Dear Solar Manufacturer:
The Silicon Valley Toxics Coalition (SVTC) is conducting our annual survey of manufacturers of solar
photovoltaic (PV) modules, and we would greatly appreciate your response. The deadline July 1, 2015.
Please complete and return this survey by the deadline to SVTC@SVTC.org using this word doc . If you have
any questions about the survey, email Sheila Davis at sdavis@svtc.org or call (408) 287-6707.
The final survey question provides space for you to further explain any of your responses. If necessary, please
attach supplemental materials to support or verify any of your answers. When prompted for information
posted on your website, this includes all publicly accessible content including sustainability and annual reports
posted as pdfs. Please provide the URL for the webpage or file.
Company Information
Company name:
Total volume of PV modules manufactured in 2014:
MWp
PV module manufacturing capacity as of Jan 1st 2015:
MWp
Countries where PV-related manufacturing occurs:
Extended Producer Responsibility
1. Would your company publicly support public policies based on the definition of extended producer
responsibility (EPR)1 in regions where you manufacture and sell PV modules?
a. Yes
b. Yes, and we have enclosed a copy of the letter we sent to Solar Energy Industries Association (SEIA) to
demonstrate our company’s commitment to EPR in the USA.*
c. No
*SVTC has enclosed a sample copy of a letter to SEIA.
2. Does your company currently set aside money to finance the collection and management of end-of-life PV
modules?
a. Yes, we have set aside money for each panel sold worldwide.
b. Yes, we have set aside money for each panel sold in Europe through the PV Cycle Initiative.
c. Not yet, but we are planning to begin this practice in the future.
d. No
e. Other (please specify):
3. Does your website let customers know how to recycle/take back their PV modules in all markets in which
they sell?
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a. Yes (please provide URL for all markets)
b. No
Cradle-to-Cradle Recycling
4. Are waste or scrap PV modules sent to a recycling facility with a documented environmental management
system and worker safeguards and protections consistent with ISO 14001?
a. Yes
b. No
c. No, we do not recycle our PV modules.
5. What is the final destination for end-of-life (EOL) and defective PV modules (by weight)?
a. ____% is cradle-to-cradle recycled2.
b. ____% is down-cycled3 into other products.
c. ____% is sent to a hazardous materials treatment facility.
d. ____% is sent to landfill.
e. ____% is sent to other (please specify):
f. ____Don’t know.
6. Has your company offered “design for recycling,” cradle-to-cradle,” or similar training to product designers
in the past three years?
a. Yes
b. No
c. No, but we’ve encouraged these concepts by doing the following:
Emissions Transparency
7. Do you post the following environmental releases on your website? (Please mark each stage of production
involving these emissions by changing the color of the circle, or marking an X in place of the circle.)
Crystalline Silicon
polysilicon
wafer
cell
module
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Greenhouse gases/C02e
Perfluorocarbons, SF6/NF3, CHF3, CF4, C2F6
Air emissions: SOx, NOx, VOCs, PM10
Hazardous landfill disposal by weight
Weight of hazardous waste released and transferred
Total heavy metal emissions
Other chemical waste (HCl, HF, Cl2)
Please provide URL:
Thin Films
Semiconductor4
cell/module
2
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
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Greenhouse gases/C02e
Perfluorocarbons, SF6/NF3, CHF3, CF4, C2F6
Air emissions: SOx, NOx, VOCs, PM10
Hazardous landfill disposal by weight
Weight of hazardous waste released and transferred
Total heavy metal emissions
Other chemical waste (HCl, HF, Cl2)
Please provide URL:
Chemical Reduction Plan
8. Does your company post annual hazardous chemical reduction targets on your website?
a. Yes (please provide URL).
b. No
Workers’ Rights, Health, and Safety
9. Does your company have a worker code of conduct that addresses worker rights, health and safety?
a. Yes
b. Yes, and we have attached the code of conduct to our response or signed onto the SEIA Environmental
& Social Responsibility Commitment
c. No
10. What percentage of your manufacturing employees or workers who manufacture your brand name
products are paid more than the minimum wage for the region/country?
