PHOTOVOLTAIC MODULES CASE STUDY

When photovoltaic modules (PV modules) were added to the Sustainable Electronics Reuse and Recycling (R2) Standard, SERI didn’t just add text concerning the reuse and recycling of solar panels. The ANSI-accredited standards developer also successfully demonstrated the adaptability of R2v3, which is structured to allow the addition of new materials or processes without causing undue disruption to the certified industry.  

Coming into effect in mid-2020, R2v3 represented a wholesale rethinking of the R2 Standard. The update to R2:2013 was uniquely restructured with a set of Core Requirements that apply to all certified facilities, while separating Process Requirements, which ensured R2 is ideally suited to various business models in a constantly changing industry. The structure, with process- and material-specific requirements separated into different appendices, also allows new materials such as solar panels to be added to R2 without forcing changes on facilities that aren’t handling them.  

In that way, the early 2024 addition of Appendix G-Photovoltaic Modules represented the first successful test of R2v3’s adaptable structure.  

At the same time, the creation of Appendix G to add solar panels, formally known as photovoltaic modules, followed the same type of multi-stakeholder, consensus–based development process that R2v3, itself, did. Much of the heavy lifting was done by the PV drafting workgroup, which was a subset of the R2 Technical Advisory Committee (R2 TAC), a group of dedicated volunteers. They were supported in their work by the standards management team at SERI, which is audited by ANSI (American National Standards Institute) to ensure the process meets the ANSI Essential Requirements for standards development.

As a result of SERI’s standard-development process, Appendix G was developed through a balanced and consensus–driven process by a diverse group of stakeholders. The development process followed allows the standard to be differentiated from other standards that are written with one interest in mind or are narrowly crafted in private to strictly drive sales by a small group of similar stakeholders. 

Appendix G reflects differing perspectives from the varied group of experts who put hundreds of hours into crafting it.  

“Really, everybody had a voice. Everyone that was a part of it contributed in a valuable way, so it didn’t feel like one group had a lot more input than another,” said Tommy McGuire, a member of PV drafting workgroup and president of electronics and solar panel recycling company Echo Environmental. 

He and several other stakeholders shared their thoughts on the process of developing Appendix G, shining additional light on the collaboration and knowledge-sharing that went into creating the informed requirements.   

FINDING THE RIGHT TIME FOR THE RIGHT SOLUTION

When SERI first initiated the R2 TAC in early 2016 to draft a comprehensive update to replace R2:2013, the TAC decided against including solar panels in its work. The R2 TAC recognized that addressing PV modules would require different types of stakeholders who weren’t already on the R2 TAC. Recognizing that challenge and the multitude of other topics that were slated to be addressed with the update, the group decided PV modules weren’t critical to that revision of the standard at that time and could be addressed after the wholesale update was finalized.  

Creating R2v3 ultimately took nearly five years and roughly 5,000 individual volunteer hours. Not long after R2v3 went into effect on July 1, 2020, work on adding PV modules kicked off. In fall 2020, a group of experts, including PV customers, recyclers and others, worked with then-R2 Director Sean De Vries to conduct an exploratory committee to explore adding PV modules to R2.  

Jody Erikson, SERI’s R2 TAC Facilitator who facilitated that exploratory committee and the later PV drafting workgroup, recalled the exploratory committee examined whether PV modules should have their own standard or whether they’d logically fit into the R2 Standard – and, if so, how much work would be needed. They ultimately recommended that SERI incorporate PV modules into R2, to which over 900 facilities around the world were already certified. 

The prevalence of R2 certifications meant that adding PV modules to R2 would ease the way for the materials to be processed by existing electronics reuse and recycling facilities around the world.  

On May 19, 2021, presented with the recommendation, R2 TAC formally voted to add PV modules to the R2 Standard. At the time, the TAC included Mike Easterbrook, who later became SERI’s R2 Director and provided staff support drafting Appendix G.   

Not only would the addition of Appendix G be the first update to R2v3, but it would be the first time a specific material was covered by an appendix. The prior appendices focused on specific processes, including sending materials downstream, data sanitization, test and repair, materials recovery, and brokering, as opposed to a distinct type of product like solar panels.   

