Solar Panel Removal & Recycling SWMS
Decommission and end-of-life pathway for installed solar PV — de-energisation and string isolation, mechanical detachment, glass / cell handling for recycling stream, transport to PV stewardship facility, ballast / penetration make-good.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Solar panel removal and recycling covers the decommissioning and end-of-life pathway for an installed photovoltaic array — de-energisation and string isolation, mechanical detachment of panels and mounting, handling of glass and cell material for the recycling stream, transport to a PV stewardship facility, and make-good of ballast points and roof penetrations. As Australia's first large wave of rooftop and ground-mount PV reaches end of life, removal and recycling is a growing trade, and although it is not classified as High-Risk Construction Work in its own right, it carries real electrical, manual-handling, and material-hazard risks that warrant a documented safe system of work. A decommissioned array is still a live DC source under sunlight until it is isolated, and aged panels can have damaged glass, degraded backsheets, and brittle frames that complicate handling.
The electrical work follows AS/NZS 5033 for the PV array, with isolation and proving de-energised to AS/NZS 4836 before any string is disconnected. Panels removed for recycling must be handled to preserve them for the stewardship stream where possible and to control the hazards of broken glass and the small quantities of metals (including lead and cadmium compounds in some cell and solder chemistries) that make a damaged panel a controlled waste. The work intersects the developing product-stewardship framework for photovoltaic systems, and operators should confirm the current stewardship and waste pathway in their state at the time of work.
This SWMS is jurisdiction-neutral within Australia and written to the model WHS framework. Victoria operates under the Occupational Health and Safety Act 2004 and OHS Regulations 2017 — check the VIC-specific variant for the local equivalents of the duties and codes cited here.
Hazards identified
9 hazards covered, sorted by priority.
Electric shock and DC arc burns; the array remains live under sunlight until isolated, so disconnecting a string before isolation can shock the worker or strike a sustained DC arc.
Serious or fatal fall injury when removing roof-mounted panels at the perimeter or over a fragile roof element.
Deep cuts to hands, arms, and face from handling panels with cracked or shattered tempered glass, common on weather-damaged or aged arrays.
Musculoskeletal injury from lifting and manoeuvring large-format panels and rail, often in awkward roof or ground-mount positions.
Exposure to lead and cadmium compounds present in some cell and solder chemistries when a panel is broken, creating a contact and inhalation hazard from dust and fragments.
Struck-by injury to workers or public at ground level from dropped panels or mounting during roof removal.
Musculoskeletal injury or load shift; panels stacked for transport to the stewardship facility can shift or fall if not restrained correctly.
Sprain, fracture, or secondary fall on a roof or ground-mount with degraded surfaces, cabling, and removed fixings underfoot.
Sunburn, heat stress, and dehydration during sustained outdoor decommissioning work.
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Isolate and prove de-energised the array before any mechanical work — shut down the inverter, isolate at the array and string level, and prove the absence of voltage with a rated tester to AS/NZS 4836 — treating the array as a live DC source under sunlight until proven otherwise.
- 2Apply AS/NZS 5033 isolation and handling practice for the PV array, disconnecting DC connectors only when isolated and never under load, and using rated insulated tools for any electrical step.
- 3Control the fall risk for roof-mounted removal with edge protection or, where not reasonably practicable, a restraint system to certified anchors, and protect or avoid fragile roof elements, applying the falls hierarchy even though the task is not itself HRCW.
- 4Handle panels as potentially broken — gloves rated for cut resistance, controlled lifting, and a method for containing and isolating panels with shattered glass to prevent laceration and the spread of fragments.
- 5Treat broken or damaged panels as a controlled waste where the cell or solder chemistry contains lead or cadmium compounds — contain fragments, prevent dust generation, and manage the waste through the licensed pathway rather than general waste.
- 6Use mechanical handling aids and team-lift limits for panels and rail, and plan a ground-level exclusion zone with tool and material control so nothing can fall onto people below during roof removal.
- 7Restrain panels for transport to the PV stewardship facility per the load-restraint requirements, with stacking, edge protection, and tie-down that prevents shift in transit.
- 8Maintain housekeeping and footing discipline across the array — remove cabling and fixings as you go, keep walkways clear — and confirm the current PV stewardship and waste pathway in the relevant state before transporting material.
- 9Schedule outdoor work to manage heat and UV with shade, hydration, and work-rest cycles, and provide sun protection for the crew.
- 10Provide PPE as the final layer — cut-resistant gloves, eye protection against glass fragments, insulating gloves for the isolation step, respiratory protection where broken-panel dust is credible, and sun protection — inspected before use.
- 11Brief the whole crew on the SWMS, the isolation sequence, the broken-glass handling method, and the waste pathway before work starts, and verify electrical isolation competency for the worker performing the disconnection.
Applicable Codes of Practice
Becomes legally binding under Section 26A of the WHS Act from 1 July 2026. Governs the isolation and proving de-energised of the PV array before mechanical removal, and the safe handling of an energised DC source.
Installation and safety requirements for photovoltaic (PV) arrays. Provides the isolation sequence and the safe-handling practice for an energised array applied in reverse during decommissioning.
