Q: Could you describe the requirement that facilities develop and maintain a documented process to protect PV modules from conducting electricity? 

A: When reading Appendix G(5), which concerns electrical safety, it’s important to recognize the explicit requirement that the facility develop and maintain a documented process. This means that an R2 Facility cannot rely on verbal communication alone, and it must have written documentation clearly describing the steps employees must take when transporting, handling, storing and processing PV modules to protect against electrical hazards. The facility must also maintain that documentation – keeping it updated and relevant to current processes – and make it available to certification auditors. 

The documented process may address myriad concerns, such as where the modules may be stored (exposed to the sun or under cover), the equipment to be used moving and processing them (forklifts or manual carrying), the personal protective equipment employees must wear (specific types of gloves or other PPE), and more. It’s important to recognize that PV modules are sometimes taken offline because of damage, including from extreme weather. Additionally, the panels or inverter boxes may be damaged during the decommissioning or shipping process. As a result, when they conduct their risk assessment, facilities should consider the hazards presented by damaged solar panels, addressing different types of damage and conditions that trigger unique protocols for transportation, handling, storage and processing. Be cognizant of the fact that safety protocols are likely to be different depending on the types of damage, whether it’s cracked glass, a broken back sheet that potentially exposes interconnections, a damaged junction box and/or exposed writing, or a damaged inverter. As facilities assess these risks, they may also want to consider the different levels of risk introduced by exposure to DC or AC current, the latter of which is often considered more hazardous.  

It’s also important to keep in mind that the documented process needs to cover the R2 Facility’s handling of the PV modules from the moment the facility takes control of the panels, which could be before they physically arrive at a recycling or reuse facility. That means that if an R2 Facility has been hired to decommission a solar array, then the facility’s documented process must address the process employed to prevent the panels from conducting electricity in the field, where the electrical safety risk is likely going to be higher because multiple panels are wired together under direct natural light.  

A key to the documentation is that it will likely reflect the unique circumstances and hazards at each individual R2 Certified Facility. For example, the documented processes will likely look different for a facility focused on testing and reselling functional PV modules taken offline because they aren’t as productive as newer models than it will for a facility focused on recovering materials from damaged panels.  

In developing the documented process, facilities might benefit from connecting some of the results from the hazards assessment they are required to perform under Appendix G(3). That requirement states that R2 Facilities shall periodically conduct an assessment of electrical safety risks that exist or could reasonably be associated with handling and processing PV modules. Further, they must implement controls identified through the assessment (see Appendix G Certification Q&A Part 3 for a fuller explanation of these requirements). The electrical hazards assessment and its periodic updates will likely be helpful to informing the drafting and maintenance of the facility’s Appendix G(5) documented process.