An apparatus comprising a non-volatile memory and a controller. The controller is coupled to the non-volatile memory and configured to (i) accumulate a read disturb count for a first region of the non-volatile memory, (ii) accumulate error statistics for a second region of the non-volatile memory, (iii) determine, based upon both the read disturb count and the error statistics, whether the first region has reached a read disturb limit, and (iv) in response to determining that the first region has reached the read disturb limit, relocate at least some data of the first region.