Some states, like California, have considered adopting regulations that supersede federal standards, and add broken or end-of-life PV modules to the broad category of potentially toxic or hazardous products commonly known as e-waste. California’s hazardous waste criteria and leaching tests are more stringent than the federal criteria. If the state’s new regulations are implemented, certain modules that are excluded from classification as hazardous waste under federal rules could be regulated as a hazardous waste in California.
Although the chemicals in PV modules do not pose any threat during the modules’ operational life, modules disposed of in a landfill or burned in an incinerator could release toxins into the groundwater or air. For example, some thin-film technology—mainly used in large commercial installations—contains cadmium, a carcinogen that may pose a serious health risk if ingested or inhaled. The metal is considered highly toxic by the U.S. Environmental Protection Agency and Occupational Safety and Health Administration, and is banned by the European Union’s Restriction on Hazardous Substances directive, though the policy allows an exemption for its use in solar modules.
“The U.S. industry as a whole is not doing enough to ensure safe handling of current end-of-life modules,” says Dr. Vasilis Fthenakis, senior scientist at Brookhaven National Laboratory and the director of the Center for Life Cycle Analysis at Columbia University. “We need an industry-wide recycling program liked the one in Europe.”
The Solar Energy Industries Association is pushing a voluntary environmental responsibility pledge. So far, only seven of the 81 members have signed. The association also has established an internal task force to develop a program model that can be adopted at the state level. The association has been collaborating with European industry associations, as well as European take-back and recycling programs, in hopes of learning the best practices—and missteps to avoid.
Additionally, SEIA is participating in discussions conducted by the International Energy Agency’s Photovoltaic Power Systems Programme, an international framework for safety, health, and life-cycle practices for the PV industry.
“One potential problem that needs to be addressed is whether it should be the installer, the manufacturer, the distributor, the developer, or the end user who is responsible for recycling the module,” says Thomas Young, vice president of investor relations for Trina Solar. “Then there’s the issue of jurisdiction. What if the module is shipped from the United States to a distributor in Spain, who then sells it to a developer somewhere in Africa? Do we follow the recycling regulations in the country of origin or the country where it is ultimately installed? And how do we track that? We can only hope that the laws will be unified, but if not, there could be potential conflicts.”
“There is demand for end-of-life solar panel recycling now, and our growing business is proof,” says Jennifer Woolwich, founder of PV Recycling in Tempe, Arizona. Several big-name waste management companies are rumored to be experimenting with PV recycling, but none have entered the market yet. For now, PV Recycling is the only independent recycler of PV products in the United States.
Founded in 2009, the company got its start serving small- to medium-sized installers with broken or end-of-life modules on hand, but now its core business has shifted to include several large installers and manufacturers, including SolarWorld and Trina Solar.
“The decision-makers at the larger companies have been slow to decide whether to recycle these products in-house or send them elsewhere, but I’m now fielding more and more calls from big companies that are beginning to feel a sense of urgency,” Woolwich says.