As an ANSI-accredited standards developer, SERI took the first step of issuing a formal notification through ANSI of the standards development activity and seeking to recruit experts from the PV industry to serve on the R2 TAC. Following a review of applications, nine new members joined the R2 TAC in October 2021, three from each of the R2 TAC’s multistakeholder categories. 

TAC DIVERSITY BY DESIGN

After the PV industry experts joined the R2 TAC, the R2 TAC formed a drafting workgroup, which was made up of the nine new R2 TAC members from the PV industry and 10 existing R2 TAC members. The 19-person group officially kicked off in January 2022. The composition, a blend of professionals with PV industry experience and those with prior R2 knowledge, was intentional.  

Garvin Heath, principal environmental engineer at the National Renewable Energy Laboratory (NREL) and a member of the PV drafting workgroup, appreciated that the working group included both people with PV industry expertise and people who know about standards development and R2.

“It seemed like the design and structure of that worked out pretty well,” said Heath, who has also been involved in a standard-development process for the Electronic Product Environmental Assessment Tool (EPEAT).  

He added that having a working group draft the text but with the understanding that it wasn’t the final decision–maker also presented a sort of check and balance on the process.  

Another TAC and drafting workgroup member, Evelyn Butler of the Solar Energy Industries Association (SEIA), agreed that it was important for the drafting workgroup to have TAC members already familiar with R2 so they could explain how the existing standard already addresses topics under discussion.  

“We don’t want to rehash or recreate the wheel on topics where there’s alignment,” Butler said.  

The R2 TAC, itself, is also made up of representatives from different segments of the industry. Specifically, the R2 TAC has members drawn from the following three areas: electronics reuse and recycling facilities; OEMs, retailers and their representative groups; and various regulatory and public interest stakeholders, including state and federal agencies, consultants, certification bodies, standards developers, and others.  

Heath likes the requirements, laid out by ANSI, to bring different stakeholder groups to the standard-development table.  

“This requirement, of having a diverse set of stakeholders, is I think a really valuable one,” Heath said.  

The TAC doesn’t just include representatives from diverse organizations; it also includes people from diverse geographies around the world. As a result, SERI held TAC meetings at two different times, allowing representatives from the Americas, Europe and Africa to join one meeting at a convenient time and representatives from Asia and Australia to join the other at a convenient time.  

“This requirement, of having a diverse set of stakeholders, is I think a really valuable one.“

– Garvin Heath, principal environmental engineer at the National Renewable Energy Laboratory (NREL) and a member of the PV drafting workgroup

DIFFERENT PERSPECTIVES COME INTO PLAY

For McGuire of Echo Environmental, Appendix G development was his first experience with a standards-development process.  

He emphasized the value of including recyclers’ voices to describe how the standard requirements would apply in practice to activities at a processing facility.  

“There aren’t that many companies that [reuse and recycle solar panels], so to be able to put my voice in there from the actual feet–on–the–ground, hands–on–the-product side of it I thought was really important,” McGuire said.  

Another recycler voice came from Dwight Clark, who works at solar panel reuse and recycling company We Recycle Solar and who served on the PV drafting workgroup. Clark felt his input was particularly important to informing language around required testing for reusable panels. Input from perspectives such as his was important to ensuring the testing requirements were “as realistic as possible” and don’t preclude all PV module resale.  

Solar panel manufacturing representatives on the PV drafting workgroup also helped bring knowledge crucial to the discussions, particularly when it came to explaining the variety of solar panels on the market and their materials composition. Butler of SEIA recalled that, early on, she helped educate the rest of the R2 TAC about different solar modules, what they’re made of, and how they’re similar to and different from electronics covered by R2.  

Before joining the solar energy industry association eight years ago, Butler worked for over 20 years at UL Solutions, an ANSI-accredited standards developer. In 2023, she worked to get SEIA accredited by ANSI as a standards developer. She said she is very familiar with and has a “very healthy respect” for the ANSI standards development process. 

“I think that, in general, when it comes to vetting those kinds of requirements, having different affected voices at the table – having their say at the beginning – is so much more productive than waiting for people to receive the requirements and then realize that it may drastically change their business model,” Butler said.  

