Do contractors in Royal Commission cities need their own environmental permit?

No separate environmental permit for contractors is defined in the three volumes. The construction-stage permit is the EPC, which the operator must obtain before starting any construction related to the process of a new facility.^{1RCER-2025 Vol. I, 1.2.1}

Process construction means construction in process areas. It excludes geotechnical surveys, fencing and non-process facilities.^{2RCER-2025 Vol. I, Glossary}

Instead of permitting contractors, RCER makes the facility answer for them. Facilities are responsible for the violations of their contractors and other third parties related to their contract.^{3RCER-2025 Vol. III, 2.3.2}

The EPC contains special conditions to be carried out during the construction period, and RC inspects the site periodically.^{4RCER-2025 Vol. II, 1.3.1}

A facility that breaches EPC conditions faces penalties, including revocation of the permit. Changes to EPC conditions are agreed with the facility in advance.^{5RCER-2025 Vol. I, 1.2.8}

Key construction-stage duties and their Table 3.1 ranges, in riyals:^{6RCER-2025 Vol. III, Table 3.1}

Construction dust must be kept below the Table 2A ambient standards for particulate matter.^{7RCER-2025 Vol. I, 2.3.9}

The facility. Besides the general rule in Volume III, facilities are responsible for their contractors' chemical handling and contaminated equipment handling, inside or outside the premises, related to the contract.^{8RCER-2025 Vol. I, 1.1.28}

That clause carries a fine of 50,000 to 110,000 riyals.^{6RCER-2025 Vol. III, Table 3.1}

The facility, as waste generator, declares all wastes expected during construction and operation in form PA-H2.^{9RCER-2025 Vol. I, 5.1.8}

Maintenance contractors hired for clean-ups, shutdowns, turnarounds or emergencies may do maintenance work only. They may not carry out waste management or recycling.^{10RCER-2025 Vol. I, 5.1.9}

Waste produced on site by a maintenance contractor is the generator's responsibility, and the generator is liable for any illegal transport, disposal or recycling.^{11RCER-2025 Vol. I, 5.1.10}

Each of clauses 5.1.9 and 5.1.10 carries a fine of 200,000 to 500,000 riyals.^{6RCER-2025 Vol. III, Table 3.1}

Construction debris and demolition waste must be removed regularly to the designated disposal area and not allowed to build up.^{12RCER-2025 Vol. I, 5.7.3}

A few contractor roles do need their own authorisation:

Clause 5.4.20 refers to Volume II, Appendix F for the asbestos procedures, while the asbestos guideline appears in Volume II as Appendix I.^{15RCER-2025 Vol. I, 5.4.20}

Transporting waste without RC authorisation and breaching the asbestos clause each carry 200,000 to 500,000 riyals.^{6RCER-2025 Vol. III, Table 3.1}

Yes. No person, facility, agency or contractor may operate equipment that exceeds the Table 8 noise standards at their boundary fence.^{18RCER-2025 Vol. I, 8.2.1}

Noise is measured outside the fence next to the source, or in public areas.^{19RCER-2025 Vol. I, 8.1.1}

The Table 8 L10 limits are:^{20RCER-2025 Vol. I, Table 8}

A boundary exceedance carries a fine of 5,000 to 10,000 riyals.^{6RCER-2025 Vol. III, Table 3.1}

First Category facilities submit an Environmental Management Plan following Appendix O, together with the screening questionnaire.^{4RCER-2025 Vol. II, 1.3.1}

Appendix O asks for a table of construction and installation activities, each with its potential environmental risk and the controls to prevent or reduce it. The example given is site grading with dust controlled by regular water spray.^{21RCER-2025 Vol. II, App. O, Table 3}

For Second and Third Category facilities, the EIA's environmental management and monitoring plan must cover the management of construction impacts.^{22RCER-2025 Vol. II, App. C}

RCER-2025 does not use the term CEMP. In practice the EPC conditions and these plans are the documents your contractors should work to.

These are the contractor issues that most often end up as fines for the facility: