO authorisation. Compliance with this AMC is not mandatory,
and an applicant may elect to use an alternative means of compliance. However, the alternative
means of compliance must meet the relevant requirements, ensure an equivalent level of safety, and
be approved by EASA on a product or ETSO article basis.
1.2 This AMC recognises EUROCAE ED-80, Design Assurance Guidance for Airborne Electronic
Hardware, dated April 2000, and RTCA DO-254, Design Assurance Guidance for Airborne Electronic
Hardware, dated 19 April 2000.
1.3 This AMC describes when to apply EUROCAE ED-80/RTCA DO-254, and it supplements EUROCAE
ED-80/RTCA DO-254 with additional guidance and clarification for the development of custom devices,
including the use of commercial off-the-shelf (COTS) intellectual property (IP), for the use of COTS
devices and for the development of circuit board assemblies (CBAs).
The additional guidance and clarifications are provided in the form of objectives. The applicant is
expected to describe the process and activities to satisfy the objectives of this AMC.
Note: EUROCAE ED is hereafter referred to as ‘ED’; RTCA DO is hereafter referred to as ‘DO’. Where
the notation ‘ED-80/DO-254’ appears in this document, the referenced documents are recognised as
being equivalent.
1.4 This AMC does not address the Single Event Effects (SEE) aspects or the assessment of the
hardware susceptibility to SEE. AMC SEE aspects are usually addressed through a certification review
item (CRI), and further guidance may be found in EASA CM-AS-004 Issue 01, issued 8 January 2018.
However, the Plan for Hardware Aspects of Certification may still be used to document the
certification considerations for SEE.
2 APPLICABILITY
This AMC may be used by applicants, design approval holders, and developers of airborne systems
and equipment containing airborne electronic hardware (AEH) to be installed on type-certified
aircraft, engines, and propellers. This applicability includes the developers of ETSO articles.
This AMC is applicable to AEH that contributes to hardware development assurance level (DAL) A, DAL
B, or DAL C functions.
When an objective is not applicable to a specific hardware DAL, the applicability restriction is directly
indicated within the objective text with the following convention, for instance ‘For DAL A hardware,
…’ For AEH contributing to hardware DAL C functions, only a limited set of objectives applies.
Even though there is a benefit in having a structured development process that ensures a proper flow-
down of requirements to the hardware and the fulfilment by the hardware of the intended function,
the use of this AMC is not required for AEH contributing to hardware DAL D functions. Appendix B
provides some clarifications that may be used to ensure that the DAL D hardware performs its
intended function.

AMC 20-152A
3 DOCUMENT HISTORY
This document is the initial issue of AMC 20-152. This initial issue, jointly developed with FAA, is
intentionally set at Revision A.
4 BACKGROUND
This AMC is related to the development of custom devices in AEH, including the use of commercial
off-the-shelf intellectual property (COTS IP) within custom devices, the use of COTS devices, and the
development of circuit board assemblies (CBAs). Each of these topics is organised with:
background information dedicated to each major topic,
— applicability, and
— sections where objectives are described and uniquely identified.
A unique identifier for each objective is defined with a prefix and an index number (i) as follows:
— for the development of custom devices, the identifier is ‘CD-i’;
— for the use of COTS IP in custom devices, the identifier is ‘IP-i’;
— for the use of COTS devices, the identifier is ‘COTS-i’;
— for the development of CBAs, the identifier is ‘CBA-i’.
Objectives are also differentiated from the rest of the text by formatting in italics.
The applicant should document in the Plan for Hardware Aspects of Certification (PHAC), or any other
related planning document, the process and activities that the applicant intends to perform to satisfy
the objectives of this AMC. The PHAC, as well as those related planning documents, should be
submitted for certification.
5 CUSTOM DEVICE DEVELOPMENT
This section provides guidance for the development assurance of programmable logic devices (PLDs),
field-programmable gate arrays (FPGAs), or application-specific integrated circuits (ASICs), which are
collectively referred to as ‘custom devices’. These custom devices are addressed in ED-80/DO-254,
Section 1.2, Item 3 as ‘custom micro-coded components’.
Developing a custom device demands a well-defined development process. However, it is understood
that the process to develop complex custom devices requires more comprehensive activities and
artefacts than for a simple device.
Section 5.1 identifies custom devices that are within the scope of this AMC.
Section 5.2 provides guidance on simple/complex classification for custom devices.
Section 5.3 provides guidance on development assurance for complex custom devices.
Section 5.4 provides guidance on development assurance for simple custom devices. In particular,
Section 5.4 defines which sections from 5.5 to 5.11 are applicable to the development assurance of
simple electronic devices.
Sections 5.5 to 5.10 provide clarifications on ED-80/DO-254.
Section 5.11 provides background information and guidance specific to COTS IP used in custom
devices.

AMC 20-152A
5.1 Applicability to Custom Devices

Section 5 is applicable to a digital- or mixed-signal custom device that contributes to hardware DAL A,
B or C functions.
Appendix A to ED-80/DO-254 modulates the ED-80/DO-254 life-cycle data based on the DAL allocated
to the hardware function. This document recognises Appendix A for the modulation of the life-cycle
data according to the hardware DAL for the development of custom devices.
5.2 Simple/Complex Classification
ED-80/DO-254 introduces the notion of simple and complex hardware items. This section clarifies and
provides criteria that could be used to classify a device as simple by considering the design content of
the custom device, and subsequently, the ability to comprehensively verify the device.
A hardware custom device is classified as simple only if a technical assessment of the design content
supports the ability of the device to be verified by a comprehensive combination of deterministic tests
and analyses that ensure correct functional performance under all foreseeable operating conditions
with no anomalous behaviour. The following criteria should be used for assessing whether a device
should be classified as simple:
— simplicity of the functions and their number,
— number and the simplicity of the interfaces,
— simplicity of the data/signal processing or transfer functions, and
— independence of functions/blocks/stages.
Additional criteria specific to the digital part of the design include:
— whether the design is synchronous or asynchronous,
— number of independent clocks,
— number of state machines, number of states and state transitions per state machine, and
— independence between the state machines.
The applicant may propose other or additional criteria for the technical assessment of simplicity.
When an item cannot be classified as simple, it should be classified as complex. However, note that
an item constructed entirely from simple items may itself be complex.
Objective CD-1
For each custom device, the applicant should document in the PHAC or any related planning document:
1. the development assurance level,
2. the simple or complex classification, and
3. if a device is classified as simple, the justification based on the simple classification criteria.
5.3 Development Assurance for Complex Custom Devices
ED-80/DO-254 is recognised as the industry standard for the development assurance of complex
custom devices.
The applicant should satisfy ED-80/DO-254 and the additional objectives or clarifications described in
this AMC from Sections 5.5 to 5.11.

AMC 20-152A
5.4 Development Assurance for Simple Custom Devices

For the development of simple custom devices, it is understood that the life-cycle data might be
significantly reduced compared with the data required for a complex custom device.
ED-80/DO-254 acknowledges that the documentation for the design process of a simple hardware
device is less extensive than the one needed for a complex device. In addition, while verification and
configuration management are also needed, these supporting processes also require less
documentation for a simple device.
However, it is important that a simple custom device performs its intended function, and is under
configuration management, thus allowing the device to be reproduced, conformed, and analysed to
ensure continued operational safety.
Objective CD-2
The applicant should propose a process in the PHAC, or any other appropriate planning document, to
develop simple custom devices which encompasses the following:
1. definition of the device functions,
2. complete verification of the device functions through tests and analyses,
3. configuration management of the device, including problem reporting and the instructions to
reproduce the device,
4. assessment of the build conformance of the device.
Sections 5.5.2.4 and 5.5.2.5 of this document also apply to the verification process for simple custom
devices.
The life-cycle data for simple devices can be combined with other hardware data.
If tools are used for the simple custom device development process, the objectives or clarifications of
those objectives described in Section 5.8 of this document are also applicable.
When the applicant intends to reuse a previously developed simple device, ED-80/DO-254 Section
11.1 and the clarifications provided in Section 5.9 of this document should be used.
If the applicant intends to use COTS IP, the objectives or clarifications of those objectives described in
Section 5.11 of this document are also applicable.
5.5 Clarifications to ED-80/DO-254 Validation and Verification Processes
5.5.1 Validation Process
Establishing a correct and complete set of requirements is the cornerstone of the development
assurance process. ED-80/DO-254 Section 6.1 addresses the validation process to ensure the
completeness and correctness of derived requirements. Nevertheless, the validation process is
essential for all the requirements. Indeed, the upper-level requirements allocated to the custom
device are often refined, decomposed or restated at the custom device level, and in terms that support
the hardware design. These custom device requirements, which are traceable from/to the upper-level
requirements and, therefore, not considered to be ‘derived’, should also be correct and complete.
Objective CD-3
The applicant should validate all the custom device requirements by following the ED-80/DO254
validation process (ED-80/DO-254 Section 6). This validation activity covers both derived and non-
derived requirements.
For DAL A and B development, validation activities should be performed with independence.

AMC 20-152A
Note: ED-80/DO-254 Appendix A defines acceptable means for establishing independence.

5.5.2 Verification Process
ED-80/DO-254 broadly describes the verification process, but additional guidance is needed to ensure
the verification of the custom device is complete, particularly in the area of:
— design reviews,
— reviews of test cases and procedures, and
— verification of the implementation.
5.5.2.1 Conceptual Design Review
Conceptual design is the process of generating a high-level design description from the hardware
requirements (see ED-80/DO-254 Section 5.2). The conceptual design review is typically used to
ensure that the outcome of the conceptual design activities (see ED-80/DO254 Section 5.2.2) is
consistent with the requirements, and identifies constraints for the interfacing components (hardware
or software) and architectural constraints for the detailed design activities of the custom device.
Since this conceptual design review is already addressed in ED-80/DO-254 Section 5.2.2 through the
note, no separate objective is needed.
5.5.2.2 Detailed Design Review
Detailed design is the process of generating, from the conceptual design and the requirements, a
hardware description language (HDL) or analogue representation of the design, constraints for the
implementation (e.g. timing constraints, pinout, I/O characteristics), and the hardware– software
interface description.
ED-80/DO-254 introduces design reviews in Section 6.3.3.2. A design review is considered to be an
essential step during the detailed design process (ED-80/DO-254 Section 5.3) supporting the
implementation process, and complementing requirements-based verification.
Objective CD-4
For hardware DAL A or DAL B, the applicant should review the detailed design with respect to the
design standards, and review the traceability between the detailed design and the custom device
requirements, in order to demonstrate that the detailed design covers the custom device requirements,
is consistent with the conceptual design, and is compliant with the hardware design standards.
For hardware DAL C, the applicant should demonstrate that the detailed design satisfies the hardware
design standards.
5.5.2.3 Implementation Review
Within a custom device development process, tools are used to convert the detailed design data into
the physical implementation. While ED-80/DO-254 does not explicitly address it, a review of the design
tool reports (e.g. synthesis and place and route reports) is necessary to ensure that the execution of
the tool to generate its output was performed correctly.
Objective CD-5
When tools are used to convert the detailed design data into the physical implementation, the
applicant should review the design tool reports (e.g. synthesis and place and route reports) to ensure
that the tool executed properly when generating the output.

AMC 20-152A
5.5.2.4 Review of Verification Cases and Procedures

ED-80/DO-254 introduces verification coverage analysis in Section 6.2.2 Item 4 to satisfy the ED-
80/DO-254 verification process objectives and determine whether the verification process is correct
and complete. A part of the coverage analysis is clarified by the following objective.
Objective CD-6
Each verification case and procedure should be reviewed to confirm that it is appropriate for the
requirements to which it traces and that the requirements are correctly and completely covered by the
verification cases and procedures.
5.5.2.5 Verification of the Timing Performance of the Implementation
ED-80/DO-254 Section 6.2 addresses the verification of the implementation. The implementation
results from the process to generate the physical custom device from the detailed design data. The
post-layout netlist is the closest virtual representation of the physical custom device, resulting from
synthesis (for the digital part of the device) and place and route.
While it is recommended to test the implementation in its intended operational environment (i.e. by
a physical test), verification using the post-layout netlist may be necessary to complement the
verification of the implementation for certain requirements (e.g. features not accessible from the I/O
pins of the device, timing, abnormal conditions, or robustness cases). In such cases, the coverage of
the requirements by means other than a physical test should be justified.
The requirement to capture the activities in ED-80/DO-254 Section 5.1.2 Item 4.g introduces the need
for the requirements to address signal timing characteristics under normal- and worst-case conditions.
Nevertheless, ED-80/DO-254 does not explicitly address the necessity to verify the performance of the
device under all possible (best-case and worst-case) timing conditions that could possibly occur during
the operation of the device.
The following objective clarifies the need to take into account the variation of the environmental
conditions (temperature, voltage, etc.) during the evaluation of the timing performance of the design,
as well as the semiconductor device process variations.
Objective CD-7
The applicant should verify the timing performance of the design accounting for the temperature and
power supply variations applied to the device and the semiconductor device fabrication process
variations as characterised by the manufacturer of the semiconductor device.
Note: Static timing analysis (STA) with the necessary timing constraints and conditions is one of the
possible means of compliance with this objective for the digital parts of custom devices.
5.6 Clarifications to ED-80/DO-254 ‘Robustness Aspects’
ED-80/DO-254 mentions robustness defects but does not explicitly address robustness. The
robustness of the design is defined as the expected behaviour of the design under abnormal and
boundary/worstcase operating conditions of the inputs and internal design states. These conditions
are often captured as derived requirements when they are not allocated from the upper-level process.
When subjected to these conditions, it is understood that the design may not continue to perform as
it would under normal conditions.
Objective CD-8
For DAL A or DAL B hardware, the abnormal and boundary conditions and the associated expected
behaviour of the design should be defined as requirements.

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5.7 Recognition of HDL Code Coverage Method

HDL code coverage analysis is an assessment of whether the HDL code of the design has been
exercised through HDL simulations.
The HDL code coverage method provides an assessment of the coverage of the design logic structure,
giving an indication of which aspects of the logic structure are exercised and which are not.
When performed during requirements-based verification (per ED-80/DO-254 Section 6.2), HDL code
coverage is recognised as a method to perform ED-80/DO-254 elemental analysis per Appendix B
Section 3.3.1 for digital devices. HDL code coverage supports the assessment of whether the HDL code
elements are fully covered by requirements-based simulations. As such, it does not represent an
assessment of the completeness of the requirements-based testing activities or the effectiveness of
the requirement coverage.
Objective CD-9
For hardware DAL A or DAL B, where HDL code coverage is used to perform elemental analysis (ED-
80/DO-254 Appendix B Section 3.3.1), the applicant should define in the planning documents the
detailed coverage criteria of the HDL code elements used in the design. The criteria should ensure
coverage over the various cases of the HDL code elements used in the design (e.g. branches, conditions,
etc.). Any non-covered case or element should be analysed and justified.
Note: Code coverage might need to be complemented by additional analysis for any hardware items
that are identified as not covered by the code coverage analysis, in order to complete the elemental
analysis of all elements. This situation may occur in the use of some COTS IP instantiations.
5.8 Clarifications to ED-80/DO-254 ‘Tool Assessment and Qualification’
ED-80/DO-254 introduces the notion of tool assessment and qualification. ED-80/DO-254 Figure 11-1
includes a flow chart indicating the tool assessment considerations and activities, and provides
guidance for when tool qualification may be necessary. This AMC uses the flow chart and its related
text as a basis for providing further clarification, as follows:
ED-80/DO-254 — Figure 11-1 Item 1 — Identify the Tool
Information capturing the environment required for tool operation and the tool revision should be
included with the tool identification.
ED-80/DO-254 — Figure 11-1 Item 2 — Identify the Process the Tool Supports
When identifying the design or verification process that the tool supports, it is important to also
identify what purpose or activity within the hardware development process the tool satisfies. While
assessing the tool limitations, evidence of formal assessment of the tool problem reports is not
required if the tool output has been completely and independently assessed.
ED-80/DO-254 — Figure 11-1 Item 3 — Is the Tool Output Independently Assessed?
The purpose of assessing the tool output is to completely cover, with an independent means, the
potential errors that the tool could introduce into the design or fail to detect during verification.
Objective CD-10
When the applicant intends to independently assess a tool output, the applicant should propose an
independent assessment that verifies the tool output is correct. The independent assessment should
justify that there is sufficient coverage of the tool output. The completeness of the tool assessment
should be based on the design/implementation and/or verification objectives that the tool is used to
satisfy.

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ED-80/DO-254 — Figure 11-1 Item 4 — Is the Tool a Level A, B or C Design Tool or a Level A or B
Verification Tool?
ED-80/DO-254 Figure 11-1 Item 4 of the tool assessment/qualification flow excludes the need for
activities for tools ‘used to assess the completion of verification testing, such as in an elemental
analysis’.
The last statement is misleading regarding the intent of code coverage tools used for elemental
analysis. As stated in Section 5.7 of this document, ‘when a code coverage tool is used for elemental
analysis, it does not represent an assessment of the completeness of the requirements-based testing
activities or the effectiveness of the requirement coverage’.
It is therefore necessary to provide some further clarifications.
— This document recognises the Figure 11-1 Item 4 exclusion of tool assessment/qualification
activities for code coverage tools only when they are used to assess whether the code has been
exercised by requirements-based testing/simulations (elemental analysis).
— If test cases or procedures are automatically generated by a tool and this tool uses coverage to
determine the completion of the requirements verification, then the tool should be considered
to be a verification tool to answer the question raised in Figure 11-1 Item 4.
ED-80/DO-254 — Figure 11-1 Item 5 — Does the Tool have Relevant History?
In ED-80/DO-254, the supporting text for Figure 11-1 Item 5 can be misinterpreted to suggest that
when the tool has been previously used, no further tool assessment is necessary. Item 5 should be
understood to mean that the applicant will provide sufficient data and justification to substantiate the
relevance and credibility of the tool history.
Objective CD-11
When the applicant intends to claim credit for the relevant history of a tool, sufficient data should be
provided as a part of the tool assessment to demonstrate that there is a relevant and credible tool
history to justify that the tool will produce correct results for its proposed use.
ED-80/DO-254 — Figure 11-1 Item 9 — Design Tool Qualification
For design tools, contrary to the note in the supporting text for Figure 11-1 Item 9, the tool history
should not be used as a stand-alone means of tool assessment and qualification. A relevant tool history
may be used to compensate for some particular gaps in the tool assessment and qualification process,
for example, to explain the method of independent assessment of the tool output. In this case, a
relevant tool history is considered to be complementary data, providing more assurance for a tool.
In addition to what is already referenced in ED-80/DO-254 Figure 11-1 Item 9 for tool qualification
guidance, ED-12C/DO-178C and ED-215/DO-330 may also be used.
5.9 Clarifications to ED-80/DO-254 regarding Previously Developed Hardware (PDH)
Previously developed hardware (PDH) is defined as custom-developed hardware that has been
installed in an airborne system or equipment either approved through EASA type certification (TC/STC)
or authorized through ETSOA. The section providing clarification on the use of PDH also covers PDH
that was developed and approved prior to the use of ED-80/DO-254 in civil certification.
This section provides guidance on the use of ED-80/DO-254 Section 11.1 for PDH.
Objective CD-12
When an applicant proposes to reuse PDH, the applicant should use ED-80/DO-254 Section 11.1 and
its subordinate paragraphs. The applicant should perform the assessments and analyses required in

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ED-80/DO-254 Section 11.1 in order to ensure that using the PDH is valid and that the compliance
shown during the previous approval was not compromised by any of the following:
1. Modification of the PDH for the new application or for obsolescence management;
2. Change to the function, change to its use, or change to a higher failure condition classification
of the PDH in the new application; or
3. Change to the design environment of the PDH.
The results should be documented in the PHAC or any other appropriate planning document.
In the context of custom device development, any one of these three points potentially invalidates the
original development assurance credit for the PDH. In case of change or modification, the applicant
should assess these changes using ED-80/DO-254 Section 11.1 and its subordinate paragraphs. When
the original design assurance of the PDH is invalidated by one of the above points, the custom device
should be upgraded based on the assessment per ED-80/DO-254 Section 11.1. When upgrading the
hardware, the applicant should consider the objectives of this document that are applicable per the
assessment.
5.10 Clarifications to ED-80/DO-254 Appendix A
This section clarifies the life-cycle data referenced in ED-80/DO-254 Appendix A as follows.
— The row corresponding to 10.1.6 ‘Hardware Process Assurance Plan’ in Table A-1 should also
indicate HC2 for Level C to be consistent with row 10.8.
— The row corresponding to 10.2.2 ‘Hardware Design Standard’ in Table A-1 should also indicate
HC2 for Level C. HDL Coding Standards are part of the Hardware Design Standards.
— The row corresponding to 10.3.2.2 ‘Detailed Design Data’ in Table A-1 should indicate HC1 for
Levels A, B and C.
— The row corresponding to 10.4.2 ‘Hardware Review and Analysis Procedures’ in Table A-1
should also indicate HC2 for Level C to be consistent with row 10.4.3.
— The Top-Level Drawing referenced in ED-80/DO-254 Appendix A corresponds to a Hardware
Configuration Index (HCI) document. The HCI document completely identifies the hardware
configuration, the embedded logic, and the development life-cycle data. To support consistent
and accurate replication of the custom device (ED-80/DO-254 Section 7.1), the Top-Level
Drawing includes the hardware life cycle environment or refers to a Hardware Environment
Configuration Index (HECI) document.
5.11 Use of COTS IP in Custom Device Development
This section addresses COTS IP that is instantiated within FPGAs/PLDs/ASICs during the development
of the custom device.
This section addresses COTS IP and its integration within custom devices and describes objectives to
support the demonstration of compliance with the applicable airworthiness regulations for the
hardware aspects of airborne systems and equipment certification.
Section 5.11.2, on ‘Applicability to COTS IP’, identifies COTS IP that are within the scope of
Section 5.11.
5.11.1Background
IP refers to design functions (design modules or functional blocks, including IP libraries) used to design
and implement a part of or a complete custom device such as a PLD, FPGA, or ASIC. IP is considered
to be commercial off-the-shelf intellectual property, i.e. ‘COTS IP’, when it is a commercially available

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function, used by a number of different users, in a variety of applications and installations. Custom IP,
developed for a few specific aircraft equipment, is not considered to be COTS IP.
COTS IP are available in various source formats. COTS IP are categorised as Soft IP, Firm IP, or Hard IP
based on the stage in the custom device design flow where the IP is instantiated. A function can be a
combination of source formats and each part needs to be addressed. Definitions for Soft IP, Firm IP,
and Hard IP can be found in Appendix A ‘Glossary’.
Figure 1 shows a ‘simplified’ design flow of a PLD, FPGA, or ASIC, and where Soft IP, Firm IP, and Hard
IP are located in the design flow.
Figure 1 — Position of COTS IP within a ‘simplified’ design representation flow
The availability of a COTS IP does not guarantee that it is suitable to be used in a custom device for
aircraft systems. Some COTS IP may have been developed using ED-80/DO-254, and will therefore
have the necessary life-cycle data to demonstrate satisfaction of ED-80/DO-254. However, most COTS
IP are not developed to meet aviation development assurance standards and, therefore, there are
risks associated with their use in a custom device for aircraft systems or equipment.
The risks of using COTS IP may include:
— Incomplete or missing documentation/data regarding:
— the behavioural operation of the COTS IP,
— how to integrate it into the design;
— Insufficient verification performed by the COTS IP provider;
— Deficient quality of the COTS IP.
The potential for design errors may be increased by the lack of development assurance and/or by
insufficient service experience.
Possible design errors within COTS IP or in the use of COTS IP may lead to a failure mode. Risk factors
for these types of errors include:
— Unknown level of rigour of the COTS IP design and verification process;
— Misalignment between the intended usage of the COTS IP by the IP provider and the usage in
the custom device by the IP user;
— Incomplete or missing details regarding the detailed operation of the COTS IP;
— Incorrect integration of the COTS IP with the rest of the custom device design;
— Integrator lacking expertise with the function of the IP.
Additionally, the COTS IP user completes the development of the integrated COTS IP up to the physical
implementation of the device. The COTS IP user may introduce a design error while completing the
physical implementation of the COTS IP because of the user’s incomplete knowledge of the internal
design of the COTS IP.

