If you are expert in damage tolerance, may I take the liberty to ask you what do you think of the following paper?   I proved that, neglecting interaction effects between with load cycles, which are anyway very material dependence and very hard to model (indeed, even the code NASGRO suggests to avoid considering them unless you are extremely expert, in the spirit of being conservative), then integration of Paris' law is equivalent to use of Pamgren-Miner law.

 Hence the very developed area of spectral methods using  Pamgren-Miner law (mainly in metals), could be generalized to damage tolerance calculations.  I know this is mainly for metals, but who   could be interested to discuss this in the relevant agencies/industies?

Ciavarella, M., D'antuono, P., & Papangelo, A. (2018). On the connection between Palmgren‐Miner rule and crack propagation laws. Fatigue & Fracture of Engineering Materials & Structures.

Thanks in advance

prof. Michele Ciavarella

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