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Contract No. DE-AC36-08GO28308

Managing EHS of PV-Related 

Equipment at the National 

Renewable Energy Laboratory

Preprint

Troy McCuskey and Brent P. Nelson

Presented at the 2012 IEEE Photovoltaic Specialists Conference

Austin, Texas

June 3–8, 2012

Conference Paper

NREL/CP-5200-54132

June 2012
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1

Managing EHS of PV-Related Equipment at the 

National Renewable Energy Laboratory

Troy McCuskey and Brent P. Nelson

National Renewable Energy Laboratory

Golden, CO 80401

Abstract — Managing environment, health, and safety (EHS) 

risks at a national laboratory, or university, can be intimidating 

to a researcher who is focused on research results. Laboratory 

research and development (R&D) operations are often driven by 

scientists with limited engineering support and lack well-refined 

equipment development resources. To add to the burden for a 

researcher, there is a plethora of codes, standards, and 

regulations that govern the safe installation and operation of 

photovoltaic-related R&D equipment—especially those involving 

hazardous production materials. To help guide the researcher 

through the vast list of requirements, the EHS office at NREL 

has taken a variety of steps. Organizationally, the office has

developed hazard-specific laboratory-level procedures to govern 

particular activities. These procedures are a distillation of 

appropriate international codes, fire agencies, SEMI standards, 

U.S. Department of Energy orders, and other industry standards 

to those necessary and sufficient to govern the safe operation of a 

given activity. The EHS office works proactively with researchers 

after a concept for a new R&D capability is conceived to help 

guide the safe design, acquisition, installation, and operation of 

the equipment. It starts with a safety assessment at the early 

stages such that requirements are implemented to determine the 

level of risk and degree of complexity presented by the activity so 

appropriate controls can be put in place to manage the risk. As 

the equipment requirements and design are refined, appropriate 

equipment standards are applied. Before the “to-build” 

specifications are finalized, a process hazard analysis is 

performed to ensure that no single-point failure presents an 

unacceptable risk. Finally, as the tool goes through construction 

and installation stages, reviews are performed at logical times to 

ensure that the requisite engineering controls and design are in 

place and operational. Authorization to operate is not given until 

adherence to these requirements is fully verified and documented. 

Operations continue under the conditions defined through this 

process and are reviewed with changing processes.

Index Terms — Environment, safety, and health (ESH); NREL, 

management, codes, standards, hazardous production materials, 

operations.

I. INTRODUCTION

Managing environment, safety, and health (EHS) risks at a 

national laboratory, or university, can be different in many 

aspects than doing so at a manufacturing facility. The biggest 

difference is that at a national laboratory, there are many 

chemicals but of generally small quantities, whereas a given 

manufacturing facility has much fewer chemicals but in much 

larger quantities. A typical national laboratory (and many 

universities) will have chemicals in virtually all of the hazard 

classes—e.g., highly toxic, toxic, pyrophoric, corrosive, 

flammable—in both liquid and gaseous states, as well as 

solids with these hazards. Having a large number of chemicals 

invokes multiple codes and regulations that can often be 

complex and confusing to scientists and engineers, and 

therefore, makes compliance challenging.

Another difference between industrial processes and those 

at research laboratories is the degree to which various aspects 

of the process are compartmentalized. For example, in an 

industrial operation using hazardous gases, the gas vendor 

often installs cylinders and the gas-handling manifold may 

even be leased from the vendor. Process engineers and 

technicians operate the deposition equipment. The abatement 

system may be centralized for the facility and operated and 

maintained by facilities staff. In contrast, at a national 

laboratory, the group “owning” the experiment often is 

responsible for the sources, plumbing, tool, and abatement 

systems. The equipment itself is also quite different in terms 

of size and purpose. Industrial tools are often commercially 

fabricated, highly automated, and integrated with other tools 

to achieve high throughput on a continuous basis. National 

laboratory and university tools are often custom (or “oneoff’s), manually operated (or less automated than industry), 

and standalone to obtain answers to specific technological 

questions and operated on an intermittent schedule. EHS 

professionals need to be recruited with a broad background of 

experience or from industries that are similar to photovoltaics 

(PV). EHS professionals who come from a focused industry 

often find this broad range of hazards a challenge to manage.