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5.11.2Applicability to COTS IP
Section 5.11 is applicable to COTS IP used in a custom device that meets the definition of ‘commercial
off-the-shelf intellectual property’ in the Glossary of Appendix A. This scope encompasses digital,
analogue, and mixed-signal COTS IP.
Note: Analogue COTS IP is within the above-mentioned scope, as it could be instantiated within a
custom, mixed-signal device.
Section 5.11 is applicable to COTS IP contributing to hardware DAL A, B or C functions.
Section 5.11 is applicable to Soft IP, Firm IP, and Hard IP that are inserted within a custom device by
the applicant. However, Section 5.11 does not apply to Hard IP that is embedded in the silicon of an
FPGA or a PLD by the FPGA/PLD device manufacturer. This type of IP is considered to be part of the
COTS device, and is covered in Section 6 ‘Use of Commercial Off-the-Shelf Devices.
5.11.3Development Assurance for COTS IP
A COTS IP development assurance approach should be based on the category of the COTS IP (Soft,
Firm, Hard) and on the identified risks of failure due to a design error in the COTS IP itself or an error
in the way it is used in the custom device.
This section provides objectives addressing development assurance when using COTS IP. These
objectives are intended to cover the particular aspects of development when using COTS IP, and are
expressed in connection with the custom device development process that follows ED-80/DO-254 and
the custom device objectives of this document.
The development aspects related to COTS IP start from the custom device process that captures the
allocated requirements for the function that will be performed by the COTS IP. From this entry point,
the following aspects provide a basis to define the development assurance objectives for the use of
COTS IP:
— Selection of the COTS IP,
— Assessment of the IP provider and the IP data,
— Planning activities, including the verification strategy,
— Definition of the requirements/derived requirements,
— Design integration, implementation, and verification of the COTS IP in the custom device.
5.11.3.1 Selection of the COTS IP to implement the function
COTS IP can be available in different forms/source formats and various levels of quality. Some COTS
IP may not be acceptable for use in airborne systems. The selection criteria below are intended to
address the essential characteristics that are considered a minimum for the use of IP in custom AEH
devices.
Objective IP-1
The applicant should select a COTS IP that is considered to be an acceptable solution, based on at least
the following criteria:
1. The IP is technically suitable for implementing the intended function;
2. The description of the COTS IP architecture or IP design concept provides an understanding of
the functionality, modes, and configuration of the IP. The description should also include an
understanding of the source format or combination of source formats of the COTS IP;

AMC 20-152A
3. The availability and quality of data and documentation allow the understanding of all aspects
of the COTS IP functions, modes, and behaviour, and enable the integration and verification of
the COTS IP (e.g. datasheets, application notes, user guide, knowledge of errata, etc.);
4. Information exists for the IP user to be able to create the physical implementation of the COTS
IP (e.g. synthesis constraints, usage and performance limits, physical implementation, and
routing instructions);
5. It can be demonstrated that the COTS IP fulfils its intended function.
5.11.3.2 Assessment of the COTS IP Provider and COTS IP Data
Objective IP-2
The applicant should assess the COTS IP provider and the associated data of the COTS IP based on at
least the following criteria:
1. The IP provider provides all the information necessary for the integration of the COTS IP within
the custom device and to support the implementation of the COTS IP within the device (e.g.
synthesis constraints, usage domain, performance limits, physical implementation, and routing
instructions);
2. The configurations, selectable options, and scalable modules of the COTS IP design are
documented so that the implementation of the COTS IP can be properly managed;
3. The COTS IP has been verified by following a trustworthy and reliable process, and the
verification covers the applicant’s specific use case for the COTS IP (including the used scale for
scalable IP and the IP functions selected for selectable functions);
4. The known errors and limitations are available to the IP user, and there is a process to provide
updated information to the IP user;
5. The COTS IP has service experience data that shows reliable operation for the applicant’s specific
use case for the COTS IP.
The assessment should be documented. The results of the assessment should be submitted together
with the planning documents.
5.11.3.3 Planning of the Hardware Development Assurance Approach related to COTS IP
5.11.3.3.1 Complementary Development Assurance
Objective IP-3
When the IP-2 Objective criteria items 1, 2, 4 or 5 cannot be completely met using the IP provider’s
data, the applicant should define an appropriate development assurance activity to mitigate the
criteria that were not met and address the associated risk of development errors. The development
assurance activity should be based on the ED-80/DO-254 objectives.
Note: The results of the assessment of Objective IP-2 Item 3 are considered in Section 5.11.3.3.2.
5.11.3.3.2 The Verification Strategy for COTS IP Functions
In addition to the verification of the custom device functions supported by the COTS IP, there is a need
to ensure that the aspects related to the COTS IP and its usage are addressed. This section focuses on
defining a verification strategy to cover those aspects.
The verification performed by the COTS IP provider typically does not follow the ED-80/DO-254
verification process but may provide some credit to be used for the verification strategy. However,
the verification process for COTS IP generally differs from one IP vendor to another, and the level of
assurance varies depending on the IP provider’s development practices.

AMC 20-152A
The verification strategy may combine different means to complement the traditional requirements-
based testing approach.
Based on the applicant’s assessment of the IP provider and the IP data through Objective IP-2, the
applicant is expected to establish a verification strategy. The aim of this verification strategy is to cover
all three of the following aspects:
— The COTS IP: the purpose is to ensure that the COTS IP is verified, addressing the risk identified
from the IP-2 Item 3 objective;
— Its implementation: the purpose is to ensure that the COTS IP still performs its allocated
function, and that no design errors have been introduced by the design steps performed by the
applicant (e.g. synthesis/place and route);
— Its integration within the custom device: the purpose is to ensure that the COTS IP has been
properly connected, configured, and constrained within the custom device.
The strategy may accomplish more than one aspect within a common verification step.
This section identifies a general objective for the verification of COTS IP used in a custom device,
enabling various verification approaches.
Objective IP-4
The applicant should describe in the hardware verification plan, PHAC, or any related planning
document, a verification strategy that should encompass all three of the following aspects:
1. The verification of the COTS IP itself, addressing the risk identified from the IP-2 Item 3 objective;
2. The verification of the COTS IP after the design steps performed by the applicant (e.g.
synthesis/place and route);
3. The verification of the integrated COTS IP functions within the custom device.
Note 1: Reliable and trustworthy test data, test cases or procedures from the COTS IP provider may be
used as part of the verification strategy to satisfy this objective.
Note 2: If the COTS IP implements functions based on an industry standard, proven standardised test
vectors verifying compliance with the standard may be used in the verification strategy of the
COTS IP.
Note 3: The verification strategy covers at a minimum the used functions of the COTS IP and ensures
that the unused functions are correctly disabled or deactivated and do not interfere with the
used functions.
5.11.3.3.3 COTS IP and Planning Aspects
The applicant has to define the activities that are needed for the hardware development assurance
approach related to COTS IP.
Objective IP-5
The applicant should describe in the PHAC, or any related planning document, a hardware
development assurance approach for using the COTS IP that at least includes:
1. identification of the selected COTS IP (version) and its source format(s) associated with the
point(s) in the design flow where the COTS IP is integrated into the custom device;
2. a summary of the COTS IP functions;
3. the development assurance process that the applicant defines to satisfy the objectives of Section
5.11.3;

AMC 20-152A
4. the process related to the design integration and to the usage of the COTS IP in the development
process of the custom device;
5. tool assessment and qualification aspects when the applicant uses a tool to perform design
and/or verification steps for the COTS IP.
5.11.3.4 Requirements for COTS IP Function and Validation
Custom device requirements typically contain requirements that relate to the function supported by
the COTS IP. The granularity of these requirements may be very different depending on the COTS IP
function and the visibility of the functions supported by the IP at the custom device level.
Depending on the extent of requirements-based testing as a part of the chosen verification strategy
of the COTS IP, the level of detail and the granularity of the AEH custom device requirements may
need to be refined to specifically address the COTS IP functions and the implementation of the COTS
IP.
In addition, requirements should be captured to encompass all the necessary design detail used to
connect, configure, and constrain the COTS IP and properly integrate it into the AEH custom device.
Objective IP-6
The requirements related to the allocated COTS IP functions should be captured to an extent
commensurate with the verification strategy.
In addition, derived requirements should be captured to cover the following aspects associated with
the integration of the COTS IP into the custom device design:
1. COTS IP used functions (including parameters, configuration, selectable aspects);
2. Deactivation or disabling of unused functions;
3. Correct control and use of the COTS IP, in accordance with the data from the COTS IP provider.
When the applicant chooses a verification strategy (see Section 5.11.3.3.2) that solely relies on
requirements-based testing, the ‘extent commensurate with the verification strategy’ corresponds to
a complete requirement capture of the COTS IP following ED-80/DO-254.
Regarding the validation aspects, the COTS IP requirements should be validated as a part of the
validation process of the AEH custom device.
5.11.3.5 Verification
The applicant should ensure that the COTS IP is verified as a part of the overall custom device
verification process per ED-80/DO-254 and based on the verification strategy for the COTS IP that has
been described in the PHAC or a related planning document.
For the requirements-based verification part, the applicant should satisfy ED-80/DO-254 Section 6.2
for the verification of the requirements related to the COTS IP (see Section 5.11.3.4 above). This can
be performed as a part of the overall custom device process, therefore there is no separate objective.
5.11.3.6 DO-254 Appendix B considerations
When developing a hardware DAL A or B custom device, ED-80/DO-254 Appendix B is applicable.
Code coverage analysis that is recognised as part of elemental analysis (refer to Section 5.7 of this
document) might not be possible for the COTS IP part of the design. However, ED-80/DO-254 Appendix
B offers other acceptable methods, including safety-specific analysis. The following objective further
clarifies the expectations when using safety-specific analysis.

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Objective IP-7
For COTS IP used in DAL A or DAL B hardware, the applicant should satisfy ED-80/DO-254 Appendix B.
The applicant may choose safety-specific analysis methods to satisfy Appendix B on the COTS IP
function and its integration within the custom device functions. This safety-specific analysis should
identify the safety-sensitive portions of the COTS IP and the potential for design errors in the COTS IP
that could affect the hardware DAL A and DAL B functions in the custom device or system.
For unmitigated aspects of the safety-sensitive portions of the IP, the safety-specific analysis should
determine which additional requirements, design features, and verification activities are required for
the safe operation of the COTS IP in the custom device.
Any additional requirements, design features and/or verification activities that result from the analysis
should be fed back to the appropriate process.
6. USE OF COMMERCIAL OFF-THE-SHELF DEVICES
Applicants are increasingly using COTS electronic devices in aircraft/engines/propellers/ airborne
systems, which may have safety implications for the aircraft, engines/propellers, or systems.
Section 6 addresses the use of COTS devices through objectives that support the demonstration of
compliance with the applicable airworthiness regulations for hardware aspects of airborne systems
and equipment certification when using complex COTS devices. Section 6.2 ‘Applicability to COTS
devices’ enables applicants to identify the COTS devices that are within the scope of Section 6.
Note: The term ‘COTS device’ used in this document applies to a semiconductor product that is fully
encapsulated in a package. This term does not apply to circuit board assemblies (CBAs).
6.1 Background
COTS devices continue to increase in complexity and are highly configurable. COTS devices provide
‘off-the-shelf’ already developed functions, some of which are highly complex. Their development and
production processes undergo a semiconductor industry qualification based on their intended market
(consumer, automotive, telecom, etc.). Their usage by the aerospace industry provides additional
integration and higher performance capabilities than were possible in the past.
The design data for these COTS devices is usually not available to the COTS user. Since these devices
are generally not developed for airborne system purposes, assurance has not been demonstrated that
the rigour of a COTS manufacturer’s development process is commensurate with the aviation safety
risks.
ED-80/DO-254 introduces a basis for the development assurance for the use of COTS devices in Section
11.2 ‘COTS components usage’. This section states that ‘the use of COTS components will be verified
through the overall design process, including the supporting processes’.
Since ED-80/DO-254 was released in the year 2000, the number of functions embedded and integrated
in a single COTS device has significantly increased. Functions which were previously split into various
components, making the interface between those components accessible for verification, are now
embedded within a single chip. While there are clearly some benefits of integrating more functions
within a device, the increased level of integration makes it difficult for the user to verify the different
hardware functions in the device due to lack of access to the interfaces between functions. Since these
devices are more complex and highly configurable than the older separate devices, the risk is greater
that the COTS device will not achieve the intended function in particular use cases over the required
operating conditions.

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Furthermore, some additional assurance is needed because design errors may still be discovered after
the COTS device is released to the market, or when an applicant extends the use of the device beyond
the manufacturer’s specifications.
6.2 Applicability to COTS Devices
Section 6 is applicable to digital, hybrid, and mixed-signal COTS devices that contribute to hardware
DAL A, B or C functions. For COTS devices contributing to hardware DAL C functions, a limited set of
the objectives of this section will apply.
Section 6 is also applicable to FPGA and PLD devices that embed Hard IP (see definition) in their
produced/manufactured silicon, but only for the COTS part of the FPGAs/PLDs.
Section 6.4 only applies to COTS devices that are complex, as determined by the following COTS
complexity assessment.
6.3 COTS Complexity Assessment
In order to define which COTS devices are complex, the following high-level criteria should be used,
considering all functions of the device, including any functions intended to be unused:
A COTS device is complex when the device:
1. has multiple functional elements that can interact with each other; and
2. offers a significant number of functional modes; and
3. offers configurability of the functions, allowing different data/signal flows and different
resource sharing within the device.
Or when the device:
4. contains advanced data processing, advanced switching, or multiple processing elements (e.g.
multicore processors, graphics processing, networking, complex bus switching, interconnect
fabrics with multiple masters, etc.).
For complex COTS devices, it is impractical to completely verify all possible configurations of the
device, and it is difficult to identify all potential failures.
Objective COTS-1
The applicant should assess the complexity of the COTS devices used in the design according to the
high-level criteria of Section 6.3, and document the list of relevant devices (see Note 1), including the
classification rationale, in the PHAC or any related hardware planning document.
Note 1: The applicant is not expected to assess the complete bill of material to satisfy the above
objective, but only those devices that are relevant for the classification, including devices that
are at the boundary between simple and complex. The resulting classification (simple or
complex) for those devices that are at the boundary and those that are definitely complex
should be documented.
Note 2: A classification rationale is required for those devices that are at the boundary (meeting a part
of the high-level criteria) and are classified as simple.
Some examples of classification are provided in the GM Appendix for illustration.
6.4 Development Assurance for Use of Complex COTS
ED-80/DO-254 Section 11.2.1 identifies some electronic component management process (ECMP)
items when using a COTS device. ED-80/DO-254 Section 11.2.2 and Section 6.1 of this document
identify some concerns with using a COTS device. The following objectives acknowledge and

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supplement ED-80/DO-254 Section 11.2 in clarifying how to gain certification credit when using
complex COTS devices.
6.4.1 Electronic Component Management Process (ECMP)
As stated in ED-80/DO-254 Section 11.2, ‘the use of an electronic component management process,
in conjunction with the design process, provides the basis for COTS components usage.’
Objective COTS-2
The applicant should ensure that an electronic component management process (ECMP) exists to
address the selection, qualification, and configuration management of COTS devices. The ECMP should
also address the access to component data such as the user manual, the datasheet, errata, installation
manual, and access to information on changes made by the component manufacturer.
As part of the ECMP, for devices contributing to hardware DAL A or B functions, the process for
selecting a complex COTS device should consider the maturity of the COTS device and, where risks are
identified, they should be appropriately mitigated.
Note: Recognised industry standards describing the principles of electronic component management
may be used to support the development of the ECMP. See Appendix B.
6.4.1.1 Using a Device outside Ranges of Values Specified in its Datasheet
The device reliability is established by the device manufacturer through the device qualification
process (see definition of ‘qualification of a device’ in the glossary). ED-80/DO254 Section 11.2.1 Item
6 mentions that a device is selected based on the technical suitability of the device for the intended
application.
In some cases, the applicant may need to use the device outside the specified operating conditions
guaranteed by the device manufacturer. ED-80/DO-254 Section 11.2.1 Item 4 and Item 6 should be
addressed when the device is used outside its guaranteed specification. The following objective
describes what to achieve when using a device outside the ranges of values specified in its datasheet.
Objective COTS-3
When the complex COTS device is used outside the limits of the device manufacturer’s specification
(such as the recommended operating limits), the applicant should establish the reliability and the
technical suitability of the device in the intended application.
6.4.1.2 Considerations when the COTS Device has Embedded Microcode
COTS devices may need microcode to execute some hardware functions. When those functions are
used by the applicant, there is a risk if the microcode has not been verified by the device manufacturer
during the COTS device qualification, or if the microcode is proposed to be modified by the applicant.
If the microcode is delivered by the device manufacturer, is controlled by the device manufacturer’s
configuration management system, and is qualified together with the device by the device
manufacturer, it is accepted that the microcode is part of the qualified COTS device. If the microcode
is not qualified by the device manufacturer or if it is modified by the applicant, the microcode cannot
be considered to be part of the qualified COTS device.
Objective COTS-4
If the microcode is not qualified by the device manufacturer or if it is modified by the applicant, the
applicant should ensure that a means of compliance for this microcode integrated within the COTS
device is proposed by the appropriate process, and is commensurate with the usage of the COTS device.
Note: The PHAC (or any other related planning document) should document the existence of the
microcode and refer to the process (hardware, software, system) where it is addressed.

AMC 20-152A
6.4.2 COTS Device Malfunctions

Some COTS devices may contain errors that may or may not have been detected by the device
manufacturer.
Objective COTS-5
The applicant should assess the errata of the COTS device that are relevant to the use of the device in
the intended application, and identify and verify the means of mitigation for those errata. If the
mitigation means is not implemented in hardware, the mitigation means should be fed back to and
verified by the appropriate process.
Note: The above objective refers to any mitigation means (such as hardware, software, system, or
other means).
Objective COTS-6
The applicant should identify the failure modes of the used functions of the device and the possible
associated common modes, and feed both of these back to the system safety assessment process.
6.4.3 Usage of COTS Devices
This section focuses on the usage of complex COTS devices, while Section 7 covers the overall circuit
board assembly development process. This Section 6.4.3 refers to the term ’intended function of the
hardware’, which is considered to be defined through the CBA development process.
Complex COTS devices can have multiple functions and many configurations of those functions. The
configuration of a device should be managed in order to provide the ability to consistently apply the
required configuration settings, to replicate the configuration on another item, and to modify the
configuration in a controlled manner, when modification is necessary.
The configuration of the device addresses at least the following topics:
— Used functions (e.g. identification of each function, configuration characteristics, modes of
operation),
— Unused functions and the means (internal/external) used to deactivate them,
— Means to control any inadvertent activation of the unused functions, or inadvertent
deactivation of the used functions,
— Means to manage device resets,
— Power-on configuration,
— Clocking configuration (e.g. identification of the different clock domains), and
— Operating conditions (e.g. clock frequency, power supply level, temperature, etc.).
Objective COTS-7
The applicant should ensure that the usage of the COTS device has been defined and verified according
to the intended function of the hardware. This also includes the hardware–software interface and the
hardware to (other) hardware interface.
When a COTS device is used in a hardware DAL A or B function, the applicant should show that unused
functions of the COTS device do not compromise the integrity and availability of the COTS device’s used
functions.
Note 1: For unused functions of the COTS device, it is recommended that an effective deactivation
means is used and verified, when available.

AMC 20-152A
Note 2: Verification should be performed at an appropriate level (hardware, software, equipment).

