O&M Safety Guide for Handling End-of-Life Solar Panels
Electricity demand is surging in the U.S., and it’s all driven by big growth relying on electrification, artificial intelligence, which requires new data centers, and let’s not forget the resurgence in industrial reshoring and manufacturing. All great news, and that means all the connected industries like energy supply are also surging. Solar power is a major part of the energy mix. For the U.S. to stay competitive, we will need to ensure all these projects are incorporating the material end-of-life handling and management safety, efficiently, and economically from the beginning of the project’s life. As it stands, operations and maintenance (O&M) services are in great demand as they haven’t quite caught up to the rapid development of large-scale sites.
Usually, we look at waste management as a line item for trash bins when the project is being built and decommissioned, but what about the new responsibilities in managing the removal, handling, and recycling of end-of-life (EOL) solar panels our O&M teams face? If mishandled, these panels can pose electrical, chemical, and environmental risks. This guide outlines best practices for safely managing EOL modules in the field, emphasizing worker safety, regulatory compliance, and environmental protection. It is based on industry guidance from the National Renewable Energy Laboratory (NREL), Solar Landscape’s Environmental Health and Safety (EH&S) policy, and the American Clean Power Association’s (ACP) Qualified Electrical Worker (QEW) Guidelines.
References:
NREL O&M Best Practices Guide (2019)
Solar Landscape EH&S Policy (2024)
ACP Solar PV QEW Guidelines (2023)
2025 Power and Utilities Industry Outlook
Regulatory compliance: know what applies before you move a single solar panel
O&M teams must navigate a layered regulatory landscape when handling end-of-life solar panels. At the federal level, the Resource Conservation and Recovery Act (RCRA) governs whether solar panels meet the criteria for hazardous waste, particularly modules containing lead, cadmium, or selenium. Improper handling or disposal without a waste determination can lead to severe liability.
For worker safety, OSHA’s 29 CFR 1910 outlines critical rules for handling electrical components and heavy materials, including the use of personal protective equipment (PPE) and procedures for lockout/tagout during decommissioning.
In California, where many utility-scale projects are located, the Department of Toxic Substances Control (DTSC) allows certain photovoltaic modules to be classified as universal waste, streamlining the recycling process but still requiring proper containment, labeling and shipment to approved facilities.
While the U.S. doesn’t currently have its own version of the WEEE Directive, as the European Union does, it remains a leading model for lifecycle responsibility and may signal future regulatory trends.
For every removal, O&M teams should:
- Conduct a hazardous waste determination for panel types
- Follow PPE, lifting, and transport protocols under OSHA
- Know if their state offers universal waste classification for PV
- Maintain documentation for regulatory and investor reporting
Understanding and applying these rules before any panels are removed helps avoid violations, protects workers, and ensures panels are sent to compliant recycling facilities, not landfills.
References:
EPA – End-of-Life Solar Panels: Regulations and ManagementUS EPA
OSHA – Electrical Protective Equipment
OSHA – General Requirements for PPEOSHA+6OSHA+6OSHA
DTSC – Photovoltaic Modules (PV Modules) Universal Waste Management RegulationsDepartment of Toxic Substances Control+1
European Commission – Waste Electrical and Electronic Equipment (WEEE)
Solar panel hazard identification: know the risks before you handle
End-of-life photovoltaic (PV) panels can pose chemical, physical, and environmental hazards that must be identified before removal or transport. From a chemical standpoint, crystalline silicon modules often contain lead-based solder. At the same time, some thin-film panels use materials like cadmium telluride (CdTe) or copper indium gallium selenide (CIGS), all of which can qualify as hazardous under the Resource Conservation and Recovery Act (RCRA) if not properly managed.
Physically, panels with shattered glass can cause cuts, and damaged modules may retain residual electrical charge, creating a risk of shock or arc flash, particularly if bypass diodes or junction boxes are compromised. Environmentally, cracked or exposed panels left outdoors may leach toxic materials into soil and groundwater, especially in high-temperature or wet conditions.
For O&M teams, panels must be inspected for damage, labeled appropriately, and treated with the same safety protocols used for other e-waste and hazardous material handling. A thorough hazard identification process at the start helps prevent injury, avoid environmental contamination, and ensure legal compliance.
References:
Solar Landscape Policy, pp. 6–8
ACP QEW Guidelines, p. 6, p. 20
Personal protective equipment (PPE): protecting the crew during handling and cleanup for solar panels
Proper PPE isn’t optional when handling damaged or aging solar panels; it’s critical for avoiding injury during decommissioning, transport, or cleanup. Shattered glass, sharp metal frames, and unknown electrical charge levels all present risks that demand appropriate gear.