EHS professionals who come into the PV community from 

the semiconductor industry also find some differences in a 

much less industrially mature technology. Due to decades of 

roadmapping and standardization [1] efforts, the 

semiconductor industry is the most sophisticated industry in 

existence [2]. Many of the processes are similar from one 

company to the next, although the specific application of those 

processes may vary. In the PV industry, processes can be quite 

different from one company to the next, even within the same 

PV technology. Each generation of semiconductor equipment 

is designed to move silicon wafers of the same form factor. 

The PV industry has many materials—glass, wafers, and 

foils—in a wide variety of form factors. The goal of 

semiconductor manufacturing is to create more circuits on 

smaller and smaller dies. The goal of the PV industry is to 

cover larger and larger areas at lower and lower cost. The 

available semiconductor standards and roadmaps do not 

necessarily apply to the PV industry. R&D endeavors have 

even fewer equipment standards, so it is essential to guide 

activities using those that are necessary and sufficient,

accompanied by appropriate risk analysis.
2

II. SAFE HPM EQUIPMENT FUNCTIONALIZATION

To guide researchers through the vast array of codes and 

standards, the EHS office at NREL works proactively with the 

researchers to safely bring new capabilities on line, as 

summarized in Table 1. Once a new research need is defined, 

and a general idea of the equipment needed to perform that 

work is mapped out, the EHS office works with the researcher 

to define the specific EHS controls necessary to perform that 

work safely. Depending on the hazards presented by the 

operation, the controls can range from following a procedure 

in an equipment manual to writing a process-specific safe 

operating procedure to documenting that the equipment is in 

compliance with existing hazard-specific laboratory-level 

procedures (a process called a readiness verification) to a very 

detailed operational readiness review (ORR). Operations using 

hazardous production materials (HPMs) [3] require the most 

stringent shepherding through the various stages to bring the 

equipment on line.

Table 1. Stages of HPM Equipment Development

Researchers Vendor EHS Support

Define research need

Concept 

specifications

Consult on 

possibilities Hazard analysis

Design revisions Budgetary 

quotations Equipment standards

Purchasing process Provide bid

“To-build” 

specifications Finalize contract Process hazard analysis

Site facilitation

Equipment 

fabrication

Vendor 

acceptance

Tool-specific ORR 

inspection

Delivery to site

Hook up utilities Stage 1 ORR

Test with power and 

inert gases Stage 2 ORR

Observed operation Stage 3 ORR

Fully operate

The equipment design revision stage involves bringing all 

appropriate parties to the table to minimize roadblocks further 

down the development cycle. In addition to researcher 

technical reviews, potential vendors might be consulted to 

offer input into what capabilities are possible, site operations 

personnel are consulted to ensure facility capacity, contracts 

and business services are made aware of what is coming to 

give tips on how various acquisitions can best be put through 

the contractual system, and the legal office may be consulted, 

especially if intellectual property is involved. It is at this point 

that the EHS office helps with providing EHS-specific 

equipment standards to ensure that the equipment will be 

properly designed from the beginning. Most research 

laboratories do not get SEMI-S2 [1] fully compliant 

equipment for two main reasons: cost, and because R&D 

equipment tends to be unique and making the first version of a 

piece of equipment fully S2-compliant is exceedingly difficult,

resulting in significant delays. These equipment specifications 

are constantly evolving to ensure that those that are necessary 

and sufficient are required, while best practices are 

recommended based on the risk and cost-benefit 

considerations. It is advisable to separate EHS requirements 

into what is required by the vendor and what is required to be 

in place in the laboratory so that the vendor has clarity on 

responsibility. The specifications are closely coupled to the 

ORR requirements, as described below, to ensure that 

reviewers and those constructing and installing equipment are 

focused on the same elements. The equipment design revision 

stage is usually an iterative process because researchers 

typically begin with a very large scope and reduce the scope 

as available budgets are evaluated relative to early budgetary 

quotations that are usually larger than expected.

Once a final set of specifications is achieved, the 

purchasing process begins, which ultimately, if not painfully, 

leads to a contract with an equipment supplier. Because the 

potential vendors cannot invest enough time into the bid 

process to look at every detail of the equipment fabrication, it 

is typical that a phase of clarification occurs, leading to an 

agreement between the researcher and the vendor on the final 

“to-build” specifications and drawings. The EHS office works

proactively with the researcher to ensure that the equipment 

will safely perform as requested.. At this stage, a process 

hazard analysis (PHA) is performed to ensure that no singlepoint component failure causes an unacceptable risk. It is best 

that the PHA occurs before equipment is assembled to avoid 

costly change orders.