ED-80/DO-254 Section 10.3.2.2.4 introduces hardware/software (HW/SW) interface data, which can
be used as a reference to define the software interface data of the COTS device.
Some additional consideration should be given to the critical configuration settings. Those are defined
as the settings that are deemed necessary by the applicant for the proper usage of the hardware,
which, if inadvertently altered, could change the behaviour of the COTS device, causing it to no longer
fulfil the hardware intended function.
Objective COTS-8
If the complex COTS device contributes to DAL A or B functions, the applicant should develop and verify
a means that ensures an appropriate mitigation is specified in the event of any inadvertent alteration
of the ‘critical configuration settings’ of the COTS device.
Note: The mitigation means might be defined at the hardware, software, or system level, or a
combination of these. The mitigation means may also be defined by the safety assessment process.
7 Development Assurance of Circuit Board Assemblies (CBAs)
This section provides guidance for the development assurance of CBAs (a board or a collection of
boards).
7.1 Applicability
Section 7 is applicable to CBAs that contribute to hardware DAL A, B or C functions.
7.2 Development Assurance of Circuit Board Assemblies (CBAs)
While it is already a common practice for applicants to have an internal process to address the
development of CBAs, it is necessary to clarify the expectations for development assurance, including
the flow-down of the equipment/system requirements to the hardware. For consolidation of the
development and/or the use of complex devices, it is essential to ensure consistency in the overall
development assurance approach for the hardware domain. Moreover, definition of the CBA function
is also necessary to enable the allocation of requirements and their flow-down to the complex devices.
Objective CBA-1
The applicant should have a process to address the development of CBAs that contain complex custom
devices or complex COTS devices, in order to ensure that the CBA performs its intended function. The
process should include requirements capture, validation, verification, and configuration management
activities, and ensure an appropriate flow-down of requirements. See Appendix B for additional
information.
Note: The applicant’s process to address the development of the CBA may be defined together with
the equipment process, when relevant.
8 RELATED REGULATORY, ADVISORY AND INDUSTRY MATERIAL
(a) Related EASA Certification Specifications (CSs)
(1) CS-23, Certification Specifications and Acceptable Means of Compliance for Normal,
Utility, Aerobatic, and Commuter Category Aeroplanes
(2) CS-25, Certification Specifications and Acceptable Means of Compliance for Large
Aeroplanes
(3) CS-27, Certification Specifications and Acceptable Means of Compliance for Small
Rotorcraft

AMC 20-152A
Rotorcraft
(5) CS-E, Certification Specifications and Acceptable Means of Compliance for Engines, and
AMC 20-3B, Certification of Engines Equipped with Electronic Engine Control Systems
(6) CS-P, Certification Specifications for Propellers, and AMC 20-1A, Certification of Aircraft
Propulsion Systems Equipped with Electronic Control Systems
(7) CS-ETSO, Certification Specifications for European Technical Standard Orders
(8) CS-APU, Certification Specifications for Auxiliary Power Units; and AMC 20-2B,
Certification of Essential APU Equipped with Electronic Controls
(b) FAA Advisory Circulars (ACs)
(1) AC 20-152, Development Assurance for Airborne Electronic Hardware
(2) AC 00-72, Best Practices for Airborne Electronic Hardware Design Assurance Using
EUROCAE ED-80( ) and RTCA DO-254( )
(3) AC 23.1309-1, System Safety Analysis and Assessment for Part 23 Airplanes
(4) AC 25.1309-1, System Design and Analysis
(5) AC 27-1309, Equipment, Systems, and Installations (included in AC 27-1, Certification of
Normal Category Rotorcraft)
(6) AC 29-1309, Equipment, Systems, and Installations (included in AC 29-2, Certification of
Transport Category Rotorcraft)
(c) Industry Documents
(1) EUROCAE ED-79A, Guidelines for Development of Civil Aircraft and Systems, dated
December 2010
(2) EUROCAE ED-80, Design Assurance Guidance for Airborne Electronic Hardware, dated April 2000
(3) RTCA DO-254, Design Assurance Guidance for Airborne Electronic Hardware, dated 19
April 2000
(4) SAE International Aerospace Recommended Practice (ARP) 4754A, Guidelines for Development
of Civil Aircraft and Systems, dated 21 December 2010
(5) SAE International Aerospace Recommended Practice (ARP) 4761, Guidelines and Methods for
Conducting the Safety Assessment Process on Civil Airborne Systems and Equipment, dated
December 1996
(a) EASA Certification Specifications (CSs) and Acceptable Means of Compliance (AMC) may
be downloaded from the EASA website: www.easa.europa.eu
(b) FAA Advisory Circulars (ACs) may be downloaded from the FAA website: www.faa.gov
(c) EUROCAE documents may be purchased from:
102 rue Etienne Dolet, 92240 Malakoff, France
Telephone: +33 1 40 92 79 30, Fax: +33 1 46 55 62 65
(Email: [email protected], website: www.eurocae.net)

AMC 20-152A
(d) RTCA documents may be purchased from:

RTCA, Inc.
1150 18th Street NW, Suite 910, Washington DC 20036, USA
(Email: [email protected], website: www.rtca.org)
[Amdt 20/19]

AMC 20-158
AMC 20-158
AMC 20-158 Aircraft Electrical and Electronic System High-Intensity

Radiated Fields (HIRF) Protection
1. PURPOSE
a. This Acceptable Means of Compliance (AMC) provides the means and Guidance Material
(GM) related to High-Intensity Radiated Fields (HIRF) protection and the demonstration
of compliance with the Certification Specifications CS 23.1308, CS 25.1317, CS 27.1317,
and CS 29.1317.
b. This AMC is not mandatory and does not constitute a regulation. It describes an
acceptable means, but not the only means, to demonstrate compliance with the
requirements for the protection of the operation of electrical and electronic systems on
an aircraft when the aircraft is exposed to an external HIRF environment. In using the
means described in this AMC, they must be followed in all important respects.
2. SCOPE
This AMC applies to all applicants for a new Type Certificate (TC) or a change to an existing TC
when the certification basis requires the address of the HIRF certification requirements of CS
23.1308, CS 25.1317, CS 27.1317, and CS 29.1317.
3. RELATED MATERIAL
a. European Aviation Safety Agency (EASA) (in this document also referred to as the
‘Agency’)
Certification Specifications:
CS 23.1308, CS 25.1317, CS 27.1317, and CS 29.1317, High-intensity Radiated Fields (HIRF)
protection;
CS 23.1309, CS 25.1309, CS 27.1309, and CS 29.1309, Equipment, systems, and
installations; and
CS 23.1529, CS 25.1529, CS 27.1529, and CS 29.1529, Instructions for Continued
Airworthiness.
Copies of these CSs can be requested from the European Aviation Safety Agency, Postfach
10 12 53, D-50452 Cologne, Germany; Telephone +49 221 8999 000; Fax: +49 221 8999
099; Website: http://easa.europa.eu/official-publication/
b. Title 14 of the Code of Federal Regulations (14 CFR)
Sections:
§§ 23.1308, 25.1317, 27.1317, and 29.1317, High-intensity Radiated Fields (HIRF)
protection;
§§ 23.1309, 25.1309, 27.1309, and 29.1309, Equipment, systems, and installations; and
§§ 23.1529, 25.1529, 27.1529, and 29.1529, Instructions for Continued Airworthiness.
Copies of the above 14 CFR sections can be requested from the Superintendent of
Documents, Government Printing Office, Washington, D.C. 20402-9325, telephone 202-

AMC 20-158
512-1800, fax 202-512-2250. Copies can also be requested from the Government Printing
Office (GPO), electronic CFR Internet website at http://www.gpoaccess.gov/cfr/.
c. FAA Advisory Circulars (ACs)
AC 20-158A, The Certification of Aircraft Electrical and Electronic Systems for Operation
in the High-Intensity Radiated Fields (HIRF) Environment.
AC 23.1309-1E, System Safety Analysis and Assessment for Part 23 Airplanes; and AC
25.1309-1A, SystemDesign and Analysis.
Copies of these ACs can be requested from the U.S. Department of Transportation,
Subsequent Distribution Office, DOT Warehouse M30, Ardmore East Business Center,
3341 Q 75th Avenue, Landover, MD 20785; telephone +1 301 322 5377. These ACs can
also be accessed via the FAA website:
http://www.faa.gov/regulations_policies/advisory_circulars/.
d. European Organization for Civil Aviation Equipment (EUROCAE). Copies of these
documents can be requested from EUROCAE, 102 rue Etienne Dolet, 92240 Malakoff,
France; Telephone: +33 1 40 92 79 30; Fax: +33 1 46 55 62 65; Website:
http://www.eurocae.net.
1. EUROCAE ED-107A, Guide to Certification of Aircraft in a High Intensity Radiated
Field (HIRF) Environment. ED-107A and SAE ARP 5583A, referenced in paragraph
3.f.1. below, are technically equivalent and either document may serve as the
‘User’s Guide’ referred to in this AMC.
2. EUROCAE ED-14G, Environmental Conditions and Test Procedures for Airborne
Equipment. This document is technically equivalent to RTCA/DO-160G. Whenever
there is a reference to RTCA/DO-160G in this AMC, EUROCAE ED-14G may also be
used.
3. EUROCAE ED-79A, Guidelines for Development of Civil Aircraft and Systems. This
document is technically equivalent to ARP 4754A. Whenever there is a reference
to ARP 4754A in this AMC, EUROCAE ED-79A may also be used.
e. Radio Technical Commission for Aeronautics (RTCA).
RTCA/DO-160G, Environmental Conditions and Test Procedures for Airborne Equipment.
This document is technically equivalent to EUROCAE ED-14G.
Copies of this document can be requested from RTCA, Inc., 1828 L Street NW, Suite 805,
Washington, DC 20036; Telephone: +1 202 833 9339; Website: http://www.rtca.org.
f. Society of Automotive Engineers (SAE International). Copies of the below documents
can be requested from SAE World Headquarters, 400 Commonwealth Drive, Warrendale,
Pennsylvania 15096-0001; Telephone: +1 724 776 4970; Website: http://www.sae.org.
1. SAE Aerospace Recommended Practice (ARP) 5583A, Guide to Certification of
Aircraft in a High Intensity Radiated Field (HIRF) Environment. SAE ARP 5583A and
ED-107A, referenced in paragraph 3.d.1. above, are technically equivalent and
either document may serve as the ‘User’s Guide’ referred to in this AMC.
2. SAE ARP 4754A, Guidelines For Development Of Civil Aircraft And Systems,
December 2010.
3. SAE ARP 4761, Guidelines and Methods for Conducting the Safety Assessment
Process on Civil Airborne Systems and Equipment, December 1996.

AMC 20-158
4. BACKGROUND
a. Aircraft protection. Concern for the protection of aircraft electrical and electronic
systems has increased substantially in recent years because of:
1. greater dependence on electrical and electronic systems performing functions
required for continued safe flight and landing of an aircraft;
2. reduced electromagnetic shielding afforded by some composite materials used in
aircraft designs;
3. increased susceptibility of electrical and electronic systems to HIRF because of
increased data bus and processor operating speeds, higher density integrated
circuits and cards, and greater sensitivities of electronic equipment;
4. expanded frequency usage, especially above 1 gigahertz (GHz);
5. increased severity of the HIRF environment because of an increase in the number
and radiated power of Radio Frequency (RF) transmitters; and
6. adverse effects experienced by some aircraft when exposed to HIRF.
b. HIRF environment. The electromagnetic HIRF environment exists because of the
transmission of electromagnetic RF energy from radar, radio, television, and other
ground-based, shipborne, or airborne RF transmitters. The User’s Guide (EUROCAE ED-
107A) provides a detailed description of the derivation of these HIRF environments.
5. DEFINITIONS
Adverse effect: HIRF effect that results in system failure, malfunction, or misleading information
to a degree that is unacceptable for the specific aircraft function or system addressed in the
HIRF regulations. A determination of whether a system or function is adversely affected should
consider the HIRF effect in relation to the overall aircraft and its operation.
Attenuation: Term used to denote a decrease in electromagnetic field strength in transmission
from one point to another. Attenuation may be expressed as a scalar ratio of the input
magnitude to the output magnitude or in decibels (dB).
Bulk Current Injection (BCI): Method of Electromagnetic Interference (EMI) testing that
involves injecting current into wire bundles through a current injection probe.
Continued safe flight and landing: The aircraft can safely abort or continue a take-off, or
continue controlled flight and landing, possibly using emergency procedures. The aircraft must
do this without requiring exceptional pilot skill or strength. Some aircraft damage may occur
because of the failure condition or on landing. For large aeroplanes, the pilot must be able to
land safely at a suitable airport. For CS-23 aeroplanes, it is not necessary to land at an airport.
For rotorcraft, the rotorcraft must continue to cope with adverse operating conditions, and the
pilot must be able to land safely at a suitable site.
Continuous Wave (CW): RF signal consisting of only the fundamental frequency with no
modulation in amplitude, frequency, or phase.
Coupling: Process whereby electromagnetic energy is induced in a system by radiation
produced by a Radio Frequency (RF) source.
Current injection probe: Inductive device designed to inject RF signals directly into wire bundles
when clamped around them.
Direct drive test: Electromagnetic Interference (EMI) test that involves electrically connecting
a signal source directly to the unit being tested.

AMC 20-158
Equipment: Component of an electrical or electronic system with interconnecting electrical

conductors.
Equipment electrical interface: Location on a piece of equipment where an electrical
connection is made to the other equipment in a system of which it is a part. The electrical
interface may consist of individual wires or wire bundles that connect the equipment.
External High-Intensity Radiated Fields (HIRF) environment: Electromagnetic RF fields at the
exterior of an aircraft.
Field strength: Magnitude of the electromagnetic energy propagating in free space expressed
in volts per meter (V/m).
High-Intensity Radiated Fields (HIRF) environment: Electromagnetic environment that exists
from the transmission of high power RF energy into free space.
HIRF vulnerability: Susceptibility characteristics of a system that cause it to suffer adverse
effects when performing its intended function as a result of having been subjected to an HIRF
environment.
Immunity: Capacity of a system or piece of equipment to continue to perform its intended
function, in an acceptable manner, in the presence of RF fields.
Interface circuit: Electrical or electronic device connecting the electrical inputs and outputs of
equipment to other equipment or devices in an aircraft.
Internal HIRF environment: The RF environment inside an airframe, equipment enclosure, or
cavity. The internal RF environment is described in terms of the internal RF field strength or wire
bundle current.
Margin: Difference between equipment susceptibility or qualification levels and the aircraft
internal HIRF environment. Margin requirements may be specified to account for uncertainties
in design, analysis, or test.
Modulation: Process whereby certain characteristics of a wave, often called the carrier wave,
are varied in accordance with an applied function.
Radio Frequency (RF): Frequency useful for radio transmission. The present practical limits of
RF transmissions are approximately 10 kilohertz (kHz) to 100 gigahertz (GHz). Within this
frequency range, electromagnetic energy may be detected and amplified as an electric current
at the wave frequency.
Reflection plane: Conducting plate that reflects RF signals.
Similarity: Process of using existing HIRF compliance documentation and data from a system or
aircraft to demonstrate HIRF compliance for a nearly identical system or aircraft of equivalent
design, construction, and installation.
Susceptibility: Property of a piece of equipment that describes its inability to function
acceptably when subjected to unwanted electromagnetic energy.
Susceptibility level: Level where the effects of interference from electromagnetic energy
become apparent.
System: Piece of equipment connected via electrical conductors to another piece of equipment,
both of which are required to make a system function. A system may contain pieces of
equipment, components, parts, and wire bundles.

AMC 20-158
Transfer function: Ratio of the electrical output of a system to the electrical input of a system,
expressed in the frequency domain. For HIRF, a typical transfer function is the ratio of the
current on a wire bundle to the external HIRF field strength, as a function of frequency.
Upset: Impairment of system operation, either permanent or momentary. For example, a
change of digital or analogue state that may or may not require a manual reset.
User’s Guide: Refers to SAE document ARP 5583A or EUROCAE document ED-107A.
6. APPROACHES TO COMPLIANCE
a. General. The following activities should be elements of a proper HIRF certification
programme. The iterative application of these activities is left to the applicant. Adherence
to the sequence shown is not necessary. The applicant should:
1. identify the systems to be assessed;
2. establish the applicable aircraft external HIRF environment;
3. establish the test environment for installed systems;
4. apply the appropriate method of HIRF compliance verification; and
5. verify HIRF protection effectiveness.
b. Identify the systems to be assessed
1. General. The aircraft systems that require HIRF assessment must be identified. The
process used for identifying these systems should be similar to the process for
demonstrating compliance with CS 23.1309, CS 25.1309, CS 27.1309, and CS
29.1309, as applicable. These sections address any system failure that may cause
or contribute to an effect on the safety of flight of an aircraft. The effects of an
encounter with HIRF, therefore, should be assessed in a manner that allows for the
determination of the degree to which the aircraft and its systems’ safety may be
influenced. The operation of the aircraft systems should be assessed separately
and in combination with, or in relation to, other systems. This assessment should
cover:
a. all normal aircraft operating modes, phases of flight, and operating
conditions;
b. all failure conditions and their subsequent effect on aircraft operations and
the flight crew; and
c. any corrective actions required.
2. Safety assessment. A safety assessment related to HIRF must be performed to
establish and classify the equipment or system failure condition. Table 1 provides
the corresponding failure condition classification and system HIRF certification
level for the appropriate HIRF regulations. The failure condition classifications and
terms used in this AMC are similar to those used in AC 23.1309-1E and AMC
25.1309, as applicable. Only those systems identified as performing or contributing
to functions the failure of which would result in Catastrophic, Hazardous, or Major
failure conditions are subject to HIRF regulations. Based on the failure condition
classification established by the safety assessment, the systems should be assigned
appropriate HIRF certification levels, as shown in Table 1. The safety assessment
should consider the common cause effects of HIRF, particularly for highly
integrated systems and systems with redundant elements. Further guidance on

AMC 20-158
performing the safety assessment can be found in AC 23.1309-1E, AMC 25.1309,

ED-79A, and SAE ARP 4761.
Table 1 — HIRF failure conditions and system HIRF certification levels
HIRF REQUIREMENTS EXCERPTS FROM CS 23.1308, SYSTEM HIRF

FAILURE CONDITION
CS 25.1317, CS 27.1317, AND CS 29.1317 CERTIFICATION LEVEL
Each electrical and electronic system that performs a Catastrophic A
function whose failure would prevent the continued safe
flight and landing of the aircraft.
Each electrical and electronic system that performs a Hazardous B
function whose failure would significantly reduce the
capability of the aircraft or the ability of the flight crew to
respond to an adverse operating condition.
Each electrical and electronic system that performs a Major C
function whose failure would reduce the capability of the
aircraft or the ability of the flight crew to respond to an
adverse operating condition.
3. Failure conditions. A safety assessment should consider all potential adverse effects due to
system failures, malfunctions, or misleading information. The safety assessment may show that some
systems have different failure conditions in different phases of flight; therefore, different HIRF
requirements may have to be applied to the system for different phases of flight. For example, an
automatic flight control system may have a Catastrophic failure condition for autoland, while
automatic flight control system operations in cruise may have a Hazardous failure condition.
c. Establish the applicable aircraft external HIRF environment. The external HIRF environments
I, II and III, as published in CS 23.1308, CS 25.1317, CS 27.1317, and CS 29.1317, are shown in Tables 2, 3 and
4 respectively. The field strength values for the HIRF environments and test levels are expressed in root mean
square (rms) units measured during the peak of the modulation cycle, which is how many laboratory
instruments indicate amplitude.
Table 2 — HIRF environment I
FREQUENCY FIELD STRENGTH (V/m)

PEAK AVERAGE
10 kHz – 2 MHz 50 50
2 MHz – 30 MHz 100 100
30 MHz – 100 MHz 50 50
100 MHz – 400 MHz 100 100
400 MHz – 700 MHz 700 50
700 MHz – 1 GHz 700 100
1 GHz – 2 GHz 2 000 200
2 GHz – 6 GHz 3 000 200
6 GHz – 8 GHz 1 000 200
8 GHz – 12 GHz 3 000 300
12 GHz – 18 GHz 2 000 200
18 GHz – 40 GHz 600 200
In this table, the higher field strength applies to the frequency band edges.