Becomes legally binding under Section 26A from 1 July 2026. Governs the assessment and control of the manual handling of large-format panels and rail during detachment, loading, and transport.
Becomes legally binding under Section 26A from 1 July 2026. Governs the fall controls for roof-mounted panel removal, including edge protection, restraint, and fragile-roof protection.
Safe working on or near low-voltage and high-voltage electrical installations and equipment. Provides the test-prove-test methodology for proving the array de-energised before string disconnection.
Who this is for
- →Solar installers extending their service to array decommissioning and end-of-life removal.
- →Electrical contractors performing the de-energisation and string isolation phase of a removal.
- →Demolition and strip-out contractors removing PV as part of a building refurbishment or re-roof.
- →Waste and recycling operators handling end-of-life PV panels into the stewardship stream.
- →Facility managers decommissioning ageing rooftop or ground-mount arrays on commercial assets.
What you receive
- ✓Editable Microsoft Word .docx — open in Word or Google Docs, drop in your company logo and ABN.
- ✓State-specific variant matched to the jurisdiction selected at checkout (NSW, VIC, QLD, SA, WA, TAS, NT, or ACT).
- ✓All 9 hazards risk-assessed with inherent and residual ratings against a documented control set.
- ✓Isolation, handling, and waste controls referenced to AS/NZS 5033, AS/NZS 4836, and the model codes.
- ✓Guidance on handling broken panels as controlled waste and the PV stewardship pathway.
- ✓CIH-reviewed content written to be defended in front of a head contractor or a SafeWork inspector.
- ✓Instant download on payment, with a re-download window so you can retrieve the file again if needed.
- ✓Sign-on register and review-log structure ready for site-specific completion by the PCBU.
Worked example
A solar business in regional New South Wales is engaged to remove a 30 kW rooftop array from a rural commercial shed where the panels, installed more than a decade earlier, are weather-damaged with several cracked glass faces, ahead of a re-roof. The job runs over two days. Although the work is not High-Risk Construction Work, the business prepares a SWMS to control the electrical, fall, glass, and waste hazards, selecting the NSW variant. The crew first isolates the array — the inverter is shut down, the strings are isolated, and the absence of voltage is proven with a rated tester to AS/NZS 4836 before any connector is disconnected, treating the array as live under the sun until proven otherwise. Roof work uses edge protection at the perimeter and the cracked panels are handled with cut-resistant gloves and contained to prevent glass fragments spreading. Because some panels are broken and the cell chemistry may contain lead and cadmium compounds, the damaged panels are managed as a controlled waste rather than general waste. Panels are lowered mechanically with a ground-level exclusion zone beneath, stacked and restrained for transport, and taken to a PV stewardship facility; the crew confirms the current stewardship pathway in NSW before transport. Roof penetrations and ballast points are made good for the re-roofing contractor. The removal is completed without injury, and the signed SWMS and the waste-disposal records are retained for the client's environmental and end-of-life-asset file.
Related legislation
- Work Health and Safety Act 2011 (NSW) — Sections 19 (primary duty of care), 28 (worker duties), 46-49 (consultation)
- Work Health and Safety Regulation 2017 (NSW) — Sections 39-43 (hazardous manual tasks framework), 140-165 (electrical), 78-80 (falls)
- AS/NZS 5033:2021 — Installation and safety requirements for photovoltaic (PV) arrays
- AS/NZS 4836:2023 — Safe working on or near low-voltage and high-voltage electrical installations and equipment
- Protection of the Environment Operations Act 1997 (NSW) — controlled-waste handling for damaged panels (check state equivalent)
Frequently asked questions
Is solar panel removal High-Risk Construction Work?
No — removal and recycling is not classified as HRCW in its own right, which is why this product sits at the $149 non-HRCW price and the SWMS does not include a Reg 291 breakdown. It still carries genuine electrical, fall, glass, and waste hazards, so a documented safe system of work is appropriate, and roof-mounted removal at height should apply the falls hierarchy even though it is not a standalone HRCW trigger.
Is the array still dangerous once it is being decommissioned?
Yes. A photovoltaic array remains a live DC source whenever it is exposed to sunlight, regardless of whether it is being installed or removed. The SWMS requires the array to be isolated and proven de-energised to AS/NZS 4836 before any string is disconnected, and DC connectors are never opened under load.
How are broken panels handled for disposal?
Broken or damaged panels are treated as a controlled waste where the cell or solder chemistry contains lead or cadmium compounds. The SWMS requires fragments to be contained, dust generation prevented, and the material managed through the licensed waste and PV stewardship pathway rather than general waste. Operators should confirm the current stewardship and waste pathway in their state at the time of work, as this framework is developing.
Do the panels have to go to a recycling facility?
Where a PV product-stewardship pathway is available, panels are directed to a stewardship facility to recover glass, aluminium, and cell materials rather than to landfill. The SWMS covers the transport and load-restraint of panels to the facility, and prompts the operator to confirm the current stewardship arrangement in the relevant state, because availability and requirements vary and are changing.