_____%
11. Do you post signs in areas workers frequent or make arrangements for giving publicity to minimum wage
provisions in languages or dialects understood by workers who need protection, adapted where necessary to
the needs of illiterate persons?
a. Yes
b. No
12. What percentage of your manufacturing employees or workers who manufacture your brand name
products are covered by collective bargaining agreements?5
_____%
13. What are your workday case rates for the following regions?6
a. Global:
b. Americas:
c. Europe, Middle East, and Africa:
d. Asia Pacific and Japan:
14. What are your recordable incidence rates for the following regions?7
a. Global:
b. Americas:
c. Europe, Middle East, and Africa:
d. Asia Pacific and Japan:
3
15. What share of manufacturing facilities (based on production output) has received Occupational Health and
Safety Management (OHSAS 18001) Certification?8
_____%
Supply Chain
16. Does your entire supply chain9 from polysilicon to PV module manufacturing report the following
environmental releases from each production stage on their websites? (Mark all that apply).
Crystalline Silicon
polysilicon wafer
cell
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module
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backsheet encapsulant
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Greenhouse gases/C02e
Perfluorocarbons, SF6/NF3, CHF3, CF4, C2F6
Air emissions: SOx, NOx, VOCs, PM10
Hazardous landfill disposal by weight
Weight of hazardous waste released and transferred
Total heavy metal emissions
Other chemical waste (HCl, HF, Cl2)
Thin Films
Semiconductor
cell/module
backsheet
encapsulant
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Greenhouse gases/C02e
Perfluorocarbons, SF6/NF3, CHF3, CF4, C2F6
Air Emissions: SOx, NOx, VOCs, PM10
Hazardous landfill disposal by weight
Weight of hazardous waste released and transferred
Total heavy metal emissions
Other chemical waste (HCl, HF, Cl2)
17. Which of your supplier tiers are required to meet your worker code of conduct? (Mark all that apply)
Tier One10
Tier Two11
Tier Three12
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Module Toxicity
18. Do your PV modules contain cadmium or lead? If so, what is the maximum concentration found in any
homogenous material?13 Please mark all that apply.
a. Yes, cadmium at concentrations greater than 0.01% or 100 ppm.
b. Yes, cadmium at concentrations less than 0.01% or 100 ppm.
c. Yes, lead at concentrations greater than 0.10% or 1,000 ppm.
d. Yes, lead at concentrations less than 0.10% or 1,000 ppm.
e. No
19. Have you performed a hazardous waste determination for your PV modules?
a. We have not performed a hazardous waste determination for our PV modules.
b. Our modules are not hazardous waste according to (select all that apply):
i. US EPA TCLP
ii. California STLC/TTLC
iii. International Electrotechnical Commission, IEC 62321
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iv. Germany, DIN 38414-S4
v. EU Directive on Waste BS EN 12457, CEN/TS14405, NTENVIR003
vi. British Standards Institution, BS EN 12457
vii. European Committee for Standardization EU CEN/TS14405
viii. Nordtest NT ENVIR 003
ix. Other (please specify):
c. Our PV modules are hazardous waste according to:
i. US EPA TCLP
ii. California STLC/TTLC
iii. International Electrotechnical Commission, IEC 62321
iv. Germany, DIN 38414-S4
v. EU Directive on Waste BS EN 12457, CEN/TS14405, NTENVIR003
vi. British Standards Institution, BS EN 12457
vii. European Committee for Standardization EU CEN/TS14405
viii. Nordtest NT ENVIR 003
ix. Other (please specify):
Biodiversity
20. How many incidental take permits14 for threatened and endangered species were issued for projects (power
plants, manufacturing facilities, warehouses, etc.) your company developed in the US from 2011 to 2013? Add
to this number any equivalent permits issued for species of concern in other countries over the same time period.
21. Are species of special concern, sensitive species, and/or threatened and endangered species found on lands
where projects (power plants, manufacturing facilities, warehouses, etc.) developed by your company or its
subsidiaries are sited?
a. Yes
b. No
22. Identify significant impacts of activities from your company or its subsidiaries on biodiversity in protected
areas or on areas of high biodiversity value outside protected areas.
Energy Use & Greenhouse Gas (GHG) Emissions
23. Do you report the overall direct and indirect energy consumption used to make your PV module by primary
energy sources?15
a. Yes, on our website.
b. Yes, to a third party (e.g. Carbon Disclosure project, Global Reporting Initiative).
c. No
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Conflict Minerals
24. Tin is a PV manufacturing input that has been classified as a potential conflict mineral.16 Can you verify that
your supply chain does not contain conflict minerals from the Democratic Republic of the Congo (DRC),
Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda,
Malawi and Zambia as per the due diligence guidance outlined by the OECD?17
a. Yes, we have conducted due diligence to confirm that there are no conflict minerals in our supply chain.