AMC 20-158
Table 3 — HIRF environment II

PEAK AVERAGE
10 kHz – 500 kHz 20 20
500 kHz – 2 MHz 30 30
2 MHz – 30 MHz 100 100
30 MHz – 100 MHz 10 10
100 MHz – 200 MHz 30 10
200 MHz – 400 MHz 10 10
400 MHz – 1 GHz 700 40
1 GHz – 2 GHz 1 300 160
2 GHz – 4 GHz 3 000 120
4 GHz – 6 GHz 3 000 160
6 GHz – 8 GHz 400 170
8 GHz – 12 GHz 1 230 230
12 GHz – 18 GHz 730 190
18 GHz – 40 GHz 600 150
Table 4 — HIRF environment III

PEAK AVERAGE
10 kHz – 100Hz 150 150
100 kHz – 400 MHz 200 200
400 MHz – 700 MHz 730 200
700 MHz – 1 GHz 1 400 240
1 GHz – 2 GHz 5 000 250
2 GHz – 4 GHz 6 000 490
4 GHz – 6 GHz 7 200 400
6 GHz – 8 GHz 1 100 170
8 GHz – 12 GHz 5 000 330
12 GHz – 18 GHz 2 000 330
18 GHz – 40 GHz 1 000 420
d. Establish the test environment for installed systems

1. General. The external HIRF environment will penetrate the aircraft and establish
an internal RF environment to which installed electrical and electronic systems will
be exposed. The resultant internal RF environment is caused by a combination of
factors, such as: aircraft seams and apertures, re-radiation from the internal
aircraft structure and wiring, and characteristic aircraft electrical resonance.
2. Level A systems. The resulting internal HIRF environments for Level A systems are
determined by aircraft attenuation to the external HIRF environments I, II, or III, as
defined in CS-23 Appendix K, CS-25 Appendix R, CS-27 Appendix D, and CS-29
Appendix E, as applicable. The attenuation is aircraft and zone specific and should

AMC 20-158
be established by aircraft test, analysis, or similarity. The steps for demonstrating

Level A HIRF compliance are presented in Chapter 9 of this AMC.
3. Level B systems. The internal RF environments for Level B systems are defined in
CS-23 Appendix K, CS-25 Appendix R, CS-27 Appendix D, and CS-29 Appendix E, as
applicable, as equipment HIRF test levels 1 or 2. The steps for demonstrating Level
B HIRF compliance are presented in Chapter 10 of this AMC.
4. Level C systems. The internal RF environments for Level C systems are defined in
CS-23 Appendix K, CS-25 Appendix R, CS-27 Appendix D, and CS-29 Appendix E, as
equipment HIRF test level 3. The steps for demonstrating Level C HIRF compliance
are also presented in Chapter 10 of this AMC.
e. Apply the appropriate method of HIRF compliance verification
1. General. Table 5 summarises the relationship between the aircraft performance
requirements in the HIRF regulations (sections (a), (b) and (c)), and the HIRF
environments and test levels.
2. Pass/fail criteria. Establish specific HIRF compliance pass/fail criteria for each
system as it relates to the applicable HIRF regulation performance criteria. These
pass/fail criteria should be presented to the Agency for approval. The means for
monitoring system performance relative to these criteria also should be
established by the applicant and approved by the Agency. All effects that define
the pass/fail criteria should be the result of identifiable and traceable analysis that
includes both the separate and interdependent operational characteristics of the
systems. The analysis should evaluate the failures, either singularly or in
combination, which could adversely affect system performance. This should
include failures that could negate any system redundancy, or failures that could
influence more than one system performing the same function.
Table 5 — Summary of HIRF certification requirements
HIRF FAILURE CONDITION PERFORMANCE ITEM THE HIRF ENVIRONMENT

FROM CS 23.1308, CS 25.1317, CRITERIA ENVIRONMENT OR OR TEST LEVEL
CS 27.1317, AND CS 29.1317 TEST LEVEL APPLIES TO
Each electrical and electronic …each function is not …the aircraft… …is exposed to HIRF
system that performs a adversely affected during environment I.
function whose failure would and after the time…
prevent the continued safe
flight and landing of the
aircraft must be designed and
installed so that…
…each electrical and …the aircraft… …is exposed to HIRF
electronic system environment I.
automatically recovers
normal operation of that
function, in a timely
manner after…
…each electrical and …the aircraft… …is exposed to HIRF
electronic system is not environment II.
adversely affected during
and after…

AMC 20-158
…each function required …the rotorcraft… …is exposed to HIRF

during operation under environment III
visual flight rules is not (Parts 27 and 29
adversely affected during only).
and after…
Each electrical and electronic …the system is not …the equipment …is exposed to
system that performs a adversely affected providing these equipment HIRF test
function whose failure would when… functions… level 1 or 2.
significantly reduce the
capability of the aircraft or the
ability of the flight crew to
respond to an adverse
operating condition must be
designed and installed so
that…
Each electrical and electronic …the system is not …the equipment …is exposed to
system that performs such a adversely affected providing these equipment HIRF test
function whose failure would when… functions… level 3.
reduce the capability of the
aircraft or the ability of the
flight crew to respond to an
adverse operating condition
must be designed and installed
so that…
f. Verify the HIRF protection effectiveness. It should be demonstrate that the RF current on
system and equipment wire bundles and the RF fields on the system, created by the HIRF
environment, are lower than the equipment or system HIRF qualification test levels.
7. MARGINS
A margin is normally not necessary for HIRF compliance based on tests on the specific aircraft
model and system undergoing certification. However, when determining compliance based on
analysis or similarity, a margin may be required depending on the validation of the analysis or
similarity process. Where data have limited substantiation, a margin may be required
depending on the available justifications. The justification for a selected margin should be part
of the HIRF compliance plan set out in Chapter 8 below.
8. HIRF COMPLIANCE
a. HIRF compliance plan. An overall HIRF compliance plan should be established to clearly
identify and define HIRF certification requirements, HIRF protection development, and
the design, test, and analysis activities intended to be part of the compliance effort. This
plan should provide definitions of the aircraft systems, installations, and protective
features against which HIRF compliance will be assessed. The HIRF compliance plan
should be discussed with, and submitted to, the Agency for approval before being
implemented. If the aircraft, system, or installation design changes after the Agency’s
approval, a revised HIRF compliance plan should be submitted to the Agency for approval.
The HIRF compliance plan should include the following:
1. a HIRF compliance plan summary;
2. identification of the aircraft systems, with classification based on the safety
assessment as it relates to HIRF (see paragraph 6.b.2);
3. the HIRF environment for the aircraft and installed systems; and

AMC 20-158
4. the verification methods, such as test, analysis, or similarity.

b. HIRF verification test, analysis, or similarity plan. Specific HIRF test, analysis, or similarity
plans should be prepared to describe specific verification activities. One or more
verification plans may be necessary. For example, there may be several systems or
equipment laboratory test plans, an aircraft test plan, or a similarity plan for selected
systems on an aircraft.
1. Test plan
a. A HIRF verification test plan should include the equipment, system, and
aircraft test objectives for the acquisition of data to support HIRF
compliance. The plan should provide an overview of the factors being
addressed for each system test requirement. The test plan should include:
1. the purpose of the test;
2. a description of the aircraft and/or system being tested;
3. system configuration drawings;
4. the proposed test set-up and methods;
5. intended test levels, modulations, and frequency bands;
6. pass/fail criteria; and
7. the test schedule and test location.
b. The test plan should cover Level A, B, and C systems and equipment, as
appropriate. Level A systems may require both integrated systems
laboratory tests and aircraft tests. Level B and Level C systems and
equipment require only equipment laboratory testing.
c. The test plan should describe the appropriate aspects of the systems to be
tested and their installation. Additionally, the test plan should reflect the
results of any analysis performed in the overall process of the HIRF
compliance evaluation.
2. Analysis plan. A HIRF compliance analysis plan should include the objectives, both
at the system and equipment level, for generating data to support HIRF compliance
verification. Comprehensive modelling and analysis for RF field coupling to aircraft
systems and structures is an emerging technology; therefore, the analysis plan
should be coordinated with the Agency to determine an acceptable scope for the
analysis. The analysis plan should include:
a. the purpose and scope of the analysis;
b. a description of the aircraft and/or system addressed by the analysis;
c. system configuration descriptions;
d. proposed analysis methods;
e. the approach for validating the analysis results; and
f. pass/fail criteria, including margins to account for analysis uncertainty.
3. Similarity plan. A similarity plan should describe the approach taken in using
certification data from previously certified systems, equipment, and aircraft. The
similarity plan should include:

AMC 20-158
a. the purpose and scope of the similarity assessment;

b. specific systems addressed by the similarity assessment;
c. data that will be used from the previously certified systems, equipment, and
aircraft; and
d. any significant differences between the aircraft and system installation
proposed for certification and the aircraft and system installation from
which the data will be used. Include appropriate margins to account for
similarity uncertainty.
c. Compliance reports. One or more compliance reports may be necessary to document the
results of test, analysis, or similarity assessments. For new or significantly modified
aircraft, HIRF compliance reports may include many system and equipment test reports,
aircraft test reports, and HIRF analysis reports. For these types of HIRF certification
programmes, a compliance summary report may be useful to summarise the results of
tests and analyses. For HIRF certification programmes on relatively simple systems, a
single compliance report may be adequate.
1. Test reports. Comprehensive test reports should be produced at the conclusion of
HIRF compliance testing. The test reports should include descriptions of the salient
aspects of equipment or system performance during the test, details of any area
of non-compliance with HIRF requirements, actions taken to correct the non-
compliance, and any similarity declarations. Supporting rationale for any
deviations from system performance observed during testing should also be
provided.
2. Analysis reports. Analysis reports should describe the details of the analytical
model, the methods used to perform the analysis, and the results of the analysis.
The reports should identify any modelling uncertainty and justify the margins
established in the analysis plan.
3. Similarity reports. Similarity reports should document the significant aircraft,
system, equipment, and installation features common between the aircraft or
system that is the subject of the similarity analysis and the aircraft or system that
previously was certified for HIRF. Identify all significant differences encountered,
along with the assessment of the impact of these differences on HIRF compliance.
These reports should also justify the margins established in the similarity plan.
d. Methods of compliance verification
1. Various methods are available to aid in demonstrating HIRF compliance. Methods
acceptable to the Agency are described in Chapters 9 and 10. Figures 1 and 2 below
outline the steps to demonstrate HIRF compliance for systems requiring Level A
HIRF certification. Figure 3 below outlines the steps to demonstrate HIRF
compliance for systems requiring Level B or C HIRF certification. The steps in these
figures are not necessarily accomplished sequentially. Wherever a decision point
is indicated on these figures, the applicant should complete the steps in that path
as described in Chapters 9 and 10.
2. Other HIRF compliance techniques may be used to demonstrate system
performance in the HIRF environment; however, those techniques should be
approved by the Agency before using them.

AMC 20-158
Figure 1 — Routes to HIRF compliance — Level A systems
(n) = Step number as described in Chapter 9 of this AMC.

AMC 20-158
Figure 2 — Aircraft low-level coupling tests — Level A systems

AMC 20-158
Figure 3 — Routes to HIRF compliance — Level B and C systems
9. STEPS TO DEMONSTRATE LEVEL A SYSTEM HIRF COMPLIANCE

a. Step 1 — System safety assessment. The applicant should determine the system failure
condition classification for the systems being certified on their aircraft, using a system
safety assessment as discussed in paragraph 6.b.2. For systems classified with
Catastrophic failure conditions (Level A systems), the applicant should follow compliance
steps 2 through 15 listed below, as appropriate. These compliance steps are also depicted
in Figures 1 and 2 of this AMC, and are not necessarily accomplished sequentially. For
systems classified with Hazardous or Major failure conditions (Level B and C systems), the
compliance steps outlined in Chapter 10 should be followed.

AMC 20-158
b. Step 2 — Define aircraft and system HIRF protection. The applicant should define the
HIRF protection features that will be incorporated into the aircraft and system designs,
based on the HIRF environments that are applicable to their aircraft and its Level A
systems. Equipment, system, and aircraft HIRF protection design may occur before
aircraft-level tests are performed, and before the actual internal HIRF environment is
determined. Therefore, the equipment, system and aircraft HIRF protection design
should be based on an estimate of the expected internal HIRF environment. All aircraft
configurations that may affect HIRF protection, such as opened landing gear doors,
should be considered as part of the aircraft assessment (see Step 7).
c. Step 3 — System assessment decision. The applicant should determine whether to
perform integrated system HIRF tests on the Level A system, or whether to base the
system verification on previous integrated system HIRF tests performed on a similar
system. Aircraft and system tests and assessments need not be performed for the HIRF
environments above 18 GHz if data and design analysis show that the integrated system
tests results (see Step 5) satisfy the pass criteria from 12 GHz to 18 GHz, and that the
systems have no circuits that operate in the 18 GHz to 40 GHz frequency range.
d. Step 4 — Equipment test
1. Radiated and conducted RF susceptibility laboratory tests of ED-14G, Section 20,
may be used to build confidence in the equipment's HIRF immunity before
conducting integrated system laboratory tests in Step 5. The equipment should be
tested in accordance with the test levels (wire bundle currents and RF field
strengths) of ED-14G, Section 20, or to a level estimated for the aircraft and
equipment installation using the applicable external HIRF environment.
2. Equipment HIRF tests may be used to augment the integrated system HIRF tests
where appropriate. For equipment, whose HIRF immunity is evaluated as part of
the integrated system-level HIRF tests discussed in Step 5, the individual
equipment’s HIRF testing described in this step may be considered optional.
e. Step 5 — Integrated system test
1. Radiated and conducted RF susceptibility laboratory tests on an integrated system
should be performed for Level A systems. The HIRF field strengths and wire bundle
currents selected for this test should be based on the attenuated external HIRF
environment determined in the aircraft assessment (see Steps 10, 11, or 12). In
many cases, the integrated system test is performed before the aircraft assessment
is complete. In these cases, the integrated system test field strengths and currents
should be selected based on the expected aircraft attenuation or transfer function.
2. The installation details for the laboratory integrated system tests should be similar
to the installation in the aircraft. For example, the bonding and grounding of the
system, wire size, routing, arrangement (whether parallel or twisted wires),
connector types, wire shields, and shield terminations, and the relative position of
the elements to each other and the ground plane in the laboratory should match
closely the system installation on the aircraft to be certificated. For this reason, the
laboratory integrated system rig should have an EASA conformity inspection prior
to conducting any EASA certification credit testing.
3. The integrated system should be tested with the system operating, and should
include connected displays, sensors, actuators, and other equipment. To ensure
that the integrated system is tested when operating at its maximum sensitivity, the
system should be placed in various operating modes. If the connected equipment

AMC 20-158
is not related to the functions with Catastrophic failures, these items may be
simulated by test sets, if the test sets accurately represent the terminating circuit
impedance of the sensor. However, the connected equipment should meet the
appropriate HIRF requirements required for their failure condition classification.
4. The test levels should be selected based on the expected aircraft internal HIRF
environment determined through aircraft tests (see Step 10), generic transfer
functions and attenuation (see Step 11), or aircraft similarity assessment (see Step
12), using the applicable external HIRF environment. Integrated system test
procedures are described in detail in the User’s Guide (SAE ARP 5583A/EUROCAE
ED-107A).
5. Wire bundle current injection should be used for frequencies from 10 kHz to
400 MHz. RF currents are injected into the integrated system wiring via a current
transformer. Each wire bundle in the system should be injected and the induced
wire bundle current measured. If a system wire bundle branches, then each wire
bundle branch also should be tested. Simultaneous multi-bundle current injection
may be necessary on systems where there are redundant or multi-channel
architectures.
6. High-level radiated susceptibility tests should be used at frequencies greater than
100 MHz. The radiating antenna should be far enough away to ensure the total
volume of the equipment and at least half a wavelength of the wiring is
simultaneously and uniformly illuminated during the test.
7. Define the appropriate pass/fail criteria for the system, based on the system safety
assessment and the appropriate HIRF regulation. Any system susceptibility,
including system malfunctions, upset, or damage should be recorded and
evaluated based on these previously defined pass/fail criteria.
8. Using only the modulation to which the system under evaluation is most sensitive
may minimise the test time. The User’s Guide provides guidance on modulation
selection and suggested default modulations and dwell times.
9. The equipment tests in Step 4, using the techniques in ED-14G, Section 20,
normally are not sufficient to demonstrate HIRF compliance for Step 5. However,
for simple systems, these standard ED-14G, Section 20, tests may be sufficient if
paragraphs 9.e.2. and 3. of this step are met.
f. Step 6 — System similarity assessment
1. The integrated system HIRF tests performed for a system previously certified on
one aircraft model may be used to demonstrate system verification for a similar
system. Each system considered under the similarity approach needs to be
assessed independently even if it may use equipment and installation techniques
that have been the subject of a previous certification.
2. The system used as the basis for similarity must have been certified previously for
HIRF compliance on another aircraft model, and must have successfully completed
integrated system HIRF tests. Similarity assessment requires comparison of both
equipment and installation differences that could adversely affect HIRF immunity.
The assessment should consider the differences between the previously HIRF
certified system and the equipment circuit interfaces, wiring, grounding, bonding,
connectors, and wire-shielding practices of the equipment that comprises the new
system.

AMC 20-158
3. If the assessment finds only minimal differences between the previously certified
system and the new system to be certified, similarity may be used as the basis for
system-level verification without the need for additional integrated system tests,
providing there are no unresolved in-service HIRF problems related to the
previously certified system. If there is uncertainty about the effects of the
differences, additional tests and analyses should be conducted as necessary and
appropriate to resolve the uncertainty. The amount of additional testing should be
commensurate with the degree of difference identified between the new system
and the system previously certified. If significant differences are found, similarity
should not be used as the basis for system-level verification.
g. Step 7 — Aircraft assessment decision
1. Level A systems require an aircraft assessment. The aircraft assessment should
determine the actual internal HIRF environment where the Level A systems are
installed in the aircraft. The applicant should choose whether to use aircraft tests,
previous coupling/attenuation data from similar aircraft types (similarity), or, for
Level A display systems only, the generic transfer functions and attenuation in
Appendix 1 to this AMC. Alternately, the aircraft assessment may be a test that
exposes the entire aircraft with operating Level A systems to external HIRF
environments I, II, or III (Tables 2, 3, and 4 respectively), as appropriate, to
demonstrate acceptable Level A system performance.
2. Integrated display systems include the display equipment, control panels, and the
sensors that provide information to the displays. In some systems, the sensors also
provide information to Level A systems that are not displays. If the sensors also
provide information to Level A flight controls, the applicant must use actual
transfer functions and attenuation when demonstrating compliance for these
sensors and the flight controls.
3. Other methods for aircraft HIRF assessment, such as analysis, may be acceptable.
However, comprehensive modelling and analysis for RF field coupling to the
aircraft structure is an emerging technology. Therefore, analysis alone is currently
not adequate to demonstrate HIRF compliance for Level A systems and should be
augmented by testing.
4. If analysis is used to determine aircraft attenuation and transfer function
characteristics, test data should be provided to support this analysis. Any analysis
results should take into account the quality and accuracy of the analysis. Significant
testing, including aircraft level testing, may be required to support the analysis.
5. Aircraft and system tests and assessments need not be performed for the HIRF
environments above 18 GHz if data and design analysis show that the integrated
system tests results (see Step 5) satisfy the pass criteria from 12 GHz to 18 GHz,
and the systems have no circuits that operate in the 18 GHz to 40 GHz frequency
range.
h. Step 8 — Aircraft test decision
1. Various aircraft test procedures are available and accepted for collecting data for
aircraft HIRF verification. The two main approaches to aircraft testing are the
aircraft high-level test (see Step 9) and the aircraft low-level coupling test (see Step
10). The aircraft high-level field-illumination test involves radiating the aircraft at
test levels equal to the applicable external HIRF environment in the HIRF
regulations. Aircraft low-level coupling tests involve measuring the airframe

AMC 20-158
attenuation and transfer functions, so that the internal HIRF electric fields and
currents can be compared to the integrated system test levels.
2. Some test procedures may be more appropriate than others because of the size of the
aircraft and the practicality of illuminating the entire aircraft with the appropriate
external HIRF environment. The aircraft low-level coupling tests (see Step 10) may
be more suitable for testing large aircraft than the high-level field-illumination test
in Step 9, which requires illumination of the entire aircraft with the external HIRF
environment.
i. Step 9 — Aircraft high-level tests
1. The aircraft high-level field-illumination test requires generating RF fields external
to an aircraft at a level equal to the applicable external HIRF environment.
2. At frequencies below 400 MHz, the distance between the aircraft and the
transmitting antenna should be sufficient to ensure the aircraft is illuminated
uniformly by the external HIRF environment. The transmitting antenna should be
placed in at least four positions around the aircraft, typically illuminating the nose,
tail, and each wingtip. The aircraft should be illuminated by the antenna at each
position while sweeping the frequency range. Separate frequency sweeps should
be performed with the transmitting antenna oriented for horizontal and vertical
polarisation. The RF field should be calibrated by measuring the RF field strength
in the centre of the test volume before the aircraft is placed there.
3. At frequencies above 400 MHz, the RF illumination should be localised to the
system under test, provided all parts of the system and at least one wavelength of
any associated wiring (or the total length if less than one wavelength) are
illuminated uniformly by the RF field. Reflection planes may be needed to
illuminate relevant apertures on the bottom and top of the aircraft.
4. To ensure that the systems are tested when operating at their maximum
sensitivity, Level A systems should be fully operational and the aircraft should be
placed in various simulated operating modes.
5. The test time can be minimised by using only the modulation to which the system
under evaluation is most sensitive. In this case, the rationale used to select the
most sensitive modulation should be documented in the HIRF test plan as
discussed in paragraph 8.b.1. The User’s Guide provides guidance on modulation
selection and suggested default modulations and dwell times.
6. As an alternative to testing at frequencies below the first airframe resonant
frequency, it is possible to inject high-level currents directly into the airframe using
aircraft high-level direct-drive test methods. Aircraft skin current analysis should
be performed as described in the User’s Guide, or low-level swept-current
measurements should be made to determine the skin current distribution that will
exist for different RF field polarisations and aircraft illumination angles so that
these can be simulated accurately during this test. Aircraft high-level direct-drive
testing, although applicable only from 10 kHz to the first airframe resonant
frequency, is advantageous because it is possible to test all systems
simultaneously.

