Silicon Valley Toxics 2014 Scorecard Guidance Document

Silicon Valley Toxics Coalition

2014 Solar Scorecard Guidance Document

April 2014

SVTC Sustainable Solar Industry Initiative

Sustainability Scoring Criteria:

•Extended Producer Responsibility•Emissions Reduction•Workers Rights, Health and Safety•Supply chain•Conflict Minerals•Module Toxicity•Cradle to Cradle Recycling•Prison Labor•Biodiversity•Water•Energy & GHGs.

2014-16 Scoring MethodologyNew scoring methodology

• SVTC will score Solar companies’ websites bi-annually based on survey

response, interviews, news sources and publicly available data and

information posted on their websites.

• SVTC will continue to score 40 companies that represent an estimated 80-

85% of the market share. SVTC will also score smaller companies who

request to participate.

• SVTC will provide companies with survey questionnaires and notify

companies of deadlines via email announcements. The survey questions

and instructions on how to participate in the Scorecard will also be posted

on SVTC’s website.

• SVTC will use the existing 2013 survey questions to score companies in

2014-15.

• SVTC will be as transparent as possible about the scoring system.

• SVTC expects companies to improve their scores over the course of the

two years. Thus, SVTC will acknowledge companies that are innovating and

also acknowledge companies that are not truthful in their reporting.

• SVTC will partner with San Jose Sate University and the University of

California -Santa Cruz and other stakeholders to develop 2016 scoring

system, metrics and environmental standards.

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Extended Producer Responsibility (EPR) – 20 points

Issue: PV modules at the end-of-life have a recipe for e-waste—valuable metals mixed with

toxic materials. There is a growing concern that PV modules will be found in future e-waste

streams sent to developing countries.

Goal: Companies have a global take-back and responsible recycling program and support

legislation that moves in this direction.

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Criteria Description Points Possible

EPR program participation Q2

Fully funded collection and recycling system for End of Life PV modules produced globally

+5 — all PV modules produced globally+2 — PV Cycle member only

Direct support for EPR policy in USA Q1

Manufacturer writes a letter to the Solar Energy Industry Association (SEIA) urging them to support EPR laws and regulations

+5 — SEIA letter

Commitment to EPR in principle Q1

Reports to SVTC that they support public policies based on EPR in the regions they manufacture and sell PV modules.

+5 — Direct communication to SVTC orevidence of policy support fromwebsite.

Module Label & Website Q3

Label with crossed-out garbage bin appears on PV module nameplate. Clearly describes on website how all customers can responsibly return PV modules for recycling

+2 — Garbage bin on PV nameplate+1 — PV Cycle link on website+2 — More detailed recycling information on website

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Cradle-to-Cradle Recycling - 5 pointsIssue: There are numerous materials used in PV that are finite resources and making PV from

recycled materials will reduce waste, improve recycling markets and lessen the overall impact

on natural resources.

Goal: Companies have cradle to cradle recycling in which 95% or more of the materials recovered are destined for high value recycling and materials recovery.

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High Value MaterialRecovery Rate Q5

95% of the PV module is recycled into similar value and quality products; or 95% of the PV module is down-cycled into lesser value and quality products

+2 – cradle to cradle recycle, or+1 – down-cycle

ISO 14001 Facilities Q4

All recycling activities take place at a facility with a documented environmental management system and worker safeguards and protections consistent with ISO 14001

+1

Design for the environment Q6

Cradle to cradle recycling is encouraged at the design stage through design for the environment (dfe) training programs offered by company.

+2

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Emissions Transparency - 10 pointsIssue: PV manufacturing relies on the use of hazardous chemicals similar to those used in the

electronics industry which led to widespread contamination at manufacturing sites (Silicon

Valley has the highest concentration of Superfund sites in the USA).

Goal: Companies disclose chemical emissions information on their website.

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Chemical Emissions Q7

Information regarding chemical emissions including chemical waste (HCl, HF, Cl2), hazardous waste disposal and/or heavy metals.

+4 – chemical waste (HCL, HF, Cl2), hazardous waste disposal, heavy metals

Air Pollutants Q7 Information regarding air pollutants is disclosed in annual report, and or confirmed by third party auditing or government agency.

+2 – NOx, SOx, Volatile Organic Compounds, Particulate matter (PM)Or +1 – if fewer than above

Ozone Depleting SubstancesQ7

Information regarding ozone depleting substances is disclosed in annual report, and/ or confirmed by third party auditing or government agency.

+2 – Ozone depleting substances

Landfill Disposal Q7

Information regarding landfill disposal is disclosed in annual report, and/ or confirmed by third party auditing or government agency.

+2

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Chemical Reduction Plan – 5 points

Issue: Reducing chemical use per module has benefits to the environment, workers, and the

cost of making PV.

Goal: Companies have a plan to reduce the use of hazardous chemicals. Companies should be able to measure, track, and report on progress.

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Chemical Reduction Plan Q8

Companies have adopted a plan with goals to reduce chemical use per module and described it on their website or sustainability report.

+5

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Workers’ Rights, Health and Safety - 15 points

Issue: PV manufacturing should be done in a way that protects worker rights, health and safety.

Goal: Companies protect workers’ rights, health and safety and can prove it. SVTC’s overall goals for worker protections can be found on our Green Job’s Platform on our website.