The next two stages are parallel activities. The equipment 

vendor starts fabrication. Once enough is known about the 

specific facility requirements of the equipment, the 

researcher—along with site operations (facilities) and EHS 

consultation—starts readying the facility for the equipment 

installation so that everything is ready to hook up to the 

equipment upon its arrival. The researchers, along with other 

appropriate parties, monitor the equipment fabrication to 

ensure that it is constructed to the specifications. This is done 

through frequent emails, phone calls, and teleconferences to 

exchange documents and pictures, ensuring that the research 

needs are being implemented by the vendor. Researchers who 

dedicate significant effort to managing this communication get 

a better product in the end. Those who just place an order and 

trust that the vendor can understand all the technical nuances 

of their needs as they construct the tool can be surprised with 

non-compliance issues at later stages.

It is best that at least two vendor site visits are scheduled, 

with the first when things are far enough along that the 

equipment can be inspected to ensure things are headed in the 

right direction to meet specifications. This includes looking at 

the general footprint, how the tool will interface with building 

and specialty utilities (to help ready the facility for eventual 

arrival), quality of components, and discuss technical detail of 

final construction face-to-face. Once the equipment is able to 

be tested at the vendor location, a vendor site acceptance test 

occurs. This is where the researcher ensures that the 

equipment performs the desired technical functions and the 
3

equipment is evaluated to ensure the EHS requirements are in 

place. It is recommended that at least two people make this 

trip to divide up the responsibility for areas of inspection (e.g., 

one looking at performance items and the other looking at 

EHS items). It is prudent to make this a formal and strict 

process. The vendor has a much stronger incentive to fix 

deficiencies while it is on their site (because they want to get 

the equipment out of their plant) than they do once it ships to 

the final location. Once the equipment is performing 

technically and safely at the vendor location, it is shipped to 

NREL.

Because these systems are complicated and often require 

being hooked up to a variety of utilities (e.g., cooling water, 

power, house gases, specialty gases, ventilation, monitoring 

equipment), the ORR process is phased over three equipment 

installation stages.

The first ORR stage is to ensure that the tool can be safely 

hooked up to the non-HPM utilities and then properly installed. 

HPM utilities (e.g., toxic, pyrophoric, flammable delivery 

systems) can be installed, but no HPM sources can be installed. 

Once these hook-ups are complete, the ORR process 

documents that the requirements to do equipment testing are 

in place. The next stage is putting the equipment through 

operational testing with power and inert gases. This is where 

many bugs and loose ends are resolved. The ORR process 

documents that the requirements to admit HPMs into the 

equipment are in place and that there is nothing outstanding 

that presents an undo risk. Complex equipment, or operations 

intended for multiple shifts, are required to start up under 

closely observed conditions and demonstrate safe operation 

before being allowed to fully operate. The entire ORR usually 

consists of two to three dozen checklists of requirements (see 

Table 2), depending on the complexity of the process, where 

requirements are matched commensurately to the hazard 

present. These checklists are closely matched to equipment 

design standards.

Any non-conforming items receive a risk analysis [4], as 

summarized in Figure 1. The risk of nonconformity is related 

to both the probability a particular event (failure) occurring

and the consequences of that event occurring. NREL only 

accepts operations that present low or routine risks.

The intersection of the probability of occurrence and the 

consequences provides the level of risk. In other words, 

something with a relatively large consequence could have a 

low level of risk if the probability of occurrence is low due to 

adequate and redundant engineering controls. Research 

laboratories tend to have lower event consequences than 

manufacturing facilities due to having lower quantities of 

materials. However, they also tend to have a larger number of

chemicals, so the probability of occurrence may increase due 

to the statistics of large numbers. Engineering controls (e.g., 

exhausted enclosures) help reduce the risk by lowering the 

event consequences and administrative controls (e.g., 

chemical reduction programs) help reduce the risk by lowering 

the probability of occurrence.

A generalized approach is used to assign values to both the 

probability of occurrence and the consequences of an event 

because specific data for formal fault-tree analysis is often 

difficult to obtain. Sometimes there is a conflict between 

protecting the safety of workers and protecting the 

environment. A similar methodology is used to strike the 

proper balance of risk between these cases.