AMC 20-158
j. Step 10 — Aircraft low-level coupling tests

1. General
a. The aircraft low-level coupling tests include three different tests that cover
the frequency range of 10 kHz to 18 GHz (see Figure 2). Detailed descriptions
are available in the User’s Guide. Other techniques may be valid, but must
be discussed with and approved by the Agency before being used.
b. The low-level direct-drive test (see Step 10b, Figure 2) and the low-level
swept-current test (see Step 10c) are used for frequencies at or below
400 MHz. The low-level swept-field test (see Step 10d) is used for
frequencies at and above 100 MHz. There is an overlap of test frequencies
from 100 MHz to 400 MHz in the low-level swept-current test and the low-
level swept-field test. The division at 400 MHz is not absolute but rather
depends on when HIRF penetration of the equipment case becomes a
significant factor.
2. Steps 10a and 10b — Aircraft skin current analysis and low-level direct-drive test.
Low-level direct-drive tests in conjunction with skin current analysis should be used
to determine the transfer function between the skin current and individual
equipment wire bundle currents. The low-level direct-drive test is typically used for
frequencies from 10 kHz to the first airframe resonant frequency. For the low-level
direct-drive test to be applied successfully, a three-dimensional model of the
aircraft should be derived using aircraft skin current analysis. The three-
dimensional model can then be used to derive the aircraft's skin current pattern
for the applicable external HIRF environment. Guidance on skin current analysis is
in the User’s Guide. If the relationship between the external HIRF environment and
the skin current is known for all illumination angles and polarisation, either
because of aircraft skin current analysis or the use of the low-level swept-current
test, the skin current can be set up by direct injection into the airframe. The
resultant currents on the system wire bundles are measured with a current probe
and normalised to 1 V/m electric field strength so that they can be scaled to the
appropriate external HIRF environment. This test method has improved sensitivity
over the low-level swept-current test and may be necessary for small aircraft or
aircraft with high levels of airframe shielding.
3. Step 10c — Low-level swept-current test
a. The low-level swept-current test involves illuminating the aircraft with a low-
level external HIRF field to measure the transfer function between the
external field and the aircraft and equipment wire bundle currents. This test
is typically used in the frequency range of 500 kHz to 400 MHz. The transfer
function is resonant in nature and is dependent on both the aircraft
structure and the system installation. Because the transfer function relates
wire bundle currents to the external field, the induced bulk current injection
test levels can be related to an external HIRF environment.
b. The transmitting antenna should be placed in at least four positions around
the aircraft, typically the nose, tail, and each wingtip, with sufficient distance
between the aircraft and the transmitting antenna to ensure the aircraft is
illuminated uniformly. The aircraft should be illuminated by the antenna at
each position while sweeping the frequencies in the range of 500 kHz to 400
MHz. Separate frequency sweeps should be performed with the transmitting

AMC 20-158
antenna oriented for horizontal and vertical polarisation. The currents

induced on the aircraft wire bundles should be measured.
c. The ratio between the induced wire bundle current and the illuminating
antenna field strength should be calculated and normalised to a ratio of 1
V/m. This provides the transfer function in terms of induced current per unit
external field strength. Then the current induced by the applicable external
HIRF environment can be calculated by multiplying the transfer function by
the external HIRF field strength. The calculated HIRF currents for all
transmitting antenna positions for each aircraft wire bundle being assessed
should be overlaid to produce worst-case induced current for each wire
bundle. These worst-case induced currents can be compared with the
current used during the integrated system test in Step 5.
4. Step 10d — Low-level swept-field test. Low-level swept-field testing is
typically used from 100 MHz to 18 GHz. The test procedures for the low-level
swept-field test are similar to those used for the low-level swept-current
test; however, in the low-level swept-field test, the internal RF fields in the
vicinity of the equipment are measured instead of the wire bundle currents.
Various techniques can be used to ensure the maximum internal field in the
vicinity of the equipment is measured. Depending on the size of the aircraft
and the size of the aircraft cabin, flight deck, and equipment bays, multipoint
measurement or mode stirring can be used to maximise the internal field in
the vicinity of the equipment. See the User’s Guide for detailed low-level
swept-field test procedures.
k. Step 11 — Generic transfer functions and attenuation — Level A display systems only
1. Level A displays involve functions for which system information is displayed directly
to the pilot. For Level A display systems, the aircraft attenuation data may be
determined using generic attenuation and transfer function data. This approach
should not be used for other Level A systems, such as control systems, because
failures and malfunctions of those systems can more directly and abruptly
contribute to a Catastrophic failure event than do display system failures and
malfunctions; therefore, other Level A systems should have a more rigorous
method of HIRF compliance verification.
2. The integrated system test levels specified in Step 5 may be derived from the
generic transfer functions and attenuation for different types of aircraft.
Acceptable transfer functions for calculating the test levels are given in Appendix 1
to this AMC. Appendix 1 to this AMC also contains guidelines for selecting the
proper generic attenuation. The generic transfer functions show the envelope of
the currents that might be expected to be induced in the types of aircraft in an
external HIRF environment of 1 V/m. The current levels should be multiplied
linearly by HIRF environment I, II, or III, as appropriate, to determine the integrated
system test levels.
3. The internal HIRF electric field levels are the external HIRF environment divided by
the appropriate attenuation, in linear units. For example, 20 dB or a 10:1
attenuation means the test level is the applicable external HIRF environment
electric field strength reduced by a factor of 10.
4. The internal HIRF environments for Level A display systems can also be measured
using on-aircraft low-level coupling measurements of the actual system installation

AMC 20-158
(see Step 10). This procedure should provide more accurate information to the
user, and the test levels may be lower than the generic transfer functions or
attenuation, which are worst-case estimates.
l. Step 12 — Aircraft similarity assessment
1. The aircraft attenuation and transfer functions tests performed for a previously
certified aircraft may be used to support aircraft-level verification for a similar
aircraft model. The aircraft used as the basis for similarity must have been
previously certified for HIRF compliance, using HIRF attenuation and transfer
functions determined by tests on that aircraft.
2. The similarity assessment for the new aircraft should consider the aircraft
differences that could impact the internal HIRF environment affecting the Level A
systems and associated wiring. The comparison should consider equipment and
wiring locations, airframe materials and construction, and apertures that could
affect attenuation for the external HIRF environment.
aircraft and the new aircraft to be certified, similarity may be used to determine
aircraft attenuation and transfer functions without the need for additional aircraft
tests, providing there are no unresolved in-service HIRF problems related to the
existing aircraft. If there is uncertainty about the effects of the differences,
additional tests and analyses should be conducted as necessary and appropriate to
resolve the uncertainty. The amount of additional testing should be commensurate
with the degree of difference identified between the new aircraft and the aircraft
previously certified. If significant differences are found, similarity should not be
used as the basis for aircraft-level verification.
m. Step 13 — Assess immunity
1. The test levels used for the integrated system test of Step 5 should be compared
with the internal RF current or RF fields determined by the aircraft low-level
coupling tests (see Step 10), the generic transfer functions and attenuation (see
Step 11), or the aircraft similarity assessment (see Step 12). The actual aircraft
internal RF currents and RF fields should be lower than the integrated system test
levels. The applicant’s comparison method should be included in the HIRF
compliance plan. The method should enable a direct comparison between the
system test level and the aircraft internal HIRF environment at the equipment or
system location, using current for frequencies from 10 kHz through 400 MHz, and
using electric field strength for frequencies from 100 MHz through 18 GHz.
2. If the conducted RF susceptibility test levels used for the integrated system test
(see Step 5) were too low when compared with the aircraft-induced currents
determined in Steps 10b, 10c, 11 or 12, then corrective measures may be needed
(see Step 14). If the radiated RF susceptibility test levels used for integrated system
tests (see Step 5) were too low when compared with the aircraft internal fields
determined in Steps 10d, 11 or 12, then corrective measures may also be needed
(see Step 14).
3. When comparing the current measured during low-level swept-current tests in
Step 10c with the current used during the integrated system tests in Step 5, there
may be differences. These differences may be due to variations between the actual
aircraft installation and the integrated system laboratory installation, such as wire
bundle lengths, shielding and bonding, and wire bundle composition. The worst-

AMC 20-158
case current signature for a particular wire bundle should be compared to the
current induced at the particular test level or equipment malfunction over discrete
frequency ranges such as 50 kHz to 500 kHz, 500 kHz to 30 MHz, and 30 MHz to
100 MHz. This comparison should be broken into discrete frequency ranges
because the resonant frequencies may differ between the integrated system tests
and the aircraft tests.
4. If the applicant used aircraft high-level tests (see Step 9) for aircraft HIRF
verification, it should be determined if there were any Level A system
susceptibilities. Any Level A system susceptibilities should be evaluated based on
the pass/fail criteria as established in the test plan (see paragraph 8.b.1). If the HIRF
susceptibilities are not acceptable, then corrective measures may be needed (see
Step 14).
5. HIRF susceptibilities that were not anticipated or defined in the test plan pass/fail
criteria may be observed during aircraft high-level tests or integrated system
laboratory tests. If so, the data collected during the HIRF compliance verification
process should be used to determine the effect of the HIRF susceptibility on the
aircraft systems and functions. The pass/fail criteria may be modified if the effects
neither cause nor contribute to conditions that adversely affect the aircraft
functions or systems, as applicable, in the HIRF regulations. The applicant should
provide an assessment of, and supporting rationale for, any modifications to the
pass/fail criteria to the Agency for approval. If the HIRF susceptibilities are not
acceptable, then corrective measures may be needed (see Step 14).
6. If the Level A systems show no adverse effects when tested to levels derived from
HIRF environment I or III, as applicable, then this also demonstrates compliance of
the system with HIRF environment II.
7. If the integrated system tests results (see Step 5) satisfy the pass criteria from 12
GHz to 18 GHz, and design analysis shows that the system has no circuits that
operate in the 18 GHz to 40 GHz frequency range, then this demonstrates by
analysis that the system is not adversely affected when exposed to HIRF
environments above 18 GHz. If these conditions are satisfied, further aircraft and
system tests and assessments above 18 GHz are not necessary.
8. Review the actual system installation in the aircraft and the system configuration
used for the integrated system test (see Step 5). If significant configuration
differences are identified, corrective measures may be needed (see Step 14).
9. Certain RF receivers with antennas connected should not be expected to perform
without effects during exposure to the HIRF environments, particularly in the RF
receiver operating band. Because the definition of adverse effects and the RF
response at particular portions of the spectrum depends on the RF receiver system
function, the applicant should refer to the individual RF receiver minimum
performance standards for additional guidance. However, because many RF
receiver minimum performance standards were prepared before implementation
of HIRF requirements, the RF receiver pass/fail criteria should be coordinated with
the Agency.
n. Step 14 — Corrective measures. Corrective measures should be taken if the system fails
to satisfy the HIRF immunity assessment of Step 13. If changes or modifications to the
aircraft, equipment, system or system installation are required, then additional tests may
be necessary to verify the effectiveness of the changes. The ED-14G, Section 20,

AMC 20-158
equipment tests, integrated system tests, and aircraft tests, in whole or in part, may need
to be repeated to demonstrate HIRF compliance.
o. Step 15 — HIRF protection compliance. The test results and compliance report should
be submitted to the Agency for approval as part of the overall aircraft type certification
or supplemental type certification process.
10. STEPS TO DEMONSTRATE LEVEL B AND C SYSTEM HIRF COMPLIANCE
a. Step 1 — System safety assessment. The applicant should determine the system failure
condition classification for the systems being certified on their aircraft using a system
safety assessment as discussed in paragraph 6.b.2. For systems classified with Hazardous
or Major failure conditions (Level B and C systems), the applicant should follow
compliance steps 2 through 8 listed below, as appropriate. These compliance steps are
also depicted in Figure 3 of this AMC, and are not necessarily accomplished sequentially.
For systems classified with Catastrophic failure conditions (Level A systems), the
compliance steps outlined in Chapter 9 should be followed.
b. Step 2 — Define aircraft and system HIRF protection. The applicant should define the
HIRF protection features that will be incorporated into the aircraft and system designs,
based on the HIRF environments that are applicable to their aircraft and its Level B and C
systems. Equipment, system, and aircraft HIRF protection design may occur before
aircraft-level tests are performed, and before the actual internal HIRF environment is
determined. Therefore, the equipment, system and aircraft HIRF protection design
should be based on an estimate of the expected internal HIRF environment.
c. Step 3 — Select compliance method. The applicant should determine whether to
perform equipment HIRF tests on the Level B and C systems, or whether to base
compliance on previous equipment tests performed for a similar system.
d. Step 4 — Equipment test
1. Level B and Level C systems do not require the same degree of HIRF compliance
testing as Level A systems and, therefore, do not require aircraft-level testing. ED-
14G, Section 20, laboratory test procedures should be used, using equipment test
levels defined in the regulations. The test levels used depend on whether the
system is categorised as Level B or C. Equipment HIRF test level 1 or 2, as applicable,
should be used for Level B systems. ED-14G, Section 20, Category RR, satisfies the
requirements of equipment HIRF test level 1. For equipment HIRF test level 2, the
applicant may use the approach in paragraph 9.k. to help determine acceptable
aircraft transfer function and attenuation curves for their Level B system.
Equipment HIRF test level 3 should only be used for Level C systems. ED-14G,
Section 20, Category TT, satisfies the requirements of equipment HIRF test level 3.
When applying modulated signals, the test levels are given in terms of the peak of
the test signal as measured by a root mean square (rms), indicating spectrum
analyser’s peak detector. See the User’s Guide (SAE ARP 5583A/EUROCAE ED-
107A) for more details on modulation.
2. Define the appropriate pass/fail criteria for the system, based on the system safety
assessment and the appropriate HIRF regulation (see paragraph 6.b.2). Any
susceptibility noted during the equipment tests, including equipment
malfunctions, upset, or damage, should be recorded and evaluated based on the
defined pass/fail criteria.

AMC 20-158
e. Step 5 — Similarity assessment

1. The equipment HIRF tests performed for a system previously certified on one
aircraft model may be used to show compliance for a similar system. Each system
considered for similarity needs to be assessed independently even if it may use
equipment and installation techniques that have been the subject of a previous
certification.
2. The system used as the basis for certification by similarity must have been
previously certified for HIRF compliance on another aircraft model, and must have
successfully completed equipment HIRF tests. Similarity assessment requires
comparison of both equipment and installation differences that could adversely
affect HIRF immunity. An assessment of a new system should consider the
differences in the equipment circuit interfaces, wiring, grounding, bonding,
connectors, and wire-shielding practices.
system and the new system to be certified, similarity may be used for HIRF
compliance without the need for additional equipment HIRF tests, providing there
are no unresolved in-service HIRF problems related to the previously certified
system. If there is uncertainty about the effects of the differences, additional tests
and analyses should be conducted as necessary and appropriate to resolve the
uncertainty. The amount of additional testing should be commensurate with the
degree of difference identified between the new system and the system previously
certified. If significant differences are found, similarity should not be used as the
basis for HIRF compliance.
f. Step 6 — Assess immunity
1. The results of the equipment test should be reviewed to determine if the pass/fail
criteria is satisfied. HIRF susceptibilities that were not anticipated or defined in the
test plan pass/fail criteria may be observed during equipment HIRF tests. If so, the
applicant should determine the effect of the HIRF susceptibility on the aircraft
systems and functions. The pass/fail criteria may be modified if the effects neither
cause nor contribute to conditions that adversely affect the aircraft functions or
systems, as applicable, in the HIRF regulations. The applicant should provide an
assessment of, and supporting rationale for, any modifications to the pass/fail
criteria to the Agency for approval. If the HIRF susceptibilities are not acceptable,
then corrective measures may be needed (see Step 7).
2. The actual system installation in the aircraft and the configuration used for the
equipment tests (see Step 4) should be reviewed. If significant differences in
grounding, shielding, connectors, or wiring are identified, corrective measures may
be needed (see Step 7).
3. Certain RF receivers with antennas connected should not be expected to perform
without effects during exposure to the HIRF environments, particularly in the RF
receiver operating band. Because the definition of adverse effects and the RF
response at particular portions of the spectrum depends on the RF receiver system
function, the applicant should refer to the individual RF receiver minimum
performance standards for additional guidance. However, because many RF
receiver minimum performance standards were prepared before implementation
of HIRF requirements, the RF receiver pass/fail criteria should be coordinated with

AMC 20-158
the Agency. Future modifications to the minimum performance standards should

reflect HIRF performance requirements.
g. Step 7 — Corrective measures. Corrective measures should be taken if the system fails
to satisfy the HIRF immunity assessment of Step 6. If changes or modifications to the
equipment, system, or system installation are required, then additional tests may be
necessary to verify the effectiveness of the changes. The ED-14G, Section 20, equipment
tests, in whole or in part, may need to be repeated to demonstrate HIRF compliance.
h. Step 8 — HIRF protection compliance. The test results and compliance report should be
submitted to the Agency for approval as part of the overall aircraft type certification or
supplemental type certification process.
11. MAINTENANCE, PROTECTION ASSURANCE, AND MODIFICATIONS
a. The minimum maintenance required to support HIRF certification should be identified in
the Instructions for Continued Airworthiness (ICA) as specified in CS 23.1529, CS 25.1529,
CS 27.1529, and CS 29.1529, as appropriate. Dedicated devices or specific features may
be required to provide HIRF protection for an equipment or system installation.
Appropriate maintenance procedures should be defined for these devices and features
to ensure in-service protection integrity. A HIRF protection assurance programme may
be necessary to verify that the maintenance procedures are adequate. The User’s Guide
(SAE ARP 5583A/EUROCAE ED-107A) provides further information on these topics.
b. The maintenance procedures should consider the effects of corrosion, fretting, flexing
cycles, or other causes that could degrade these HIRF protection devices. Whenever
applicable, specific replacement times for these devices and features should be defined
and identified.
c. Aircraft or system modifications should be assessed for the impact any changes will have
on the HIRF protection. This assessment should be based on analysis and/or
measurement.
[Amdt 20/13]

AMC 20-158
Appendix 1 to AMC 20-158 Generic transfer functions and

attenuation
1. Generic transfer functions

a. Suitable transfer functions for calculating the bulk current injection test levels for Level A
display systems (see paragraph 9.k.) are given in Figures A1-1 through A1-5. These are
derived generic transfer functions acquired from test results obtained from a significant
number of aircraft. The test results were then processed to establish a 95 per cent
population probability.
b. The transfer functions are normalised to a 1 V/m HIRF environment and may be
multiplied linearly by the external HIRF environment to establish the bulk current
injection test level requirements in the frequency range from 10 kHz up to 400 MHz. For
example, if the HIRF environment is 100 V/m at 3 MHz, then using Figure A1-1, multiply
0.7 mA/V/m by 100 V/m to establish a test level of 70 milliamperes (mA).
c. Consult the User’s Guide (SAE ARP 5583A/EUROCAE ED-107A) for details on the use of
generic transfer functions.
2. Generic attenuation
a. Figure A1-6 shows the generic attenuation for frequencies from 100 MHz to 18 GHz that
can be used for determining the internal HIRF environment where equipment and
associated wiring for Level A display systems (see paragraph 9.k.) are installed. This
internal HIRF environment provides the test level for the integrated system radiated
susceptibility laboratory test. The external HIRF environment should be divided by the
appropriate attenuation, in linear units, to determine the internal HIRF environment. For
example, 12 dB or a 4:1 attenuation means the test level is the applicable external HIRF
environment electric field strength reduced by a factor of 4.
b. Guidance on the use of the generic attenuation is given below.
1. No attenuation. No attenuation credit can be used when the Level A display
equipment and associated wiring are located in aircraft areas with no HIRF
shielding, such as areas with unprotected non-conductive composite structures,
areas where there is no guarantee of structural bonding, or other open areas
where no shielding is provided. The applicant may choose to use no attenuation
for equipment that may be installed in a broad range of aircraft areas.
2. 6 dB attenuation. This attenuation is appropriate when the Level A display
equipment and associated wiring are located in aircraft areas with minimal HIRF
shielding, such as a cockpit in a non-conductive composite fuselage with minimal
additional shielding, or areas on the wing leading or trailing edges, or in wheel
wells.
equipment and associated wiring are located entirely within aircraft areas with
some HIRF shielding, in aircraft with a metal fuselage or a composite fuselage with
shielding effectiveness equivalent to metal. Examples of such areas are avionics
bays not enclosed by bulkheads, cockpits, and areas near windows, access panels,
and doors without EMI gaskets. Current-carrying conductors in this area, such as
hydraulic tubing, control cables, wire bundles, and metal wire trays, are not all
electrically bonded to bulkheads they pass through.

AMC 20-158

equipment and associated wiring are located entirely within the aircraft areas with
moderate HIRF shielding, in aircraft with a metal fuselage or a composite fuselage
with shielding effectiveness equivalent to metal. In addition, wire bundles passing
through bulkheads in these areas have shields electrically bonded to the
bulkheads. Wire bundles are installed close to metal structure and take advantage
of other inherent shielding characteristics provided by metal structure. Current-
carrying conductors such as hydraulic tubing, cables, and metal wire trays are
electrically bonded to all bulkheads they pass through.
equipment and all associated wiring to and from equipment are located entirely
within areas with very effective HIRF shielding to form an electromagnetic
enclosure.
c. Different attenuation values may be appropriate for different frequency ranges. For
example, 0 dB attenuation may be used for the frequency range of 100 MHz to 400 MHz,
6 dB attenuation for the frequency range of 400 MHz to 1 GHz, and 12 dB attenuation for
the frequency range of 1 GHz to 18 GHz. If the applicant intends to use different
attenuation values for various frequency ranges, then the supporting rationale should
also be provided.
d. Consult the User’s Guide for details on the use of generic attenuation.
3. Measured transfer functions or attenuation. The applicant can produce their own generic
transfer functions and attenuation for their Level A display systems (see paragraph 9.k.) based
on actual measurements on their aircraft models. These transfer functions and attenuation can
then be used in their HIRF compliance submission in place of the generic transfer functions and
attenuation specified in this appendix. The Agency encourages this approach because it
provides a more accurate reflection of the true internal HIRF environment of the aircraft
models. However, if the applicant intends to produce their own generic transfer functions and
attenuation, then this approach should also be addressed in the HIRF compliance plan (see
paragraph 8.a.) that is submitted to the Agency for approval.

AMC 20-158
Figure A1-1 — Generic transfer function — Aeroplane
Generic transfer function normalised to 1 V/m for an aeroplane with a fuselage length of ≤ 25 m.
Generic transfer function normalised to 1 V/m for an aeroplane with a fuselage length of > 25 m and ≤ 50 m.

AMC 20-158
Generic transfer function normalised to 1 V/m for an aeroplane with a fuselage length of > 50 m.
Figure A1-4 — Generic transfer function — Rotorcraft
Generic transfer function normalised to 1 V/m for a rotorcraft.

AMC 20-158
Figure A1-5 — Generic transfer function — All aircraft
Generic transfer function normalised to 1 V/m for all aircraft.
Figure A1-6 — Generic attenuation values — All aircraft 100 MHz to 18 GHz
[Amdt 20/13]

AMC 20-170
AMC 20-170
AMC 20-170 Integrated modular avionics (IMA)

1. Introduction
1.1. Purpose
This Acceptable Means of Compliance (AMC) provides a means that can be used to
demonstrate that the safety aspects of integrated modular avionics (IMA) systems
comply with the airworthiness requirements when such systems are integrated in a
product, a part, or an appliance submitted to EASA for approval.
Compliance with this AMC is not mandatory and hence an applicant may elect to use
alternative means of compliance. However, those alternative means of compliance must
meet the relevant certification specifications, ensure an equivalent level of safety, and be
accepted by EASA on a product basis.
1.2. Scope and applicability
The guidance contained in this AMC applies to any type certificate (TC) or supplemental
type certificate (STC) applicants seeking approval from EASA for IMA systems installed in
aircraft or rotorcraft.
IMA is a shared set of flexible, reusable and interoperable hardware and software
resources that, when integrated, form a system that provides computing resources and
services to hosted applications performing aircraft functions [ED-124].
An IMA architecture may integrate several aircraft functions on the same platform. Those
functions are provided by several hosted applications that have historically been
contained in functionally and physically separated ‘boxes’ or line replaceable units (LRUs).
This AMC addresses certification considerations for IMA systems, and should apply when:
— hosted applications* on the same platform are designed, verified and integrated
independently (at application level**) from each other; and
— the platforms/modules provide shared resources (typically designed, verified and
integrated independently from the hosted applications),
OR
— a process for obtaining incremental certification*** credit is anticipated or applied.
* A single application hosted on an independently developed platform is considered
to be a traditional federated architecture and thus is not subject to this AMC.
However, if additional application(s) that is (are) independently developed is (are)
hosted on the same platform at a later stage (e.g. through a major change), this
AMC should be applied.
** Software integration/verification activities are not performed on the whole set of
integrated software as in a federated architecture.
*** Credit for incremental certification in an IMA context as detailed in Section 4.

