WhatsAppShort answer
Spills or releases of hazardous materials that may affect groundwater or the environment outside the plant boundary must be reported to the Royal Commission immediately, with a written report within one week. Spills involving hazardous materials during transport inside the city go immediately to RC's Industrial Security and Safety Department and to EPCD. If soil is contaminated, an investigation and remediation plan is due within 60 days of notification. Failing to report a hazardous material release carries a fine of 200,000 to 500,000 riyals.
Key terms used in this guide 4 terms
- Environmental Emergency Response Plan (EERP)
- The general operational emergency response plan every facility prepares and submits, covering the issues in section 4.3 of Volume I, particularly clause 4.3.19, and following the guidelines in Volume II, Appendix D. RCER-2025 Vol. I, 1.1.10, page 3
- Major upset
- An unscheduled occurrence or excursion of a process or operation that causes an emission breaching the regulations or standards and beyond immediate control, or a release initiated to protect life in immediate or adjacent areas. RCER-2025 Vol. I, Glossary, page x
- Soil contamination
- All activities or incidents that cause soil to exceed Table 6 of Volume I or the RC approved baseline data. RCER-2025 Vol. I, Glossary, page xi
- Third party
- A contractor selected on the basis of ability and absence of any conflict of interest. All environmental studies and field tests in RC cities, including EIA studies, stack and fugitive emission tests and baseline sampling, must be done by an RC approved independent third party. RCER-2025 Vol. I, Glossary, page xi, and 1.1.27, page 4
On this page
What counts as a reportable spill or release?
RCER-2025 sets several reporting duties that overlap:
- Spills or releases of hazardous materials in quantities that may affect groundwater or the environment outside the plant boundary.RCER-2025 Vol. I, 9.2.7
- Any emergency involving hazardous materials stored at the facility.RCER-2025 Vol. I, 4.3.21
- Upsets and emergencies that cause non-compliance, and other events such as fire, odour or noise.RCER-2025 Vol. I, 9.2.6
- Accidents, spills or discharges involving hazardous materials in transit within the industrial city.RCER-2025 Vol. I, 4.4.7
- Spill incidents during marine loading or unloading.RCER-2025 Vol. I, 3.10.4
Appendix G, the Environmental Event Notification, covers air, water, spill or leak and noise events and is used for reporting under clauses 9.2.6 and 9.2.7.RCER-2025 Vol. I, App. G
Who do you tell, and how fast?
Report to the Royal Commission immediately, then send a written report fully explaining the event within one week.RCER-2025 Vol. I, 9.2.7
Table 9A summarises upsets and emergencies as immediate notice, an event summary within 24 hours and a detailed report within one week. The 24 hour summary appears in Table 9A but not in the text of clause 9.2.6.RCER-2025 Vol. I, Table 9A
Who else must be told depends on where the spill happens:
- Hazardous material spill in transit inside the city: RC's Industrial Security and Safety Department (ISSD) and EPCD, immediately, with the location, substance and transporter name.RCER-2025 Vol. I, 4.4.7
- Spill in transit outside the city: the local authority, RC and the receiver.RCER-2025 Vol. I, 4.4.8
- Waste spill in transit: the transporter notifies RC, the generator and the receiving facility, plus the local authority outside the city.RCER-2025 Vol. I, 5.3.13
- Marine loading spill: RC and the relevant agencies.RCER-2025 Vol. I, 3.10.4
The Emergency Response Plan must include a hot-line list of authorities, and workers on site may not make public statements during an emergency.RCER-2025 Vol. II, App. D
What must the report contain?
The report under clause 9.2.7 must contain at least:RCER-2025 Vol. I, 9.2.7
- A description of the incident.RCER-2025 Vol. I, 9.2.7
- Its duration.RCER-2025 Vol. I, 9.2.7
- The estimated quantity and type of emissions, discharges or hazardous waste.RCER-2025 Vol. I, 9.2.7
- Actions to minimise releases.RCER-2025 Vol. I, 9.2.7
- Actions to clean up the releases.RCER-2025 Vol. I, 9.2.7
The Appendix G form also asks for the date and time, weather conditions, chemicals involved and measures to prevent a recurrence.RCER-2025 Vol. I, App. G
What happens after the first report?
Contain the spill, stop the source and reduce its spread straight away.RCER-2025 Vol. I, 6.2.4
For a transport spill, the facility cleans up, sends the material to an RC approved disposal facility and carries out an EIA or site risk assessment if RC requires one.RCER-2025 Vol. I, 4.4.7
If soil is contaminated, the follow-up runs on fixed deadlines:
- Plan to investigate, treat and rehabilitate the site: within 60 days of notification.RCER-2025 Vol. I, 6.3.1
- Investigation by an RC approved third party.RCER-2025 Vol. I, 6.3.2
- Detailed investigation report: within 60 days of finishing the investigation.RCER-2025 Vol. I, 6.3.4
- Remediation Execution Plan: within 30 days of finishing the investigation.RCER-2025 Vol. I, 6.4.2
- Remediation report: within 60 days of finishing the work.RCER-2025 Vol. I, 6.4.5
The remediation deadline is worded two ways. Clause 6.4.1 says within 180 days of the incident notification date, while clause 6.4.4 says within 180 days after RC approval.RCER-2025 Vol. I, 6.4.1
What are the fines?