Heath of NREL echoed that sentiment, noting that the “ultimate uptake of success” of a standard is involving different perspectives and answering their questions as much in advance as possible.  

SERIOUS CONSIDERATION OF PUBLIC COMMENTS

ANSI lays out defined steps that must be followed, but each standards developer still “has their own spin” and works a little differently, Butler noted. She appreciated the support provided to the working group by the SERI standards management team.

Heath agreed. It would have been difficult for a group of strangers to start with a blank piece of paper, he noted. Having staff provide text that the group could revise and rework was helpful and reduced the burden on the volunteers.  

Substantial SERI staff and R2 TAC effort was dedicated to Appendix G’s public comment processes. ANSI requires accredited standards developers to provide draft text to the public, and then the TAC must consider and respond to each public comment. SERI went a step beyond ANSI requirements by directing that the comments and responses be disclosed to the public for transparency, in addition to meeting ANSI requirements for providing responses to each commenter.  

For Appendix G, SERI accepted a first round of public comments from April 28 to June 12, 2023. SERI received 15 comments, which the R2 TAC discussed in June, July and August 2023.  

After careful consideration, the R2 TAC converted three of those comments into changes in the draft language. Because those changes were considered substantial, another round of public comments was initiated to gather feedback focused on those changes. A second 45-day public comment period took place from Oct. 6, 2023, to Nov. 20, 2023.  

The R2 TAC considered the second round of comments and made a couple of non-substantive changes in December 2023 and January 2024 for clarity, but no further substantial changes were warranted. 

In the end, the R2 TAC unanimously voted on Jan. 17, 2024, to add PV modules to the R2 Standard. That came after the PV drafting workgroup spent nearly 400 individual volunteer hours drafting Appendix G and the full R2 TAC spent at least 400 additional volunteer hours reviewing the work and public comments.  

The SERI Board of Directors on January 25, 2024, voted to approve the addition of PV modules. Shortly thereafter, ANSI approved the inclusion.  

CONSENSUS MEANS ‘IT’S WORKABLE’

The R2 TAC reached a consensus vote to approve Appendix G, but that doesn’t mean every member loves every word of it.  

“Consensus doesn’t necessarily mean everybody is happy, but everybody can live with what’s decided,” Butler said. “It’s just that it’s workable; that’s the important thing.”

In McGuire’s opinion, nothing proposed for Appendix G compromised the overall integrity of the standard or the abilities of the recyclers to achieve it.  

“Consensus doesn’t necessarily mean everybody is happy, but everybody can live with what’s decided. It’s just that it’s workable; that’s the important thing.”

– Evelyn Butler of the Solar Energy Industries Association

“It didn’t feel like we were different industries. It felt like we were all a part of this thing trying to achieve a meaningful goal,” he said. “Being a part of that group, you could just tell everybody in there really wanted what was best for the industry and really cares about what they do and their impact within their segment of the industry.”  

Ultimately, Clark of We Recycle Solar pointed out that assembling the right team is the most important factor in developing a standard.  

“It doesn’t matter what you’re adding. You could be adding widgets. It doesn’t matter,” Clark said. “It’s all about getting the right team. It’s about getting the right people at the table and coming to consensus.” 

In the end, the addition of Appendix G demonstrates that the framework design of R2v3 worked as intended. R2v3’s structure allowed for expansion of the R2 Standard to meet the needs of a changing world without revising the entire standard. The additions were able to limit the impact only to facilities handling solar panels and avoid requiring every R2-certified facility to get re-certified. Appendix G and the process it followed proved a flexible model for agile standards development to meet a growing and continuously changing industry.  

TIMELINE

A timeline of Appendix G development

July 2020: R2v3 goes into effect.

Fall 2020: PV module exploratory committee formed.

May 2021: R2 TAC votes to formally initiate process of adding PV modules.

October 2021: PV module experts join R2 TAC.

January 2022: Drafting workgroup kicks off.

April-June 2023: Draft changes published, first round of public comments accepted.

October-November 2023: Proposed draft changes published, second round of public comments held.

January 2024: R2 TAC votes to approve minor changes to draft, approves adding PV modules. SERI Board votes to add PV modules to R2. ANSI approves additions to standard.