At a minimum, crews should be supplied with and wear:
- Cut-resistant gloves to prevent lacerations from broken glass and sharp panel edges
- Long sleeves and protective clothing to minimize skin exposure, especially when handling cracked or degraded surfaces
- Steel-toe boots during loading and transport, where panel shifting or dropping is a risk
- ANSI-rated safety glasses or goggles to protect against airborne fragments or dust during cleanup or stacking
- Voltage-rated rubber gloves if the electrical status of the panel is unknown or if disconnects have not been verified
These protections align with OSHA 29 CFR 1910 Subparts I and S and are echoed in clean energy best practices for field service and O&M teams. PPE use should be reinforced through site-specific safety protocols and tailgate briefings—especially on projects involving mixed panel types, high-temperature exposures, or complex dismantling work.
References:
ACP QEW Guidelines, Appendix A & B
Solar Landscape Policy, pp. 10–12
OSHA
OSHA
Safe handling procedures: from solar panel to pallet, every step matters
Handling end-of-life solar panels requires structured procedures that protect both personnel and materials. It begins with a pre-removal inspection, and each module should be assessed for physical damage, residual electrical charge, and the potential presence of hazardous substances like lead or cadmium.
Before any tools touch a panel, O&M teams must follow lockout/tagout (LOTO) protocols to ensure all circuits are de-energized. Only insulated tools should be used when disconnecting wiring or removing modules from racking systems, and gloves rated for electrical work should be worn if there’s any uncertainty about voltage.
To prevent secondary damage during removal, workers should avoid bending, twisting, or applying pressure to frames, which can fracture tempered glass or compromise encapsulants. Once unmounted, panels should be handled vertically, not flat, and placed in foam-lined or cushioned racks to prevent abrasion or cracking during transport.
Every panel designated for disposal or recycling must be labeled according to local or federal hazardous waste requirements. If panels are classified as hazardous, packaging and shipping must meet DOT HazMat standards, including using certified containers and labeling under 49 CFR.
Throughout the process, documentation is key. Trained personnel must supervise handling, and records of inspection, removal, and shipment should be maintained to demonstrate compliance and protect against liability.
References:
ACP QEW Guidelines, pp. 6, 22–23
OSHA 29 CFR 1910.333 – Selection and Use of Work Practices
49 CFR Subchapter C – Hazardous Materials Regulations
NREL – Best Practices at the End of the Photovoltaic System Performance PeriodNREL+2NREL+2DOE OSTI+
OSHA – Control of Hazardous Energy (Lockout/Tagout) Standards
Decontamination and cleaning: preventing the spread of contaminants during solar panel removal
Solar panels should never be cleaned at end-of-life using high-pressure water or chemical-based solvents, especially on damaged or weather-exposed units. Dry or low-moisture methods, such as using soft-bristled brushes, vacuums, or absorbent pads, are preferred to avoid runoff.
If there is visible residue, corrosion, or known exposure to extreme weather events, panels may be contaminated and must be treated as potentially hazardous materials. Cleaning should be limited to containment: any leaked material must be collected using spill-absorbent materials (pads or granules) and disposed of in accordance with RCRA or state hazardous waste guidelines.
No decontamination or removal should proceed until the site has been assessed by Environmental Health and Safety (EH&S) personnel. A documented incident review is required, especially if there’s a risk of exposure to workers or the environment. Contaminated PPE, rags, or cleanup debris must be bagged, labeled, and manifested as part of the disposal chain.
Even in non-contaminated cases, cleaning should be handled with the same caution given to electronic waste, ensuring panels are stable, dry, and managed with minimal disturbance to their surfaces or internal layers.
References:
Solar Landscape Policy, pp. 7–8
EPA – End-of-Life Solar Panels: Regulations and Management
Storage and disposal of solar panels: secure solar panels, protect the site, document the process
Decommissioned solar panels must be stored in a way that protects workers, the environment, and the panels themselves from further damage. Short-term storage should take place in weatherproof, covered areas on stable surfaces with spill control measures in place. Storage zones should be marked with clear signage indicating whether the material is classified as solar waste, universal waste, or hazardous waste, depending on local and federal guidance.
Solar panels that have life in them should never be stacked flat or stored outdoors, where they may be exposed to rain, heat, or impact. Improper stacking increases the risk of breakage, which can complicate downstream handling and raise the risk of environmental release.
When it comes to disposal, recycling is the preferred and most compliant option. O&M teams should partner with certified electronics recyclers, such as facilities with R2v3 or e-Stewards certification, to ensure responsible material recovery and proper documentation of the chain of custody.