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FormalCommitment Q9

Companies adopt a formal commitment that protects worker rights, health, and safety that goes beyond compliance with local laws and regulations

+4 SEIA’s commitment or equivalent company declaration, or+2 policy for a company declaration that is missing important elements of a commitment to worker, right, health, and safety.

Living Wage Q10 Commitment to improving wages of employees. +2 All employees paid more than min wage.

Post Signs in workplace Q11

Post signage for minimum wage provisions for illiterate workers

+1

CollectiveBargaining Q12

Utilize a workforce protected by collective bargaining

+2 if 100%+1 if > 50%

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Workers Rights, Health and Safety - 15 points… continued

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Work Day Case Rate Q13

Report and show improvements in workday case rates

+1 for annual improvement+1 for reporting

Recordable Incident Rates Q14

Based on reporting criteria used Bureau of Labor Statistics http://www.bls.gov/iif/osheval.htm

+1 for annual improvement+1 for reporting

OHSAS Q15 OHSAS for 100% of their facilities +2 if 100% of facilities, +1 if >50%

Issue: PV manufacturing should be done in a way that protects worker rights, health and safety.

Goal: Companies protect workers’ rights, health and safety and can prove it. SVTC’s overall goals for worker protections can be found on our Green Job’s Platform on our website.

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Supply Chain 10 points

Issue: As global supply chains become increasingly complex, it is often not known what is

happening regarding worker and environmental impacts in the supply chain

Goal: Companies have their suppliers from across the lifecycle report chemical emissions; have companies adopting binding commitments to monitoring and improving the environmental, health, and safety of their operations.

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Supply ChainChemical Monitoring Q16

Purchase from suppliers that report all chemical emissions from module upstream to polysilicon production or semiconductor preparation

+2 if all tiers report+1 if only first tier suppliers report

Commitment

from

Suppliers

Q17

Enforceable commitment from suppliers to protect workers and the environment.

+7 SEIA commitment, UNGC , or SA8000+3 if a less comprehensive code of conduct

Commitment

from Tier 2

Suppliers

Q17

Companies could also earn points if the agreement with suppliers extended to tier 2 of suppliers’ supply chain.

+1 code of conduct covers tier two.

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Module Toxicity 10 points

Issue: Using toxic materials in PV poses a risk to the environment and workers, and increases

operating and disposal costs.

Goal: Companies have no toxic substances in its PV modules.

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Eliminate Heavy Metals Q18

Companies that do not contain toxic heavy metals. Some manufacturers have been able to significantly reduce the toxicity of their modules to very low levels. The levels of Cd and Pb allowed in products under RoHS is the threshold used for claims to be cadmium or lead free.

+10 – for no more Pb or Cd than allowed under RoHS.

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Biodiversity - 5 points

Issue: Many solar power plants, including PV power plants are being built on sensitive

ecological habitat in some of the areas that will be most affected by climate change.

Goal: Companies build projects (PV installations, manufacturing fabs, factories) on previously disturbed or degraded lands or on rooftops and parking lots and have no direct impacts on threatened and endangered species or on wildlife and biodiversity.

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Zero Take permitsQ20

Zero take permits for endangered, threatened, or special concern animals in the US from 2013 to pending.

+3

No harm to wildlife or sensitize species Q21

No Species of Special Concern Present at Project Sites

+1

No Biodiversity Impacts Q22

No significant impacts of activities on biodiversity in protected areas or on areas of high biodiversity value outside protected areas

+1

These are all questions derived from the Global Reporting Initiative (which is supported by UNEP/OECD/ISO)

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Energy Use & Greenhouse Gas (GHG) Emissions - 5 points

Issue: Reporting on energy use and GHGs will encourage manufacturers to use the cleanest

energy possible to make PV.

Goal: Companies report energy use, sources of energy, and greenhouse gas emissions (GHGs).

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Energy & GHG Reporting Q23

Companies that report energy use GHGs, perfluorocarbon and/or report information to a third party.

+1 report energy use annually

+1 report greenhouse gases

+1 Report perfluorocarbons

+2 report GHGs and/or energy to

third party

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Conflict Minerals - 5 points

Issue: Tin is a conflict mineral and its use in PV is widespread.

Goal: Companies confirm through due diligence that there are no conflict minerals in their

products.

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OECD Guidelines Q24

PV manufacturing 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 and can produce documentation

+5 Document OECD Due Diligence+3 Starting the due diligence process

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Water - 5 points

Issue: There are significant amounts of water used and wastewater emissions for making PV.

Goal: Companies do not pollute the water and reduce the amount used in production. One place to start is to require manufacturers disclose water use and emissions.

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Report Water Use Q25, Q26, Q27

Company recognizes the importance of reducing impacts to water.

+2 They report volume of water use +1 and wastewater generated +2 according to several water quality indicators.

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Prison Labor - 5 points

Issue: Prison labor does not have the same oversight as non-prison labor and prisoners may

be exposed to higher levels of pollution in the workplace.

Goal: Companies have written policies forbidding the use of prison labor throughout the supply chain.

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Prison Labor Free Production Q28

company have an explicit policy forbidding prison labor

+5 – for providing the policy to SVTC or posting on website.+3 – company declared they do not use prison labor on previous SVTC surveys.

Solar Scorecard Core Staffing

Sheila Davis, Executive Director, Silicon Valley Toxics Coalition

Dustin Mulvaney, Ph.D., SVTC Senior Research Scientist

Assistant Professor, Environmental Studies, San Jose State University

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