AMC 20-170
An applicant may choose to apply this AMC for a system which would not fulfil the
conditions above. In that case, early discussions should take place between the applicant
and EASA in order to confirm whether this AMC should be followed or not.
1.3. Document overview
This document:
(a) provides an overview of and background information on IMA systems and on
concerns related to their certification (Section 2);
(b) presents the EASA policy for IMA certification by recognising the use of EUROCAE
document ED-124, Integrated Modular Avionics (IMA) Development Guidance and
Certification Considerations, as an acceptable means of compliance for the
development and certification of IMA systems. It also clarifies and amends the
intent, scope, and use of that document (in Section 3);
(c) introduces the incremental certification approach, and introduces the link to ETSO
authorisations (ETSOAs) (in Section 4);
(d) complements ED-124 with additional considerations on dedicated topics, such as
environmental qualification, open problem reports (OPRs), and configuration files
(in Section 5).
1.4. Documents to be used with this AMC
This AMC should be used together with the following documents. The applicable version
of the documents for a given project will be established in the certification basis or in the
applicable CRIs.
Reference Title
ED-124/DO-297 Integrated Modular Avionics (IMA) Development Guidance and
Certification Considerations
ED-79/ARP4754* Certification Considerations for Highly-Integrated or Complex Aircraft
Systems
ED-79A/ARP4754A Guidelines for Development of Civil Aircraft and Systems
ED-12()/DO-178()** Software Considerations in Airborne Systems and Equipment
Certification
ED-80/DO-254 Design Assurance Guidance for Airborne Electronic Hardware
ARP4761() Guidelines and Methods for Conducting the Safety Assessment Process
on Airborne Systems and Equipment
ED-14()/DO-160() Environmental Conditions And Test Procedures For Airborne
Equipment
ED-215/DO-330 Software Tool Qualification Considerations
* ED-79A should be used, unless ED-79 is the applicable document in a given project.
** Recommendations for software are developed in AMC 20-115().
1.5. Referenced material
1.5.1. Certification specifications (CS) and acceptable means of compliance (AMC)
Reference Title
CS XX.1301 Function and installation
CS XX.1302 Installed systems and equipment for use by the flight crew
CS XX.1309 Equipment, systems and installations

AMC 20-170
Reference Title
AC 23.1309-1() System safety analysis and assessment for Part 23 airplanes
AMC 25.1309 System design and analysis
AC 27.1309 Equipment, systems and installations
AC 29.1309 Equipment, systems and installations
CS XX.1322 Flight crew alerting
CS-E 50 Engine control system
AMC E 50 Engine control system
AMC 20-3 Certification of engines equipped with electronic engine control
systems
AMC 20-115() Software considerations for certification of airborne systems and
equipment
ETSO-2C153 Integrated Modular Avionics (IMA) platform and modules
ETSO-C214 Functional-ETSO equipment using authorised ETSO-2C153 IMA
platform or module
The applicable version of the documents for a given project will be established in
the certification basis or in the applicable CRIs.
1.5.2. Referenced documents
Reference Title
ED-94C Supporting information for ED-12C and ED-109A
1.6. Definitions and abbreviations

1.6.1. Definitions
Term Meaning
Aircraft A capability of the aircraft that is provided by the hardware and
function software of the systems on the aircraft. [ED-124]
Application Software and/or application-specific hardware with a defined set of
interfaces that, when integrated with a platform(s), performs a
function. [ED-124]
Cabinet Result of the integration of hardware modules mounted within one
rack. [ETSO-2C153]
Compliance Evidence that a set of objectives related to certification requirements
credit has been reached for a component or a set of components.
Credit can be full or partial, meaning that, in case of partial credit,
some objectives allocated to the component were not yet satisfied
and should be completed at another stage.
Component A self-contained hardware part, software part, database, or
combination of them that is configuration-controlled. A component
does not provide an aircraft function by itself. [ED-124 Chapter 2.1.1]
Core software The operating system and support software that manage resources to
provide an environment in which applications can execute. Core
software is a necessary component of a platform and is typically
comprised of one or more modules (such as, for example, libraries,
drivers, kernel, data-loading, boot, etc.). [ED-124]
Federated Aircraft equipment architecture consisting of primarily line
system replaceable units that perform a specific function, connected by
dedicated interfaces or aircraft system data buses. [ED-124]

AMC 20-170
Term Meaning
IMA system Consists of an IMA platform(s) and a defined set of hosted
applications. [ETSO-2C153]
Incremental The incremental certification process is the process by which EASA
certification agrees to grant compliance credit to IMA modules/platforms or
hosted applications considered independently, based on activities
performed at intermediate steps.
Intermixability The capability to intermix software and/or hardware of different
versions and/or modification standards. [ED-124]
Interoperability The capability of several modules to operate together to accomplish a
specific goal or function. [ED-124]
Module A component or collection of components that may be accepted by
themselves or in the context of an IMA system. A module may also
comprise other modules. A module may be software, hardware, or a
combination of hardware and software, which provides resources to
the IMA system hosted applications. [ED-124]
Module/ The action of setting some adjustable characteristics of the
platform module/platform in order to adapt it to the user context.
configuration By extension, the result of this action.
NOTE: A configuration table is one way but not the only way to
configure a module/ platform.
Partitioning Partitioning is ‘An architectural technique to provide the necessary
and robust separation and independence of functions or applications to ensure
partitioning that only intended coupling occurs.’ [ED-124]
Robust partitioning is a means for assuring the intended isolation in
all circumstances (including hardware failures, hardware and
software design errors, or anomalous behaviour) of aircraft functions
and hosted applications using shared resources. The objective of
robust partitioning is to provide a level of functional isolation and
independence equivalent to that of a federated system
implementation.
Platform A module or group of modules, including core software, that manages
resources in a manner sufficient to support at least one application.
[ED-124]
Resource Any object (processor, memory, software, data, etc.) or component
used by a processor, IMA platform, core software or application. A
resource may be shared by multiple applications or dedicated to a
specific application. A resource may be physical (a hardware device)
or logical (a piece of information). [ED-124]
Support Embedded software necessary as a complement to the operating
software system to provide general services such as contributing to the
intended function of resources sharing, handling hardware, drivers,
software loading, health monitoring, boot strap, etc. [ETSO-2C153]
Usage domain The usage domain of an IMA module is defined as an exhaustive list
of conditions (such as configuration settings, usage rules, etc.) to be
respected by the user(s) to ensure that the IMA module continues to
meet its characteristics. Compliance with the usage domain ensures
that:
the module is compliant with its functional, performance, safety and
environmental requirements specified for all implemented intended
functions;
the module characteristics documented in the user guide/manual
remain at the levels guaranteed by the manufacturer;

AMC 20-170
Term Meaning
the module remains compliant with the applicable airworthiness
requirements (including continuing airworthiness aspects).
[Adapted from ETSO-2C153, without reference to the ETSO Minimum
Performance Standard]
1.6.2. Abbreviations
Abbreviation Meaning
AEH airborne electronic hardware
API application programming interface
ATA air transport association of America
CRI certification review item
CS certification specification
EASA European Aviation Safety Agency
ETSO European technical standard order
ETSOA European technical standard order authorisation
F-ETSO functional ETSO
HW hardware
IDAL item development assurance level
I/O input/output
IMA integrated modular avionics
LRU line replaceable unit
MMEL master minimum equipment list
OPR open problem report
RSC reusable software component
SOI stage of involvement
STC supplemental type certificate
SW software
TC type certificate
TQL tool qualification level
TSO technical standard order
TSOA technical standard order authorisation
2. Background
The use of IMA has rapidly expanded in the last two decades and is expected to progress even
more in the future in all types of products, parts and appliances. Additional guidance is hence
needed to address specific aspects at the application, component, platform, system, and aircraft
levels.
2.1. IMA overview
A representation of a simple IMA architecture is illustrated in Figure 1:
— Applications implementing several aircraft functions are hosted on the same
platform. Several applications (e.g. Applications 1.1 & 1.2) may contribute to the
same aircraft function.
— The platform consists of:

AMC 20-170
— a hardware layer offering resources shared by the applications; and

— a software layer, also known as ‘middleware’, including the operating
system, health monitoring, various kinds of services and hardware drivers
(core software [ED-124] and support software [ETSO-2C153]).
— Through the middleware, the platform mainly:
— provides services to the software applications;
— manages the interfaces between software applications;
— manages the internal/external resources shared between software
applications; and
— ensures isolation between applications.
— External inputs/outputs (I/Os) may encompass a wide scope of interfaces such as
discrete data, various data buses or analogue signals.
— The software applications and the platform may be independently provided by
different stakeholders (i.e. different system suppliers, or entities pertaining to the
same company/group).
Figure 1 — Illustration of an IMA architecture
Note: Examples of different classes of electronic hardware parts constituting a

platform/module can be found in ETSO-2C153.
Figure 2 shows a functional projection of an IMA architecture at aircraft level:
— Each aircraft function may have its own set of LRUs connected to the platform
(which provides/gets the data to/from the application).
— The set of I/O may cover a large range of items, such as:
— input items: data from sensors, control panels, data received from other
applications/systems;

AMC 20-170
— output items: data to actuators, displays, and data transmitted to other

applications/systems.
Figure 2 — Functional projection of an IMA architecture at aircraft level
An example of an IMA architecture is illustrated in Figure 3.

AMC 20-170
Figure 3 — Illustration of an IMA architecture
2.2. IMA system breakdown into aircraft systems (ATA chapters)

The organisation of an IMA system into aircraft systems (e.g. ATA chapters) provides
structure to a certification project and to the methods used to demonstrate compliance.
This breakdown may depend on (this list is not exhaustive):
— the aircraft and systems’ architecture;
— the industrial organisation and work sharing;
— the applicant’s development methods; and/or
— the aircraft maintenance principles and procedures (closely linked to ATA-XX
chaptering).
Note: Applicants may elect to address the IMA items and activities (not the hosted
functions) within an ATA chapter dedicated to IMA systems such as ATA-42.
2.3. IMA certification concerns
From a certification viewpoint, the use of an IMA architecture raises the following
concerns:
— failures or faults of the IMA platforms (including hosted applications) or LRUs
connected to the communication network and the associated interfaces may cause
the malfunction, loss or partial loss of more than one function;
— the potential for some failures to propagate and create multiple failure conditions;
— the lack of design independence among common hardware resources;

AMC 20-170
— susceptibility to common mode failures, faults or design errors, within several

identical modules or within the communication network;
— a lack of assurance that the system will behave as intended once all the hosted
applications are integrated onto the platform/modules, when software and
electronic hardware items have been independently developed and verified;
— inappropriate resource management leading to potential access conflicts and a
lack of determinism or unexpected system behaviour; and
— improper isolation mechanisms or configuration not ensuring correct partitioning
between functions.
2.4. Functional isolation and independence
From a safety perspective, the primary purpose of the IMA design and certification
activities is to demonstrate that the level of functional isolation and independence
between the aircraft functions hosted in the IMA system is equivalent to that which
would be achieved in a federated architecture.
Functional isolation mostly relies on three pillars:
— proper allocation of shared resources, to prevent adverse interference between
hosted applications;
— robust partitioning, concretely assuring the isolation and detection/mitigation of
partitioning violations;
— fault containment, to prevent the propagation of faults between hosted
applications.
3. Policy for IMA system certification
This section provides guidance to be used for the certification of an IMA system. Considering
the IMA architecture, industrial organisation, and the experience in IMA system development
of the applicant, several approaches are considered:
— use of the ED-124 standard;
— use of an alternative means to demonstrate compliance;
— use of previously recognised IMA certification processes.
3.1. Use of ED-124
3.1.1. Recognition of ED-124
EUROCAE document ED-124 on Integrated Modular Avionics (IMA) Development
Guidance and Certification Considerations, published in July 2007 (equivalent to
the RTCA document DO-297), provides guidance for the development and
certification of IMA systems.
The use of ED-124 is acceptable to EASA to support the certification of IMA systems
when it is used in conjunction with the additional considerations described in this
AMC.
3.1.2. Scope of this AMC with respect to ED-124
ED-124 encompasses various aspects and some concepts which are not compatible
with the EASA system or which are considered to be outside the scope of this AMC:

AMC 20-170
— It is not the intent of this AMC to cover the development processes for
aircraft functions, even if they are implemented by applications hosted in an
IMA system.
— In relationship with ED-124, it is not the intent of this AMC to cover:
— operational aspects of master minimum equipment lists (MMELs) (ED-
124 Chapter 3.9);
— considerations for continued airworthiness (ED-124 Chapter 6);
— the safety assessment process (ED-124 Chapter 5.1).
— The cybersecurity aspects (ED-124 Chapter 5.1.5.8) are not adequate, and
should be superseded by the applicable cybersecurity standards as defined
in the project certification basis.
— Regarding the incremental certification process presented in ED-124:
— the ‘letter of acceptance’ concept is not feasible in the EASA context.
The certification given by EASA is limited to only a specific aircraft type
certification (TC), or to a subsequent aircraft level certification of a
system change or in the frame of a supplemental type certificate
(STC), or granted through an ETSOA;
— the alternate concept of ‘reusable software component (RSC)’
acceptance as described in ED-124 Chapter 4, Table 4, with reference
to FAA AC 20-148, is not feasible in the EASA context as it makes use
of acceptance letters for software parts.
3.1.3. Clarification and use of ED-124
ED-124 defines a complete ‘end-to-end’ framework and a set of objectives to
support the certification of IMA systems, i.e. from the development of
software/airborne electronic hardware (SW/AEH) items to aircraft integration.
As it covers the complete development and certification of IMA systems, ED-124
may contain some objectives, activities and life cycle data similar to those that
apply to a federated architecture, and which may not be IMA-specific. Additionally,
some considerations in ED-124 may overlap or may be considered to be addressed
by other applicable guidance documents (e.g. ED-79).
The way in which ED-124 was written, e.g. by allocating objectives, activities and
life cycle data to the various ‘tasks’, should therefore not be interpreted:
— as imposing a unique scheme in terms of the project organisation,
sequencing of activities and expected life cycle data required to meet the
objectives; or
— as requesting the duplication of activities or life cycle data.
The following sections further explain the flexibility which is inherent in the ED-124
approach and which is fully recognised by EASA.
3.1.3.1. The ED-124 task framework
ED-124 structures the IMA development activities by tasks and objectives to
be achieved at the AEH/SW/module item level. This framework also suggests
a definition of roles and responsibilities of the different stakeholders

AMC 20-170
involved in the IMA system development (e.g. application supplier, IMA

system integrator).
Figure 4 illustrates a mapping between an IMA system breakdown and the
certification tasks of ED-124:
Figure 4 — Mapping between an IMA system and the ED-124 certification tasks
Among the considerations detailed in the ED-124 tasks, the key IMA
specificities are:
— Task 1: the need to develop resources/services to be shared by
applications and the adequate associated mechanisms
(partitioning, health monitoring, etc.), and the need to
document these resources, services and mechanisms for the
IMA platform users;
— Task 2: the need to characterise the applications in terms of
their resource usage and execution constraints, and the need
to verify that the applications satisfy the usage domain of the
platform;
— Task 3: the need to verify that the whole set of applications
complies with the platform usage domain, and the proper
implementation of the resource allocation and platform
configuration requests from the applications;
— Task 4: has little specificity in comparison with non-IMA
systems.
3.1.3.2. Relationship with other guidelines
In order to maximise the credit taken from other standards and existing
processes, two certification approaches based on the ED-124 tasks and
objectives are considered eligible to support an IMA system certification:

AMC 20-170
(a) an IMA system perspective: by considering the application of ED-124

as a complete and consistent set of objectives;
(b) an aircraft perspective: where the IMA system certification and its
specificities are addressed within the global framework of the aircraft
certification and its related processes. This means that ED-124
considerations/objectives may be covered by other aircraft system
processes and activities.
As ED-79 provides guidance and acceptable means of compliance for the
development of systems, ED-79 processes may be used to cover ED-124
objectives and activities. However, the use of ED-79 will not ensure
exhaustive coverage of the ED-124 objectives. Consequently, the IMA-
specific objectives and activities of ED-124 will remain to be addressed
separately from the ED-79 objectives.
These two approaches are suitable because they would ensure the
completeness of the activities supporting an IMA system certification.
Figure 5 — Links between ED-124 tasks and other guidelines
3.1.3.3. Tailoring of ED-124 tasks

A task framework is proposed by ED-124, but it is not the purpose of AMC
20-170 to enforce this division of tasks. The allocation of the ED-124
objectives to the ED-124 tasks can be tailored by the applicant.
For instance, an IMA specificity is the need to coordinate verification
activities such that the performance of the integrated IMA system can be

AMC 20-170
guaranteed without requiring the reverification of each hosted application

on the entire integrated system:
— ED-124 Chapter 3.1.3 d.2 may be interpreted as requesting that
IMA integration should be performed with the full set of
applications. However, the applicant may integrate and verify
applications independently on the IMA platform, taking into
account the platform properties (e.g. robust partitioning and
resource management).
— Some Task 3 objectives may be already anticipated and
accomplished during Task 2, or they may be deferred to Task 4.
If the applicant intends to develop an IMA system and the supported aircraft
functions by tailoring the ED-124 tasks or by following another framework,
the applicant should detail the division of tasks, the objectives of each work
package, and the associated activities.
The applicant should describe how the work package objectives are mapped
to the ED-124 objectives in order to ensure that the objectives of ED-124 are
met within the alternative framework presented by the applicant. The ED-
124 life cycle data can be also adapted to the division of tasks and work
packages defined by the applicant.
Moreover, ED-124 Task 4 may have few IMA specificities compared to a
federated architecture. The achievement of Task 4 to support compliance
demonstration in the frame of this AMC could be deemed to be outside the
scope of this AMC, provided that:
— the aircraft integration activity is covered through other
guidance and its related applicant processes (to be clarified in
the certification plan);
— Task 3 is complete: meaning that no objectives, activities, or life
cycle data are deferred to or covered by Task 4.
Another area where tailoring can be performed is requirement validation.
ED-124 Chapter 5.3.a. considers that each level of requirements within the
hierarchy should be validated prior to validating the next lower level. A strict
interpretation of this statement would not allow the development of a
platform based on the assumptions for the intended use without
consideration of the final aircraft functions (as suggested in Chapter 4.2.1.b).
Also, it would imply a top-down approach from the aircraft functions to the
level of hardware and the core/support software, which may not be
relevant. A bottom-up approach is also feasible, which involves ensuring that
the platform usage rules and constraints identified in the platform user
guide/manual (Chapter 4.2.12.e.) are fulfilled, and that they satisfy the IMA
system requirements.
3.1.4. Use of alternative means to demonstrate compliance
If an applicant elects to comply with an alternative means to demonstrate
compliance with the CS, consistency with the ED-124 acceptance objectives in
Annex A tables [A1-A6] (IMA module/platform development process objectives)
should be demonstrated.

AMC 20-170
Early coordination with EASA should be ensured.

3.2. Use of previously recognised means of compliance
Applicants who did not use this AMC in their past IMA certifications and who successfully
used other means of compliance that were:
— discussed in specific CRI(s);
— previously recognised as equivalent to the ED-124 objectives; and
— previously accepted by EASA for covering IMA certification concerns,
may use the same means of compliance for their certification project, provided that the
IMA system is similar to the previously certified one (i.e. with a similar architecture, the
same design concepts, the same development process, and the same certification
approach).
Early coordination with EASA to confirm the use of the applicant’s previously recognised
means of compliance should be ensured.
3.3. Role of the IMA system certification plan
ED-124 objectives can be met by using various industrial mappings, based on the sharing
of roles, activities and life cycle data. The strategy selected for demonstration of
compliance with this AMC should be defined by the applicant in their certification plans.
An IMA system certification plan should introduce the planning, the organisation, the
work share, work packages, and the development, validation, integration, and
verification activities of the IMA system.
Considerations regarding the content of an IMA system certification plan can be found in
ED-124 Chapter 4.4.3. The certification plan should particularly emphasise the following
topics:
— The scope covered by the IMA system certification plan and its relationship with
other certification plans, including the certification plans of the aircraft functions
hosted (totally or partially) on the IMA system.
— The strategy proposed by the applicant to demonstrate compliance with this AMC,
including:
— the certification approach selected (see paragraph 3);
— the relationship and credit potentially taken from other standards or
processes to satisfy the objectives of ED-124;
— the nature and extent of credit claimed from previously approved
components (i.e. having obtained an ETSOA) or from activities performed on
components reused from previous certification projects (see paragraph 4);
— the identification of modules, platforms and applications for which full or
partial incremental compliance credit is sought.
— The industrial organisation supporting the IMA system development and
certification, including the roles, responsibilities and work share between the
stakeholders, with, in particular:
— the sharing of activities related to aircraft functions hosted on the IMA
platform and the IMA system integration activities;

AMC 20-170
— when applicable, the tailoring and scope of the ED-124 tasks, or ED-124 life
cycle data;
— the work package allocated to each IMA stakeholder, including the design,
validation, verification and integration activities, including environmental
qualification under their responsibility and the credit claimed for the
incremental certification.
— The activities planned for the integration of the IMA system and its installation on
an aircraft with an emphasis on:
— the establishment of full or partial incremental credit gained from the
integration, validation and verification activities conducted at each stage of
the development, with their associated transition criteria. If a future step
cannot be planned by a stakeholder, who for instance would
— only perform the development of a function, the interface to future steps
and the assumptions made (e.g. on resources used) need to be identified;
— the credit expected from the characteristics of the IMA platform to
independently verify aircraft functions allocated or partially allocated to the
IMA system;
— the activities to be completed for the installation of an ETSO-2C153 or C214
article;
— the rationale for not performing some ground or flight tests when the IMA
system is installed on the aircraft.
— A description of the development and verification environments, with emphasis on
the tools used to generate data or automate the activities and the rationale for the
qualification or non-qualification of the tools.
Note: A dedicated IMA system certification plan may not be required provided that its
role is equivalently performed by a comprehensive set of documents in the applicant’s
data package.
4. Incremental certification process
As indicated in Section 3.1.2, the concepts of ‘letters of acceptance’ and of ‘reusable software
components (RSCs)’ are not compatible with the EASA system.
Furthermore, within the EASA system, there is currently no means to benefit from the
certification credit granted within a TC or an STC in the frame of another product certification.
Formal compliance credit can only be claimed from an ETSOA.
However, the lack of an ETSOA, or the absence of a letter of acceptance, does not prevent an
applicant from incrementally building confidence and demonstrating compliance of IMA
components during the development flow (as per the ED-124 task framework), nor does it
prevent the reuse of previous certification artefacts and activities for a new demonstration of
compliance.
The incremental certification process is the process to certify a product for which EASA agrees
to grant some credit to a component/module, application or system, before that module,
application or system is configured, integrated and certified as part of the final product. The
incremental certification process applies to the following approaches:

AMC 20-170
(a) Incremental component qualification: credit is taken from activities performed during
various steps of the development in order to reduce the effort during a subsequent phase
(e.g. verification activities). This qualification is mainly built up using the incremental
verification approach.
(b) Reuse: credit is taken from activities performed on components (modules, platforms,
applications) reused from other projects. This approach encompasses the components
reused from a previously approved TC or from legacy IMA systems.
(c) Compliance credit: formal credit is claimed from an ETSOA.
In all cases, the applicant should evaluate and substantiate the suitability and level of the credit
sought. Early coordination with EASA should be ensured.
Note: An ETSOA is not a mandatory step in the certification of an IMA system.
Demonstration of
Evidence supporting the
Approach compliance — Applicant activities
claim
responsibilities
(a) Incremental Under the full Full compliance Evidence of review and
component responsibility of the demonstration is acceptance by the
qualification applicant*. expected from the applicant, covering all
See paragraph applicant. objectives for which credit
4.1 is sought, including final
review reports (at
software, hardware,
platform, IMA system
level(s), as applicable).
(b) Reuse from Under the full Compliance Previous set of evidence.
previous TC responsibility of the demonstration may be Evidence of review and
See paragraph applicant*. tailored depending on acceptance by the
4.2 the agreement with applicant, covering all
EASA**. objectives for which credit
Note: Demonstration of is sought, including final
compliance for the IMA review reports (at
components may be software, hardware,
reduced (e.g. no platform, IMA system
software development level(s), as applicable).
and verification reviews
(SOI#2&3) as part of
Task 2).
(c) Compliance Shared between the: Compliance ETSOA
credit ETSO holder for the demonstration is
See paragraph scope covered by the reduced according to
4.3 ETSOA (e.g. the certification credit
module/platform); claimed from the ETSOA.
applicant* for the
completion of
integration and/or
installation activities.
Incremental certification evidence table

* Applicant stands for the applicant developing and/or installing the IMA system.