In rare situations where recycling is not technically or economically feasible, landfilling may be permitted, but only after a hazardous waste determination (typically via TCLP testing) and with explicit regulatory approval. Panels that qualify as hazardous must be managed under RCRA Subtitle C, and non-hazardous panels still require proper manifesting and tracking if disposed of in bulk.
References:
Solar Landscape Policy, pp. 11–12
Training and competency: only trained hands should handle end-of-life solar panels
Handling end-of-life (EOL) solar panels safely depends on ensuring that O&M personnel have the right training, not just once but continuously. All workers involved in panel removal, transport, or cleanup must be trained in hazard recognition, proper use of PPE, lockout/tagout (LOTO) procedures, and emergency response protocols specific to photovoltaic systems.
Any worker tasked with disconnecting or working near energized components must meet the qualifications of a Qualified Electrical Worker (QEW), as defined under OSHA 29 CFR 1910.269 and supported by the NFPA 70E standard for electrical safety in the workplace. This includes training in arc flash risk assessment, voltage testing, and the use of electrical-rated PPE.
Training is not a one-time event. Companies could perform regular assessments, refresher courses, and site-specific safety briefings to ensure all team members retain the knowledge and competency required to handle decommissioned solar equipment safely. This is not just a best practice; it’s a regulatory and liability expectation.
References:
Solar Landscape Policy, pp. 3–5
Emergency response on solar sites: prepare for cuts, shocks, and contamination events
Emergency response planning for end-of-life solar panel operations must be specific, accessible, and practiced. Incidents can involve broken glass, toxic substance exposure, or electrical shock, all of which require immediate and informed action.
If a worker is cut by shattered panel glass, provide first aid immediately and report the injury per site protocol. In the event of electrical shock, no one should touch the affected worker until the circuit is confirmed de-energized using appropriate testing tools. This step is critical to prevent a second injury.
For any suspected chemical exposure, site leads must reference the panel manufacturer’s Safety Data Sheet (SDS), which outlines the proper response and necessary medical treatment. SDS documents should be stored on-site and readily available to all crews during panel handling or cleanup.
Spill response kits must be stationed at each active work area, and any material used for chemical cleanup, absorbents, rags, or gloves should be treated as potentially hazardous waste until properly characterized.
Emergency plans must include communication protocols, trained responders, and a designated supervisor to ensure swift reporting and containment.
Routine drills and periodic plan reviews help ensure that emergency procedures aren’t just written; they’re followed when seconds matter.
References:
Continuous improvement: make every solar job safer than the last
The Solar eWaste Solutions team knows firsthand that managing end-of-life (EOL) solar panels isn’t a set-it-and-forget-it process. It requires ongoing review and refinement based on what’s happening in the field. O&M teams should maintain a log of all incidents, near misses, and equipment handling challenges, including feedback on the condition of removed panels and the performance of recycling vendors.
This information shouldn’t stay in the logbook; it should inform updates on job hazard analyses (JHAs), tailgate briefings, and standard operating procedures (SOPs). For example, if multiple teams report glass breakage during racking removal, the removal protocol or PPE guidance should be adjusted accordingly.
Companies committed to continuous improvement should also assign leads to track changes in regulatory guidance, including updates from the EPA, OSHA, and state agencies, and incorporate those changes into field practices without delay. Participation in industry safety coalitions, solar recycling working groups, or O&M peer forums can offer early insight into evolving best practices and help your teams stay ahead of compliance curves.
Continuous improvement turns one-time fixes into a long-term safety culture, ensuring each panel is handled smarter than the last.
References:
ACP QEW Guidelines, Appendix C
Planning for the Full Lifecycle Pays Off
End-of-life solar panel handling is not just about breakage during decommissioning. It’s about anticipating the many reasons modules will eventually need to be removed, whether due to degradation, the expiration of a PPA, technology upgrades, storm damage, manufacturer defects, or evolving interconnection standards. Add to that shifting ESG expectations, stricter landfill regulations, and incentives tied to responsible recycling, and it’s clear that disposal isn’t an afterthought, it’s part of the project lifecycle.
For O&M teams, having a clear, compliant plan isn’t just safer and smarter. The teams that think ahead on storage, handling, and documentation are the ones that avoid delays, protect workers, and stay aligned with investor and regulatory expectations.
It’s a lot to manage, but it doesn’t have to be managed alone. At Solar eWaste Solutions, we are built to support these exact moments quietly behind the scenes or hands-on when needed so that O&M crews can focus on keeping solar running strong.