Table 2. Checklists in the NREL ORR Documentation

Code Requirement Checklist

1.a HPM Gas Distribution Systems

1.b General Gas Requirements

2.a Pyrophoric Liquids and Solids Distribution

2.b Highly Toxic Liquid and Solid Distribution 

2.c Cryogenic Liquid Distribution 

3.a Reaction Vessels and/or Chambers

3.b Guarding

3.c Electrical Design

3.d Safety Interlocks

3.e Fire Protection

3.f Mechanical Design

3.g Automated Material Handlers (robotics)

3.h Lasers

4.a Effluent Removal Systems

5.a Safe Operating Procedures

5.b Required Documentation

5.c Warning Signs and Labels

5.d Emergency Shutdown

5.e Hazardous Energy Isolation

6.a Exhaust Systems

6.b Gas Cylinder Cabinets

6.c General Lab Readiness Issues

7.a Monitoring Room & Interlocks

7.b Hydride Gas Monitor

7.c Hydrogen Monitoring

7.d Corrosive Gas Monitoring

8.a Environmental Protection

9.a Operator Training

9.b General Ergonomics

9.c Seated Workstation Ergonomics

9.d Standing Workstation Ergonomics

9.e System Specific Requirements

III. SUMMARY

This process, although seemingly confining, has proven to 

be effective at brining HPM operations on line in a manner 

that reduces change orders and redesigns late in development 

and ensures the safe installation, operation, and disposal of 

HPMs.

This paper focused on acquiring new equipment through a 

rigorous process that ensures performance and safety without 

undue delays. However, there are additional EHS issues that 

arise from aging equipment and facilities. Quarterly safety 

inspections are performed to “put eyes on the equipment” to

ensure systems and practices put into place at tool installation 

are still in place. New risk analysis is performed in some cases 

as aging equipment raises the probability of failure. One area 

we are currently evaluating is necessary requirements for 
4

replacing specific HPM distribution components that have 

been in service for more than 10 years.

Fig. 1. Risk Assessment Matrix: Operations must receive 

engineering controls so they present Low or Moderate Risk.

Table 3. Event Probability Classification Table: 

Probability the event will occur in a given year.

Level Annual 

Probability

Description of the Probability Level

A Frequent 

(> 1.0)

Likely to occur many times during the 

life cycle of the system 

(test/activity/operation)

B Reasonably 

probable

(0.1 to 1.0)

Likely to occur several times during 

the life cycle of the system

C Occasional 

(0.01 to 0.1)

Likely to occur sometime during the 

life cycle of the system

D Remote 

(10-4 to 10-2)

Not likely to occur in the life cycle of 

the system, but possible

E Extremely 

remote 

(10-6 to 10-4)

Probability of occurrence cannot be 

distinguished from zero

F Improbable

(< 10-6)

Physically impossible to occur

Table 4. Hazard Consequence Classification Table

Category Description 

(Est. $ Lost)

Potential Consequences

I Catastrophic 

(equipment loss 

> $1,000,000)

May cause death or system loss

II Critical

($100,000 to 

$1,000,000) 

May cause severe injury or 

occupational illness, or minor 

system damage

III Marginal 

($10,000 to 

$100,000)

May cause minor injury or 

occupational illness, or minor 

system damage

IV Negligible 

(< $10,000)

Will not result in injury, 

occupational illness, or system 

damage

ACKNOWLEDGEMENT

This work was supported by the U.S Department of Energy 

under Contract No. DE-AC36-08GO28308 with the National 

Renewable Energy Laboratory.

REFERENCES

[1] SEMI Standards can be obtained from 

http://www.semi.org/en/store/P001204

[2] Editors, “The top ten most significant advances in 

materials science over the last 50 years,” Materials Today, 

Oxford, UK, December 18, 2007

[3] HPMs are defined as a solid, liquid, or gas that has a 

degree-of-hazard rating in health, flammability, or 

reactivity of Class 3 or 4 and that is used directly in 

research, laboratory, or production processes with 

nonhazardous end products.

[4] Moskowitz, P.D.; Fthenakis, V.M.; Crandall, R.S.; Nelson, 

B.P., “Analyzing risks associated with hazardous 

production materials,” Solid State Technology. 37(7), July 

1994; pp. 121–129. Acc No. 15942.