AMC 20-170
** Discussions held on a case-by-case basis based on the information provided through the
certification plan.
Whatever the approach selected for the recognition of credit and the level of credit granted,
the applicant remains responsible for ensuring and for demonstrating that each component is
integrated and installed consistently with its function, interfaces, usage domain, and limitations.
4.1. Incremental component qualification
One main characteristic of IMA systems and the ED-124 task framework is that they allow
a high level of independence in the design and verification activities:
— between the functional level (application) and the resource level
(module/platform);
— between different applications (except for possible functional coupling between
applications).
In addition, Chapter 2.2.e of ED-124 introduces the concept of ‘composability’, where the
integration of a new application does not invalidate any of the verified requirements of
an already integrated application. When an IMA system is ‘composable’, credit can be
taken from its properties (e.g. robust partitioning) regarding two aspects:
— during the development of the application itself: credit may be taken from
module/platform development activities;
— during the integration and verification activities: credit may be taken from the
integration of the application and from the absence of impact on other already
verified and installed applications.
These principles drive a modular approach, which can be used to support an incremental
component qualification process, provided the following considerations are fulfilled:
— The applicant should define criteria and supporting evidence to demonstrate the
achievement of all objectives for which credit is sought.
— The applicant should assess, and record through a formal review, the achievement
and acceptance of a set of objectives for a given component. For instance, a final
software and hardware review (SOI#4) on the components of a module and the
acceptance of the corresponding software and hardware accomplishment
summaries could support the completion of ED-124 Task 1.
Depending on the framework and organisation, strict AMC 20-115() or ED-80 compliance
may not, on its own, be sufficient to show the achievement of a given task.
Complementary accomplishment summaries should be provided and encompassed in the
applicant’s review.
4.2. Reuse of components
The applicant remains fully responsible for the contents of the associated data, which
have to be assessed through the applicant’s activities as being reusable in the context of
the current certification project.
4.2.1. Reuse from a legacy IMA system
Components that were previously approved may be reused provided that the
applicant shows that the reuse of the component is appropriate. If changes are
necessary, a change impact analysis should be performed to identify the scope of
the changes and the necessary activities to re-engage in to cover the changes.

AMC 20-170
4.2.2. Reuse from a previous ED-124 project

The management of reused components is addressed through ED-124 Task 6 (ED-
124 Chapter 4.7). If changes are intended, they should be managed through ED-
124 Task 5 (ED-124 Chapter 4.6).
Note: To facilitate the reuse of a component, ED-124 recommends developers to
anticipate such reuse during the initial development through dedicated objectives
that are part of Tasks 1 & 2 (e.g. the module acceptance plan providing the data
listed in Chapter 4.2.3.h).
4.3. Compliance credit
In the frame of this AMC, formal certification credit is offered from an ETSOA granted to:
— platform(s)/module(s): ETSO-2C153;
— application(s) integrated with an ETSO-2C153 module/platform: ETSO-C214.
4.3.1. Use of an ETSO-2C153 authorisation
An ETSO-2C153 can be granted to a platform(s)/module(s) in order to facilitate its
(their) use in an IMA system. As per ETSO-2C153 paragraph 3.2.2.1, the IMA
module or platform should meet the ED-124 Task 1 objectives. Compliance credit
could be hence claimed by an applicant for the demonstration of compliance with
ED-124 Task 1, provided the platform(s)/module(s) had obtained an ETSO-2C153
authorisation beforehand.
Nevertheless, the ETSOA does not by itself ensure that the platform(s)/module(s)
is (are) technically adequate to be integrated into the IMA system. The applicant
remains responsible for all the activities to ensure the proper integration of the
ETSO-2C153 platform(s)/module(s) into the IMA system, and the applicant should:
— substantiate the scope of the ETSOA compliance credit, and define the
complementary certification activities based on the data provided (e.g.
user/installation manuals);
— demonstrate the correct use of the platform(s)/module(s), including
compliance:
— with the platform/module integration requirements/user requirements, and
the IMA system and safety requirements;
— of the use, the partitioning, the health monitoring, the configuration of the
resources and the installation of the items with the platforms/modules user
guide/manual, installation manual, or equivalent data (as documented per
ETSO-2C153 Appendix 3). This also includes the deactivation or disabling of
unused ETSO-2C153 functions/modules, when available, or the means to
ensure that the intended function is performed without any interference
from unused ETSO-2C153 functions/ modules.
This section only addresses the use of EASA ETSO-2C153, and its use cannot be
extended to any other authority TSO standards on IMA platforms and modules that
are not equivalent in their technical requirements.
4.3.2. Use of a functional ETSO-C214 authorisation
Through a functional ETSO-C214 (F-ETSO), an authorisation can be granted to
application(s) integrated with an ETSO-2C153 module/platform. As per ETSO-C214,

AMC 20-170
compliance with the ED-124 Task 2 & 3 objectives has to be demonstrated.

Compliance credit could hence be claimed by an applicant for the demonstration
of compliance with ED-124 Tasks 2 & 3, provided that the F-ETSO-C214
authorisation had been obtained beforehand.
Nevertheless, the functional ETSOA does not by itself ensure that the ETSO article
is technically adequate to be installed in the product. The applicant remains
responsible for all the activities to ensure the proper integration of the
application(s)/module(s)/platform(s) into the IMA system, and the applicant
should:
— substantiate the scope of the ETSOA compliance credit, and define the
complementary certification activities;
— complete the demonstration that the function covered by the F-ETSO article
complies with the IMA system and safety requirements.
If the F-ETSO article is in the ‘open’ class and the applicant intends to perform
incremental development on the ETSOA article (e.g. to add an application), the
considerations of this AMC apply to the new and affected items. The applicant
should ensure the integrity and continuity of the system configuration, and in
particular should show that the resource allocation, partitioning, and health
monitoring are not impaired by the intended changes to the ETSOA article. The
level of credit that can be obtained from the F-ETSO article, and the certification
activities to be completed in the frame of this AMC, will hence vary depending on
the scope of the changes made to the initial F-ETSO article.
If the F-ETSO article is in the ‘closed’ class, it no longer offers any capability for IMA
development. Credit can be taken for ED-124 Tasks 2 and 3. This closed F-ETSO
article is equivalent to a conventional ETSO article.
4.3.3. Summary of ETSO compliance credit
The following table summarises the credit that can be claimed from ETSO-2C153
and ETSO-C214, and the remaining certification activities to support the
demonstration of compliance with AMC 20-170:
ETSOA Credit Remaining activities
ETSO-2C153 Acceptance of the Substantiation of the scope
platform/module of ETSOA compliance credit.
(ED-124 Task 1) All subsequent activities
(ED-124 Tasks 2 and 3, plus
those deferred to Task 4).
ETSO-C214 ‘open’ class Acceptance of the Substantiation of the scope

(ED-124 Task 1) Demonstration that the F-
ETSO article complies with

AMC 20-170
Acceptance of the non- the IMA system and safety

impacted hosted requirements.
application(s) All activities impacted by
(ED-124 Task 2) the incremental
development, such as on
the modified or new hosted
application (ED-124 Tasks
2), and IMA configuration
and integration (ED-124
Task 3 plus those deferred
to Task 4.)
ETSO-C214 ‘closed’ class Acceptance of the Substantiation of the scope

(ED-124 Task 1)
Acceptance of the
hosted application(s)
(ED-124 Task 2)
IMA configuration and
integration
(ED-124 Task 3)
ETSO compliance credit table for AMC 20-170
5. Additional recommendations for IMA system certification

5.1. Fault management and human factors
ED-124 Chapter 3.6.5 deals with the annunciation of failures to the crew. CS XX.1322 and
the associated AMC address flight crew alerting systems and warning, caution, or
advisory lights. In any case where an inconsistency is identified between the text in ED-
124 and the text in CS XX.1322 and the associated AMC, the text in CS XX.1322 and the
associated AMC should prevail.
Similarly, for any inconsistency between the text in ED-124 Chapter 3.10 dealing with
human factors and the text in CS XX.1302 and the associated AMC, the text in CS XX.1302
and the associated AMC should prevail.
5.2. Configuration data/parameter data items
Guidance on IMA configuration data is provided in ED-124 Chapter 3.7.1.1 at the IMA
system level and in Chapter 3.7.1.2 at the application level. These data items are
nowadays described as ‘parameter data items’ as defined in ED-12C and should be
treated in the same way as other elements of the software. Depending on how a
parameter data item is to be used in the IMA system or application, it needs to be defined,
managed and documented at the appropriate level (platform, module, application) and

AMC 20-170
to comply with the AMC 20-115()1 guidance, including the process to ensure
intermixability and compatibility during the post-TC period as indicated in ED-124. In
particular, any parameter data item should be assigned the same software level as the
component using it.
5.3. Use of tools and the need for qualification
IMA system development may be supported by the use, at the system level, of tools in
order to eliminate, reduce, or automate the activities associated with the ED-124
objectives. If a tool could introduce an error or could fail to detect an error, and there are
no other alternative means to detect the issue, qualification of the tool is needed.
For instance, a tool may be used to generate and/or verify IMA configuration data and
may produce an erroneous configuration that is not necessarily easily detectable at a
subsequent integration/verification step.
The objectives of tool qualification are to:
— ensure an equivalent level of confidence to the non-automated process/activities;
— demonstrate that the tool complies, and its qualification is commensurate, with
the intended use.
Adequate guidance for tool qualification is provided in ED-215, Software Tool
Qualification Considerations, and should be followed when a tool is intended to be
qualified to support the IMA system development.
The following criteria should be used to determine the appropriate tool qualification level
(TQL), according to its intended use:
(a) Impact of the tool:
(1) Criterion 1: a tool whose output is part of the IMA system and thus could
introduce an error.
(2) Criterion 2: a tool that automates verification process(es) and thus could fail
to detect an error, and whose output is used to justify the elimination or
reduction of:
— verification process(es) other than that (those) automated by
the tool; or
— development process(es) that could have an impact on the IMA
system.
(3) Criterion 3: a tool that, within the scope of its intended use, could fail to
detect an error.
(b) IDAL of the IMA component supported by the tool:
Criteria
IDAL
1 2 3
A TQL-1 TQL-4 TQL-5
B TQL-2 TQL-4 TQL-5
C TQL-3 TQL-5 TQL-5
D TQL-4 TQL-5 TQL-5
1
Starting from AMC 20-115D.

AMC 20-170
5.4. Change management

This section deals not only with changes to components that were previously accepted
through a TC, STC or ETSOA, but also with changes during the development as soon as
components are delivered for use in a subsequent stage of the process and a formal
baseline is established for these components.
The main objectives of the change management process are to conduct and document a
change impact analysis and to reintegrate the changed component into the IMA system,
performing all the necessary verification, validation, and integration activities (including
regression analysis and testing).
(a) Since there are various levels of development and integration in an IMA system,
and potentially various stakeholders (the module/platform developer, application
developer, IMA system integrator, aircraft designer), agreements should be
concluded between stakeholders to establish the way to communicate changes
and to perform impact analyses at each level.
(b) A change impact analysis should consider the possible impacts to be reported at
each relevant level:
— changes at the resource allocation level;
— changes at the module/platform level;
— changes at the application level.
(c) Impacts on incremental compliance credit (if applicable) also need to be
considered.
(d) The changes should be documented in the appropriate life cycle data, including the
trace data, configuration indexes and accomplishment summaries.
5.5. Management of problem reports
IMA systems contain multiple applications hosted on the same IMA module/platform,
therefore any OPR related to a module/platform or application, collected at any level,
could affect one or several aircraft functions directly or indirectly.
Considering the diversity of stakeholders in an IMA system, the management of problem
reports can be more complex than with federated systems. In addition to the applicable
guidance on OPR management, for IMA systems, the applicant should organise the
management of OPRs, focusing on:
— the evaluation of the potential effect of each OPR on any shared resources and IMA
services, and the evaluation of those OPRs for impact on any aircraft function that
uses the affected shared resources and IMA services;
— the verification that necessary workarounds, including limitations, at the
application and/or system levels, are documented within the IMA documentation
(e.g. user guide/manual). In such cases, the efficiency of a workaround should be
substantiated and the successful (i.e. complete and correct) deployment of the
workaround should be ensured.
NOTE: In order to facilitate the assessment and the communication between
stakeholders, the use of a harmonised classification scale for OPRs is recommended.
5.6. Environmental qualification

AMC 20-170
The scope of this section is to provide environmental qualification guidance

complementary to ED-124 Chapter 5.2.6 for the environmental qualification of an IMA
system. It can be an IMA platform composed of only one LRU, or various modules in a
given configuration. The platform is qualified in conditions of the same severity as those
expected when installed on the aircraft, interfaced with its peripherals through the
aircraft (or equivalent) harnesses, and loaded with its set of applications. The acceptance
criteria to qualify the platform are driven by the operational requirements of a given
aircraft.
Level of qualification testing activities: The modularity of an IMA platform makes it
possible to conduct qualification testing activities at various stages:
— IMA module testing: the testing is performed on an IMA module, involving the
shared resources (hardware and/or software), and when relevant, with a
representative set of software applications loaded onto the module. In the case of
a cabinet, the module can be a chassis and/or a backplane.
— IMA platform testing: the testing is performed on the platform or cabinet (chassis
and backplane) equipped with its modules, and when relevant, loaded with a
representative set of software applications.
— System testing: the testing is performed on a set of modules and/or the backplane
installed in the cabinet, with system peripherals interfaced with the cabinet, and
with representative software applications loaded onto the modules.
— Aircraft testing: the testing is performed with the systems installed on the aircraft.
The modularity of the IMA platform, combined with the variety of its possible
configurations, leads to the establishment of principles to reuse qualification credit for
IMA modules in the context of qualifying a desired IMA platform for a given aircraft:
(a) The environmental usage domain of an IMA module is the set of environmental
conditions for which it is qualified. This is documented in the module user
guide/manual.
(b) For an IMA module integrated within a cabinet, its environmental qualification
conditions should consider:
— its environmental conditions (i.e. the envelope of thermal, electromagnetic,
vibration, lightning, etc., conditions) encountered inside the cabinet when in
use on the aircraft;
— all its possible arrangements in the cabinet (i.e. different IMA platform
configurations).
Incremental environmental qualification is an approach used in qualifying a cabinet
populated with modules in a known configuration for a given aircraft, relying on
existing qualification credit for IMA modules in their environmental usage domain,
and identifying any complementary qualification substantiation that would be
necessary to cover the envelope of the environmental conditions of the aircraft.
Thus it provides the latitude to populate a cabinet with already qualified modules,
to qualify it without having to perform a full reassessment of the qualification of
each module, and the capability to reuse its existing qualification dossier.
All the substantiation data recorded in the qualification plan should be based on
dedicated tests or on equivalence with the reuse of existing qualification results,
or existing authorisations such as ETSO-2C153. The representativeness of the

AMC 20-170
substantiation should consider the testing configuration, the testing conditions

(including electrical, thermal, mechanical interfaces, etc.), the qualification testing
level, the application software used for the testing, the test scenario and the level
of stress applied.
When an IMA system change is implemented, a change impact analysis should be
conducted against the qualified configuration to assess the complementary
qualification substantiation to be provided for each of its modules.
[Amdt 20/15]

AMC 20-189
AMC 20-189
AMC 20-189 The Management of Open Problem Reports (OPRs)

1. PURPOSE
This AMC describes an acceptable means, but not the only means, for showing compliance with the
applicable airworthiness regulations for the management of open problem reports (OPRs) in ETSO
authorisations and type certification, for the system, software and airborne electronic hardware (AEH)
domains. Compliance with this AMC is not mandatory, and an applicant may elect to use an alternative
means of compliance. However, the alternative means of compliance must meet the relevant
requirements, ensure an equivalent level of safety, and be approved by EASA on a product or ETSO
article basis.
2. APPLICABILITY
This AMC may be used by applicants, design approval holders, and developers of airborne systems
and equipment to be installed on type-certified aircraft, engines, and propellers. This AMC applies to
all airborne electronic systems and equipment, including to the software and AEH components
contained in those systems, which could cause or contribute to Catastrophic, Hazardous, or Major
failure conditions.
3. BACKGROUND
3.1. Each of the system, software and AEH domains relies on problem report (PR) management to
ensure the proper management of open problem reports (OPRs) and to help ensure safe
products at the time of approval. However, the existing guidance on PR and OPR management
is inconsistent and incomplete across domains. Therefore, this AMC provides consistent
guidance across these domains for PR management, OPR management, stakeholder
responsibilities, reporting, and other aspects of OPR management. This AMC complements but
does not alleviate the project-applicable system, software and AEH guidance.
3.2. The technical content of this AMC has been jointly developed with the Federal Aviation
Administration (FAA), in order to harmonise as far as practicable.
4. DEFINITIONS
4.1. Terms defined in this AMC
Approval: the term ‘approval’ in this document addresses the approval by EASA of a product or
of changes to a product, or authorisation of an ETSO article or of changes to an ETSO article.
Article: refer to Article 1(2)(f) of Regulation (EU) No 748/2012 (‘EASA Part 21’).
Development assurance: all of those planned and systematic actions used to substantiate, with
an adequate level of confidence, that errors in requirements, design, and implementation have
been identified and corrected such that the system satisfies the applicable certification basis
(source: ARP4754A/ED-79A).
Equipment: an item or collection of items with a defined set of requirements.
Error: a mistake in the requirements, design, or implementation with the potential of producing
a failure.
Failure: the inability of a system or system component to perform a function within specified
limits (source: DO-178C/ED-12C and DO-254/ED-80).

AMC 20-189
Item: a hardware or software element that has bounded and well-defined interfaces (source:
ARP4754A/ED-79A).
Open problem report (OPR): a problem report that has not reached the state ‘Closed’ at the
time of approval.
Problem report (PR): a means to identify and record the resolution of anomalous behaviour,
process non-compliance with development assurance plans and standards, and deficiencies in
life-cycle data (adapted from DO-178C/ED-12C).
Product: refer to Article 3(3) of Regulation (EU) 2018/1139 (the ‘EASA Basic Regulation’).
System: a combination of interrelated equipment, article(s), and/or items arranged to perform
a specific function (or functions) within a product.
4.2. States of PRs/OPRs
Recorded: a problem that has been documented using the problem-reporting process.
Classified: a problem report that has been categorised in accordance with an established
classification scheme.
Resolved: a problem report that has been corrected or fully mitigated, for which the resolution
of the problem has been verified but not formally reviewed and confirmed.
Closed: a resolved problem report that underwent a formal review and confirmation of the
effective resolution of the problem.
4.3. Classifications of PRs/OPRs
‘Significant’: assessed at the product, system, or equipment level, a PR that has an actual or
potential effect on the product, system, or equipment function that may lead to a Catastrophic,
Hazardous or Major failure condition, or may affect compliance with the operating rules.
‘Functional’: a PR that has an actual or a potential effect on a function at the product, system,
or equipment level.
‘Process’: a PR that records a process non-compliance or deficiency that cannot result in a
potential safety, nor a potential functional, effect.
‘Life-cycle data’: a PR that is linked to a deficiency in a life-cycle data item but not linked to a
process non-compliance or process deficiency.
5. PROBLEM REPORT MANAGEMENT
The PR management process is a key enabler for the management of OPRs. The PR management
process enables the consistent and timely management of problems encountered across the system,
software and AEH domains. Consequently, this process reduces the risk of a loss of visibility of critical
issues remaining at the time of approval.
5.1 A PR management process across the system, software and AEH domains should be established
and used during the development (both for initial certification and subsequent changes) of a
product or an ETSO article. The PR management process should address the review and
resolution of PRs that impact the transition to other development assurance processes.
5.2 A problem recorded after approval should also be managed through the PR management
process, and any related systemic process issues should be identified and corrected.
5.3 PRs that cannot be resolved by the current stakeholder should be reported in a manner that is
understandable to the affected stakeholders.

