Potential environmental hazards of photovoltaic panel disposal: Discussion of Tammaro et al. (2015)

In their recent publication in Journal of Hazardous Materials (http://dx.doi.org/10.1016/j.jhazmat.2015.12.018), Tammaro et al. evaluate the potential environmental impacts of an illegal disposal scenario of photovoltaic panels in the European Union. Critical assumptions that underlie the study's conclusions would benefit from clarification. A scenario of photovoltaic panels finely crushed and abandoned in nature is not supported with field breakage data, in which photovoltaic panels remain largely intact with a number of glass fractures or cracks, as opposed to breakage into cm-scale pieces. Fate and transport analysis is necessary to evaluate how leachate transforms and disperses in moving from the point of emissions to the point of exposure, prior to making comparisons with drinking water limits. Some hazardous metal content has declined in both crystalline silicon and thin film panels, including a 50% decline in semiconductor material intensity in CdTe thin film panels (g CdTe/W) from 2009 to 2015. Waste laws, recycling requirements and minimum treatment standards under the EU WEEE Directive, and illegal disposal rates affect the accuracy of forecasts of releasable metal amounts from PV panels in Europe through 2050.