Q: What does the hazards risk identification and assessment in Appendix G(3) entail? Is this different than the risk assessment required in Core 3?

A: The risk assessment required in Appendix G is a separate requirement from the risks and hazards identification and assessment required by Core 3, and specifically addresses hazards that might be unique to PV modules, including electrical safety risks.   

Some of the health and safety requirements emphasized in Appendix G include the following: 

• Periodic hazards identification related to the handling and processing of PV modules. In addition to the broad hazards identification and control requirements that are included in G(3) and Core 3, Appendix G(3) emphasizes evaluating electrical safety risks that exist or could reasonably be associated with the handling and processing PV modules. These risks may be unique to PV modules, which lack an “off” switch to stop them from producing at least some amount of electricity anytime they’re exposed to light.  

• Implement safety controls to mitigate identified electrical safety risks.  

In practice, Appendix G(3) could prompt a facility to identify and assess a number of health and safety threats presented by PV modules. First, electrical safety is explicitly mentioned in Appendix G(3). Electrical safety is a particular concern because PV modules awaiting processing are often unloaded, stored and loaded outside, rather than in a warehouse, owing to their large size and the space they require for storage. While outside, however, natural sunlight will allow the solar cells to produce far more electricity than standard artificial light or diffused natural light under a roof (in the latter cases, PV modules are still capable of generating a smaller amount of electricity). In the course of handling the panels, workers may be exposed to electrical shock risk from exposed wires, which may be a product of the decommissioning process or could reflect an older panel design that lacked standardized connectors and required manual splicing for installation. The worker could be shocked by touching the wire itself or from the wire contacting a metal surface.  

Another electrical safety risk may stem from defective or damaged panels. Damage can be caused in the field by severe weather, such as large hail, in handling, such as by collecting panels in roll-off containers or stacking them too high, or in transport, such as by PV modules shifting during transport. Regardless of the cause, if severe enough, PV module damage could result in electrical arcs, presenting a risk to employees.  

Electrical risk may also stem from other electrical equipment connected to PV modules, such as inverters, which convert direct current (DC) produced by the panels to alternating current (AC). Microinverters, a type of inverter that can be attached to each individual module, may regularly enter facilities and could present an electrical hazard, particularly if damaged. G(3) requires that safety controls be implemented addressing all identified electrical safety risks.  

When conducting the hazards identification, R2 Facilities may also want to consider and analyze a number of other potential dangers to employees. Beyond electrical safety risks, Core 3 requires identifying, analyzing and demonstrating effective controls of any health and safety risks (and important environmental impacts, for that matter) that a facility can control or influence.  Appendix G(3) also requires a periodic identification and assessment of the risks and hazards that could be associated with the handling and processing of PV modules. 

A common risk for workers is cuts. PV modules often enter recycling facilities with broken glass, the shards of which have sharp edges. Bent aluminum frames tend to present sharp edges, as well. Contractors decommissioning panels may cut them off their mounts, leaving sharp edges that can threaten workers.  

There is also the risk of burns from modules, which can get extremely hot to the touch while stored out in the sunlight. Additionally, PV modules are bulky and heavy compared with many other types of electronics, with individual panel weights ranging from 40 pounds (18 kilograms) to 80 pounds (36 kilograms) or more. As a result, they both present the risk of injury to workers attempting to move them manually and a crushing hazard if stacked too high or carried on broken pallets.  Facilities should consider whether controls like co-lifting the panel with another worker or height stacking limitations are appropriate.   

Finally, because PV modules are used outside in various outdoor environments, they may enter recycling facilities with biological hazards, including bacteria-laden water leaking from broken panels, animal feces, or even the presence of poisonous animals.  

Again, Core 3 requires R2 Facilities to identify and implement controls for all these aforementioned hazards, with Appendix G(3) specifically highlighting the need to consider electrical safety risks unique to PV modules. It should also be acknowledged that PV module reuse and recycling facilities may be ill-equipped to mitigate some of the hazards stated above, such as biological hazards. To address such situations, Core 3 also requires the facilities to maintain a process to visually inspect PV modules for such hazards and implement controls for the containment, segregation and special handling of them.   

As stated above, Appendix G(3) requires the identification, assessment and controls for hazards unique to PV modules, while Core 3 requires R2 Facilities to do the same for all environmental, health and safety risks. Both Core 3 and Appendix G hazards identification and mitigation requirements are more specific to electronic equipment and PV modules than the applicable hazards identification process requirements found in the EHSMS standards required by the R2 Standard in Core 3. 

In practice, the controls could include a variety of measures, some of which mitigate multiple hazards simultaneously. For example, a facility may require workers to wear cut-resistant sleeves to prevent cut injuries, thick rubber gloves to prevent cuts and reduce electrical shock risks, safety glasses to prevent eye injuries, masks or respirators to prevent inhalation of glass particles produced during aluminum frame removal or later automated materials recovery processing, and steel-toed boots to prevent injury from falling solar panels. Additionally, a facility might clean surfaces, including inside shredders or other processing equipment, with a vacuum system rather than brooms, which may kick up more potentially hazardous dust. The facility could restrict pallet stacking heights to avoid unstable loads of heavy solar panels and prevent crushing and glass breakage for panels at the bottom.  

And keep in mind the mitigation measures are required anytime an R2 Facility takes control of PV modules, and that can occur well before panels arrive at a recycling or reuse facility. That means that if an R2 Facility is hired to decommission a solar array in the field, hazards identification, analysis and mitigation is required for those field decommissioning activities, as well.  

Because of the related objectives of the Core 3 and G(3) requirements, the periodic hazards identification and mitigation exercise conducted under G(3) could be documented as part of the R2 Facility’s health and safety hazards assessment required under Core 3. That Core 3 assessment is part of the facility’s environmental, health, and safety management system. In essence, there’s no requirement that facilities document their G(3) and Core 3 health and safety assessments in different places; in fact, for the purposes of efficiency of administration and auditing, it may make sense to document them in one place.