AMC 20-189
5.4 For PRs that may have an impact on other products or articles that are developed within an
organisation, a means should be established for sharing PR information so that any necessary
corrective actions can be taken.
6. OPR MANAGEMENT
An OPR management process, based on the PR management process, should be established across
the system, software and AEH domains, including the following process steps:
6.1 The classification of OPRs
6.1.1 The applicant should establish an OPR classification scheme including, at a minimum, the
following classifications: ‘Significant’, ‘Functional’, ‘Process’ and ‘Life-cycle data’. Other
classifications or subclassifications may be created as needed. The classification scheme should
be described in the appropriate planning document(s).
6.1.2 Each OPR should be assigned a single classification per the classification scheme. When multiple
classifications apply, the OPR should be assigned the classification with the highest priority. The
priority from highest to lowest (including the defined subclassifications) is:
1. ‘Significant’;
2. ‘Functional’;
3. ‘Process’;
4. ‘Life-cycle data’;
5. any other OPR classification.
Note: The classification of an individual OPR may differ from one stakeholder to another,
depending on the known mitigations at the time of classification.
6.1.3 The classification of an OPR should account for and document all the mitigations known at the
time of classification that are under the control of the classifying stakeholder. A mitigation that
is controlled by another stakeholder may be considered in the classification only if validated
with that stakeholder, and provided this mitigation remains acceptable in the frame of the type
certificate (TC) / supplemental type certificate (STC) approval or European technical standard
order (ETSO) article authorisation, as applicable.
6.1.4 A stakeholder, other than the aircraft TC or STC applicant, should classify as ‘Significant’ any
OPR for which the classification may vary between ‘Functional’ and ‘Significant’, depending on
the installation.
6.2 The assessment of OPRs
Each OPR should be assessed to determine:
1. any resulting functional limitations or operational restrictions at the equipment level (for
ETSOs) or at the product level (for other types of approvals);
2. relationships that may exist with other OPRs; and
3. for a ‘Significant’ or ‘Functional’ OPR, the underlying technical cause of the problem.
6.3 Disposition: OPRs classified as ‘Significant’ per the classification in Section 6.1, for which no
sufficient mitigation or justification exists to substantiate the acceptability of the safety effect,
should be resolved prior to approval. The disposition of OPRs may involve coordination with the
certification authority.

AMC 20-189
6.4 Reporting: an OPR summary report should be prepared and provided to the affected
stakeholder(s), and to the certification authority upon request. The OPR summary report may
be an aggregation of summaries (e.g. Software/Hardware Accomplishment Summaries or
system-level OPR reports) prepared by all the involved stakeholders. The summary report
should provide access to the following information for each OPR:
6.4.1 The identification of the OPR (for example, the OPR ID);
6.4.2 The identification of the affected configuration item(s) (for example, the item part number,
component name, artefact name) or of the affected process(es);
6.4.3 Title or a summary of the problem, formulated in a manner understandable by the affected
stakeholder(s);
6.4.4 Description of the problem, formulated in a manner understandable by the affected
stakeholder(s);
6.4.5 The conditions under which the problem occurs;
6.4.6 The OPR classification and assessment results (per Sections 6.1 and 6.2), including:
1. for each OPR, regardless of its classification:
a. the classification of the OPR, and
b. the relationships that are known to exist with other OPRs;
2. for OPRs classified as ‘Significant’:
a. a description of any mitigations or justifications used to substantiate the
acceptability of the OPR safety effect (per Section 6.3), and
b. the functional limitations and operational restrictions, if any;
3. for OPRs classified as ‘Functional’:
a. a description of any mitigations or justifications used to reduce the safety effect to
Minor or No Safety Effect, and
b. the functional limitations and operational restrictions, if any;
4. for OPRs classified as ‘Process’, a description of the extent or nature of the process non-
compliance or deficiency that might contribute to not satisfying the applicable
development assurance objectives; and
5. for each OPR not classified as ‘Significant’ or ‘Functional’, the justification that the error
cannot have a safety or functional effect.
6.5 ETSO specifics: The ETSO authorisation holder may exclude from the reporting process (per
Section 6.4) any OPRs classified as ‘Process’ or ‘Life-cycle data’ that are not necessary for the
installation approval. However, all OPRs should be available upon request by the certification
authority for assessment in the frame of the ETSO approval.
7. STAKEHOLDER RESPONSIBILITIES
The levels of stakeholders include: item, equipment or ETSO article, system and product. The actual
stakeholders for a specific project depend on the project organisation.
7.1 The levels of stakeholders include: item, equipment or ETSO article, system and product. The
actual stakeholders for a specific project depend on the project organisation.

AMC 20-189
7.2 OPR management (per Section 6) should be performed, at a minimum, at the ETSO article level,
at the level of each individual system within a product, and at the product level.
8. RELATED REGULATORY, ADVISORY AND INDUSTRY MATERIAL
(a) Related EASA Certification Specifications (CSs)
(1) CS-23, Certification Specifications and Acceptable Means of Compliance for Normal
Category Aeroplanes
Aeroplanes
(3) CS-27, Certification Specifications and Acceptable Means of Compliance for Small
Rotorcraft
Rotorcraft
(5) CS-E, Certification Specifications and Acceptable Means of Compliance for Engines, and
AMC 20-3A, Certification of Engines Equipped with Electronic Engine Control Systems
(6) CS-P, Certification Specifications for Propellers, and AMC 20-1, Certification of Aircraft
Propulsion Systems Equipped with Electronic Control Systems
(7) CS-ETSO, Certification Specifications for European Technical Standard Orders
(8) CS-APU, Certification Specifications for Auxiliary Power Units, and AMC 20-2A,
Certification of Essential APU Equipped with Electronic Controls
(b) EASA Acceptable Means of Compliance (AMC)
(1) AMC 20-115( ), Airborne Software Development Assurance Using EUROCAE ED-12 and
RTCA DO-178
(2) AMC 20-152( ), Development Assurance for Airborne Electronic Hardware
(c) FAA ACs
Refer to latest version.
(1) AC 20-115( ), Airborne Software Development Assurance Using EUROCAE ED-12( ) and
RTCA DO-178( )
(2) AC 20-152( ), Development Assurance for Airborne Electronic Hardware
(3) AC 27-1309( ), Equipment, Systems, and Installations (included in AC 27-1, Certification of
Normal Category Rotorcraft)
(4) AC 29-1309( ), Equipment, Systems, and Installations (included in AC 29-2, Certification
of Transport Category Rotorcraft)
(d) Industry Documents
(1) EUROCAE ED-12, Software Considerations in Airborne Systems and Equipment
Certification, dated May 1982 (no longer in print)
(2) EUROCAE ED-12A, Software Considerations in Airborne Systems and Equipment
Certification, dated October 1985 (no longer in print)
(3) EUROCAE ED-12B, Software Considerations in Airborne Systems and Equipment
Certification, dated December 1992

AMC 20-189
(4) EUROCAE ED-12C, Software Considerations in Airborne Systems and Equipment

Certification, dated January 2012
(5) EUROCAE ED-79A, Guidelines for Development of Civil Aircraft and Systems, dated
December 2010
(6) EUROCAE ED-80, Design Assurance Guidance for Airborne Electronic Hardware, dated
April 2000
(7) EUROCAE ED-94C, Supporting Information for ED-12C and ED-109A, dated January 2012
(8) EUROCAE ED-215, Software Tool Qualification Considerations, dated January 2012
(9) EUROCAE ED-216, Formal Methods Supplement to ED-12C and ED-109A, dated January
2012
(10) EUROCAE ED-217, Object-Oriented Technology and Related Techniques Supplement to
ED-12C and ED-109A, dated January 2012
(11) EUROCAE ED-218, Model-Based Development and Verification Supplement to ED-12C and
ED-109A, dated January 2012
(12) RTCA DO-178, Software Considerations in Airborne Systems and Equipment Certification,
dated January 1982 (no longer in print)
(13) RTCA DO-178A, Software Considerations in Airborne Systems and Equipment
Certification, dated March 1985 (no longer in print)
(14) RTCA DO-178B, Software Considerations in Airborne Systems and Equipment
Certification, dated 1 December 1992
(15) RTCA DO-178C, Software Considerations in Airborne Systems and Equipment
Certification, dated 13 December 2011
(16) RTCA DO-248C, Supporting Information for DO-178C and DO-278A, dated 13 December
2011
(17) RTCA DO-254, Design Assurance Guidance for Airborne Electronic Hardware, dated April
19, 2000
(18) RTCA DO-297, Integrated Modular Avionics (IMA) Development Guidance and
Certification Considerations, dated 8 November 2005
(19) RTCA DO-330, Software Tool Qualification Considerations, dated 13 December 2011
(20) RTCA DO-331, Model-Based Development and Verification Supplement to DO-178C and
DO-278A, dated 13 December 2011
(21) RTCA DO-332, Object-Oriented Technology and Related Techniques Supplement to
DO178C and DO-278A, dated 13 December 2011
(22) RTCA DO-333, Formal Methods Supplement to DO-178C and DO-278A, dated 13
December 2011
(23) SAE International Aerospace Recommended Practice (ARP) 4754A, Guidelines for
Development of Civil Aircraft and Systems
9. AVAILABILITY OF DOCUMENTS
(1) EASA Certification Specifications (CSs) and Acceptable Means of Compliance (AMC) may
be downloaded from the EASA website: www.easa.europa.eu

AMC 20-189
(2) FAA Advisory Circulars (ACs) may be downloaded from the FAA website: www.faa.gov
(3) EUROCAE documents may be purchased from:
9-23 rue Paul Lafargue
"Le Triangle" building
93200 Saint-Denis, France
Telephone: +33 1 49 46 19 65
(Email: [email protected], website: www.eurocae.net)
(4) RTCA documents may be purchased from:
RTCA, Inc.1150 18th Street NW, Suite 910, Washington DC 20036, USA
(Email: [email protected], website: www.rtca.org)
10. GUIDANCE MATERIAL
GM 20-189 The Management of Open Problem Reports
GM1 to AMC 20-189 — PR management

Typically, PR processes include the following aspects:

1. PR Recording: a means to document problems resulting from the execution of life-cycle
processes.
2. PR Classification: a means to classify PRs prior to the time of approval of the product or of the
ETSO article, as early in the life cycle as practical. While early classification may be preliminary,
it will help to focus attention on PRs with a potential safety or functional effect, as well as
process PRs that may impact the development or development assurance processes.
3. PR Assessment: a means to assess the effect of having a PR remain open at the time of approval.
The assessment of PRs classified as ‘Significant’, ‘Functional’ or ‘Process’ would typically be
performed by a review board. The assessment of PRs classified as ‘Life-cycle data’ may be
performed within the peer-review process instead of a review board.
4. PR Resolution: a means to correct or mitigate PRs prior to the time of approval, as early in the
life cycle as practical. The PR resolution process may depend on the classification of the PR; for
example, shorter closure loops could be set for PRs classified as ‘Life-cycle data’.
5. PR Closure: a means to close PRs, which includes the review and confirmation of the resolution
of the problem, and indicated through a documented authorisation process (e.g. Change
Control Board sign-off).
GM2 to AMC 20-189 — OPR classification

The following paragraph links the classifications presented in DO-248C/ED-94C, DP #9 to those defined
in AMC 20-189, subparagraph 6.1. This paragraph highlights the clarifications made to the former
scheme (e.g. removing the overlaps between the classifications).

AMC 20-189
1. The most important clarification compared with the former classification scheme is to give each
OPR a single classification using a given order of priority as reflected in AMC 20-189
subparagraph 6.1.2. This promotes visibility of the most relevant issues and helps to prevent
inconsistencies in classification. For example, a missing or incorrect requirement issue can be
classified as ‘Life-cycle data’ only if it is confirmed that it cannot be classified as ‘Significant’,
‘Functional’, or ‘Process’, in that order of priority.
2. Type ‘Significant’: this typically maps to ‘Type 0’. However, some applicants may have used
‘Type 1A’ to characterise some PRs, for instance, those linked to Major failure conditions. The
AMC 20-189 scheme clarifies that those PRs potentially causing or contributing to Catastrophic,
Hazardous or Major failure conditions belong to the class ‘Significant’.
3. Type ‘Functional’: this typically maps to ‘Type 1A’ or ‘Type 1B’, that is, a problem that results in
a failure with a minor or no adverse impact on safety. A PR whose consequences are a failure
that can potentially lead to a Minor failure condition could be mapped to ‘Type 1A’, and a PR
leading to a failure having No Safety Effect could be mapped to ‘Type 1B’. Two separate
subclassifications could therefore be created in the applicant’s classification scheme to ease the
mapping: problems having a functional effect leading to a Minor failure condition could be
classified separately (e.g. ‘Functional 1’) from the ones having No Safety Effect (e.g. ‘Functional
2’). Moreover, an important clarification is that AMC 20-189 does not explicitly consider the
‘operational’ nature of a PR in the classification scheme to avoid creating overlaps, as a PR with
operational consequences could either be classified as ‘Significant’ or ‘Functional’. Creating an
‘Operational’ subclassification within the classification ‘Significant’ or ‘Functional’ is
nevertheless an option available to stakeholders to create a specific emphasis on operational
issues within the proposed classification scheme.
4. Type ‘Process’: this may map to ‘Type 3A’; however, not in cases where the process non-
compliance or deficiency could result in either not detecting a failure or creating a failure. An
important clarification in AMC 20-189 is the removal of the ambiguous notion of ‘significant
deviation from the plans or standards’ used in the definition of ‘Type 3A’. The ‘Process’
classification in AMC 20-189 should be used for PRs that record a process non-compliance or
deficiency, provided they cannot result in a potential safety or potential functional effect. An
example of an OPR that should not be classified as a ‘Process’ PR is one related to a requirement
that was not completely verified due to a process deficiency, because the potential safety or
functional impact remains undetermined. Considering the highest priority classification would,
in such a case, lead to a ‘Significant’ or ‘Functional’ classification, thus putting even more
emphasis on the need to resolve the shortcoming in the verification activities.
5. Type ‘Life-cycle data’: this typically maps to ‘Type 2’ or ‘Type 3B’. Since ‘Life-cycle data’ OPRs
may range widely, subclassifications may be proposed by stakeholders to distinguish the
different types of OPRs. Examples of OPRs classified as ‘Life-cycle data’ may range from issues
in a component having no potential safety or functional impact to PRs on pure documentary
issues. Moreover, the removal of the notion of ‘non-significant deviation from the plans or
standards’ from the definition of ‘Type 3B’ helps to remove the ambiguity and overlap between
the ‘Process’ and ‘Life-cycle data’ classifications.
6. Other OPR classification: additional classifications of OPRs may be created to cover ‘Type 4’ or
any other classification not specified in AMC 20-189, paragraph 6.1.1.

AMC 20-189
GM3 to AMC 20-189 — Additional GM related to the ‘Significant’

classification
In the frame of an engine or propeller TC/STC or of an ETSO article authorisation, the definition of
‘Significant’ is based on the anticipation of a potential effect on the product, system, or equipment
function that could lead to a Catastrophic, Hazardous or Major failure condition. The goal is to identify
and enhance the visibility of OPRs that may pose potential safety risks at the aircraft installation level
(see AMC 20-189 paragraph 6.1.4).
For example, in the case of an engine TC, a partial or complete loss of thrust or power is regarded as
a Minor Engine Effect, whereas it may have a more severe effect at the aircraft level. Unless the engine
manufacturer can confirm that the effect at the installation level is no more than Minor, the OPR
would be classified as ‘Significant’. The associated assumptions or mitigations are usually recorded
through instructions for installing and operating the engine, e.g. in an engine installation manual.
In the case of an ETSO authorisation, classification of the failure condition is either based on
assumptions defined by the applicant, or mandated through the ETSO standard, and is the basis of the
safety analysis at the ETSO article level. An OPR is classified as ‘Significant’ when the OPR may lead to
a functional failure associated with a Catastrophic, Hazardous or Major failure condition.
[Amdt 20/19]

Easy Access Rules for Acceptable Means of SUBPART B — LIST OF AMC-20 ITEMS
AMC 20-189
SUBPART B — LIST OF AMC-20 ITEMS

INDEX 1
EASA AMC-20 Title Last amended by
reference
AMC 20-1A The Certification of Aircraft Propulsion Systems Equipped AMC-20 Amdt 19
with Electronic Controls
AMC 20-2B The Certification of Essential APUs Equipped with Electronic AMC-20 Amdt 19
Controls
AMC 20-3B The Certification of Engines Equipped with Electronic Engine AMC-20 Amdt 19
Control Systems
AMC 20-4A Airworthiness Approval and Operational Criteria For the Use Cancelled
of Navigation Systems in European Airspace Designated For (By AMC-20 Amdt 17)
Basic RNAV Operations
AMC 20-5 Airworthiness Approval and Operational Criteria for the use Cancelled
of the Navstar Global Positioning System (GPS) (By AMC-20 Amdt 17)
AMC 20-6 rev 2 Extended Range Operation with Two-Engine Aeroplanes AMC-20 Amdt 7
ETOPS Certification and Operation
AMC 20-8A Occurrence Reporting AMC-20 Amdt 19
AMC 20-9 Acceptable Means of Compliance for the Approval of AMC-20 Amdt 1
Departure Clearance via Data Communications over ACARS.
AMC 20-10 Acceptable Means of Compliance for the Approval of Digital AMC-20 Amdt 1
ATIS via Data Link over ACARS.
AMC 20-11 Acceptable Means of Compliance for the Approval of use of Cancelled
Initial Services for Air Ground Data Link in Continental (by AMC-20 Amdt 11)
Airspace
AMC 20-12 Recognition of FAA Order 8400.12a for RNP 10 Operations Cancelled
(By AMC-20 Amdt 17)
AMC 20-13 Certification of Mode S Transponder Systems for Enhanced Cancelled

Surveillance (by AMC-20 Amdt 11)
AMC 20-15 AMC 20-15 Airworthiness Certification Considerations for the AMC 20 Amdt 8
Airborne Collision Avoidance System (ACAS II) with optional
Hybrid Surveillance
AMC 20-19 In-Flight Entertainment AMC-20 Amdt 19
AMC 20-20 Continuing Structural Integrity Programme AMC-20 Amdt 3
AMC 20-21 Programme to enhance aeroplane Electrical Wiring AMC- 20 Amdt 4

Interconnection System maintenance
AMC 20-22 Aeroplane Electrical Wiring Interconnection System Training AMC- 20 Amdt 4
Programme

Easy Access Rules for Acceptable Means of SUBPART B — LIST OF AMC-20 ITEMS
AMC 20-189
AMC 20-23 Development of Electrical Standard Wiring Practices AMC- 20 Amdt 4

documentation
AMC 20-24 Certification Considerations for the Enhanced ATS in AMC-20 Amdt 3
NonRadar Areas using ADS-B Surveillance (ADS-B-NRA)
Application via 1090 MHZ Extended Squitter
AMC 20-25A Airworthiness consideration for Electronic Flight Bags (EFBs) AMC-20 Amdt 16
AMC 20-26 Airworthiness Approval and Operational Criteria for RNP Cancelled
Authorisation Required (RNP AR) Operations (By AMC-20 Amdt 17)
AMC 20-27A Airworthiness Approval and Operational Criteria for RNP Cancelled
APPROACH (RNP APCH) Operations Including APV (By AMC-20 Amdt 17)
BAROVNAV Operations
AMC 20-28 Airworthiness Approval and Operational Criteria related to Cancelled

Area Navigation for Global Navigation Satellite System (By AMC-20 Amdt 17)
approach operation to Localiser Performance with Vertical
guidance minima using Satellite Based Augmentation System
AMC 20-29 Composite Aircraft Structure AMC-20 Amdt 6
AMC 20-42 Airworthiness information security risk assessment AMC-20 Amdt 18
AMC 20-115D Software considerations for certification of airborne systems AMC-20 Amdt 14
and equipment
AMC 20-128A Design Considerations for Minimizing Hazards Caused by AMC-20 Initial issue
Uncontained Turbine Engine and Auxiliary Power Unit Rotor
Failure
AMC 20-136 Aircraft electrical and electronic system lightning protection AMC-20 Amdt 13
AMC 20-152A Airborne Electronic Hardware AMC-20 Amdt 19
AMC 20-158 Aircraft electrical and electronic system high-intensity AMC-20 Amdt 13
radiated fields (HIRF) protection
AMC 20-170 IMA AMC-20 Amdt 15
AMC 20-189 The Management of Open Problem Reports AMC-20 Amdt 19
[Amdt 20/19]

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Easy Access Rules for Acceptable Means of

Compliance for Airworthiness of Products,

EASA eRules: aviation rules for the 21st century

Published March 20211

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NOTE FROM THE EDITOR

Acceptable means of compliance

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Appendix 2 to AMC 20-9 Common Terms ...............................................................................138

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AMC 20-158 ......................................................................................................................... 526

SUBPART B — LIST OF AMC-20 ITEMS ............................................. 589

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AMC 20-1A Certification of Aircraft Propulsion Systems Equipped with

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SUBSTANTIATION SUBSTANTIATION UNDER CS-25

AIRCRAFT DATA — Protection of Engine — Aircraft data reliability

THRUST REVERSER — Software/AEH — System reliability — Safety objectives

CONTROL SYSTEM — Reliability or quality — Reliability of quality of

ENVIRONMENTAL — Equipment — Declared capability — Aircraft design

LIGHTNING AND — Equipment — Declared capability — Aircraft wiring

FIRE PROTECTION — Equipment — Declared capability — Aircraft design

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AMC 20-2B Certification of Essential Auxiliary Power Units (APUs)

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4.4.3 Lightning and other electromagnetic effects

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— an APU shutdown in flight;

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Appendix to AMC 20-2B

— Independence of — Monitoring — Indication system

— Protection of APU — Aircraft data

ENVIRONMENTAL — Equipment protection — Declared capability — Aircraft design

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AMC 20-3B Certification of Engines Equipped with Electronic Engine

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The following documents are referenced in AMC 20-3B:

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ENGINE CONTROL SYSTEM

May be one or more ALTERNATE MODES

Lanes typically have

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flame-out or unmanageable delay in power recovery. For example, in a twin-engine

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