[en] The application of Miner's rule using a loading issued from a mock-up of a RHR (removal heat system) of PWR plant, made of 304 steel gives a very important non-conservative fatigue lifetime in strain control when strain fatigue curve is used. A large number of test in strain and stress control are performed in different laboratories. Two modeling of literature Smith-Watson-Topper (SWT) and Fatemi-Socie (FS) have been used to simulate these tests. Much better responses than Miner's rule are obtained. However these models need an elastic-plastic constitutive law which is difficult to propose in the presence of high cycle secondary hardening observed in austenitic stainless steels. So a conservative model for fatigue damage accumulation under variable amplitude loading is proposed for austenitic stainless steels (AISI 304, 316) in strain control, which does not need a constitutive law. Linear damage accumulation is used, while, sequence effect is taken into account using the elastic-plastic memory effect through cyclic strain stress curves with pre-hardening. This modeling is based on the fact that for stainless steels, pre-hardening is detrimental for fatigue life in strain control while it is beneficial in stress control. In the case of materials that do not demonstrate load sequence memory the modeling is identical to Miner rule. In the presence of low mean stress, the modeling is approved based on a large number of tests. Moreover the modeling permits to explain the larger detrimental effect of a tension mean stress in strain control tests than in stress control tests. To extend the modeling to higher values of mean stress it is proposed to divide mean stress effect into maximal and 'real' mean stress effects. Extending this work to the case of significant mean stress is ongoing. (authors)