b. No, we have done due diligence, but cannot confirm the country of origin of potential conflict minerals.
c. No
Water
25. Do you post the volume of water that is used in production each year on your website?
a. Yes (please provide URL).
b. No
26. Do you post your annual volume of wastewater discharged on your website?
a. Yes (please provide URL).
b. No
27. Do you post the following wastewater discharge quality indicators on your website?
If yes, please provide the URL:
a. Chemical oxygen demand
b. Biological oxygen demand
c. Heavy metals
d. Totally suspended solids
Yes
Yes
Yes
Yes
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No
No
No
No
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Prison Labor
28. Does your company currently use prison labor (e.g. UNICOR) during any aspect of the product lifecycle
including end-of-life recycling and disposal?
a. Yes
b. No
c. No, we have an explicit policy forbidding this practice and we have attached it.
If further explanations are necessary to clarify your answers, please use the space below.
End Notes
1
According to the California Product Stewardship Council, Extended Producer Responsibility means that whoever designs,
produces, sells or uses a product takes primary responsibility for minimizing its environmental impact through all stages
of the product’s life cycle. The producer, having the greatest ability to minimize impacts, has the most responsibility.
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2
Cradle–to-cradle recycling is a form of material recovery by which waste can be remade into the same or higher value
materials as the original materials.
3
Down-cycling is a form of recycling in which waste materials are converted into lower quality or lower value forms of the
materials originally used as inputs due to material degradation or contamination.
4
The semiconductor stage for thin films refers to the stage of production where the semiconductor constituents are
purified or prepared. For CdTe this would be the stage of production that purifies Cd and Te to make CdTe. For CIGS it is
the stage of production that purifies and prepares copper, indium, gallium, and selenium. For amorphous silicon it
would be silane production.
5
According to the Global Reporting Initiative (GRI), “there are two types of collective bargaining agreements, aimed either
at employers or workers. Those aimed at employers are agreements in writing regarding working conditions and terms
of employment concluded between an employer, a group of employers, or one or more employers’ organizations.
Those aimed at workers are agreements between one or more representative workers’ organizations, or, in the
absence of such organizations, the representatives of the workers duly elected and authorized by them in accordance
with national laws and regulations.” “The percentage of employees covered by collective bargaining agreements is the
most direct way to demonstrate an organization’s practices in relation to freedom of association. Freedom of
association is a human right as defined by international declarations and conventions, particularly ILO Core Conventions
87 & 98.”
6
Lost workday case rate is the number of work-related injuries that result in time away from work per 100 employees
working a full year.
7
Calculated by the US Bureau of Labor Statistics (BLS), the incidence rate represents the number of full-time employees
(out of every 100) suffering a recordable injury or illness during a given calendar year.
8
The OHSAS 18001 management system requires organizations (a) establish an OHS management system to minimize
risks to its employees and other interested parties; (b) implement, maintain, and continually improve an OHS
management system; (c) assure itself of its conformance with its stated OHS policy; (d) to demonstrate such
conformance to others; (e) seek certification/registration of its OHS management system by an external organization;
and (f) make a self-determination and declaration of conformance with the standard’s specifications.
9
If you purchase inputs from multiple suppliers, evaluate the supplier that provides the highest proportion.
10
Tier one suppliers are the suppliers that make parts for PV modules or contract manufacture your PV modules. Tier one
suppliers directly conduct business with your company.
11
Tier two suppliers are suppliers that directly conduct business with your tier one suppliers.
12
Tier three suppliers are suppliers that directly conduct business with your tier two suppliers.
13
Homogenous materials are defined as materials that cannot be mechanically disjointed into different materials and are
of uniform composition throughout.
14
For a description of an incidental take permit, see: http://en.wikipedia.org/wiki/Incidental_Take_Permit
15
Direct primary energy consumption includes energy sources used on site. Indirect primary energy consumption includes
energy produced offsite and purchased for electricity or heating.
16
Conflict minerals are minerals obtained from sources that are controlled by armed groups that use the sales to
purchase weapons. Given the complexities of global armed conflict and the diversity of mineral deposits, there is no
precise list of conflict minerals, although “blood diamonds,” coltan, tungsten, cassiterite (tin ore), and gold from the
Great Lakes Region of Africa are widely considered the most common conflict minerals. The OECD has developed a
framework for supply chain due diligence to help ensure that minerals from high-risk areas are conflict free.
17
http://www.oecd.org/daf/internationalinvestment/guidelinesformultinationalenterprises/mining.htm
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