Table 3.1 ranges for the main spill clauses, in riyals:RCER-2025 Vol. III, Table 3.1
| Cl. 9.2.7: hazardous material release reporting | 200,000 to 500,000 |
|---|---|
| Cl. 4.4.7: transit spill inside the city | 200,000 to 500,000 |
| Cl. 4.4.8: transit spill outside the city | 200,000 to 500,000 |
| Cl. 4.3.21: emergency notification | 120,000 to 180,000 |
| Cl. 3.10.4: marine loading spill | 120,000 to 180,000 |
| Cl. 9.2.6: potential non-compliance events | 10,000 to 500,000 |
| Cl. 6.2.4: immediate measures after an incident | 20,000 to 500,000, plus repair and compensation |
| Cl. 6.2.5: contamination not reported or falsified | 10,000 to 1.0 million |
| Cl. 6.4.1: remediation | 30,000 to 10 million |
Operators also pay the cost of all remedial measures on top of the fines.RCER-2025 Vol. III, 3.4
Self-reporting a violation and responding proactively multiplies the penalty by 0.75.RCER-2025 Vol. III, 3.2
Violations caused by natural causes, utility failures outside the operator's responsibility or hostilities are outside the penalty system.RCER-2025 Vol. III, 2.3.4
Table sourceRCER-2025 Vol. III, Table 3.1
What can go wrong?
Most spill penalties come from slow or incomplete reporting rather than from the spill itself:
- Waiting to see whether the spill is serious before calling RC. The duty is to report immediately, and late reporting can cost 200,000 to 500,000 riyals.RCER-2025 Vol. III, Table 3.1
- Forgetting the written report due within one week of the event.RCER-2025 Vol. I, 9.2.6
- Falsifying or withholding contamination data, which can reach 1.0 million riyals.RCER-2025 Vol. III, Table 3.1
- Assuming a contractor's spill is the contractor's problem. Facilities answer for the violations of their contractors and third parties.RCER-2025 Vol. III, 2.3.2
- Using an investigator who is not RC approved for soil contamination work.RCER-2025 Vol. I, 6.3.2
- Losing the 0.75 self-reporting factor by letting RC discover the incident first.RCER-2025 Vol. III, 3.2
- Missing the 60 day investigation plan deadline, which carries 50,000 to 110,000 riyals.RCER-2025 Vol. III, Table 3.1
Spill response checklist
A short sequence for the first week:
- Contain the spill and stop the source.RCER-2025 Vol. I, 6.2.4
- Notify RC immediately, and ISSD and EPCD for a transport spill inside the city.RCER-2025 Vol. I, 4.4.7
- Complete the Appendix G notification form.RCER-2025 Vol. I, App. G
- Send the written report within one week.RCER-2025 Vol. I, 9.2.7
- If soil is affected, appoint an RC approved third party and diary the 60 day plan deadline.RCER-2025 Vol. I, 6.3.1 and 6.3.2
Hills & Field helps you prepare the RC notification and one-week report, plans the site investigation and supports remediation through to RC acceptance.
References
Each small number in this guide shows the article or section that point comes from. Hover over or tap a number to see it, or open the full list below.
Show all 23 references and the 3 regulation texts
- RCER-2025 Vol. I, 9.2.7
- RCER-2025 Vol. I, 4.3.21
- RCER-2025 Vol. I, 9.2.6
- RCER-2025 Vol. I, 4.4.7
- RCER-2025 Vol. I, 3.10.4
- RCER-2025 Vol. I, App. G
- RCER-2025 Vol. I, Table 9A
- RCER-2025 Vol. I, 4.4.8
- RCER-2025 Vol. I, 5.3.13
- RCER-2025 Vol. II, App. D
- RCER-2025 Vol. I, 6.2.4
- RCER-2025 Vol. I, 6.3.1
- RCER-2025 Vol. I, 6.3.2
- RCER-2025 Vol. I, 6.3.4
- RCER-2025 Vol. I, 6.4.2
- RCER-2025 Vol. I, 6.4.5
- RCER-2025 Vol. I, 6.4.1
- RCER-2025 Vol. III, Table 3.1
- RCER-2025 Vol. III, 3.4
- RCER-2025 Vol. III, 3.2
- RCER-2025 Vol. III, 2.3.4
- RCER-2025 Vol. III, 2.3.2
- RCER-2025 Vol. I, 6.3.1 and 6.3.2
How to read these references 3 texts cited
- RCER-2025 Vol. I
- Royal Commission Environmental Regulations 2025, Volume I, Regulations and Standards
- RCER-2025 Vol. I, 1.3.6, page 6 means Volume I, clause 1.3.6, on printed page 6. All three volumes define a day as a working day.
The three RCER-2025 volumes are listed in the Royal Commission library.
Regulation texts this guide is written from
- Royal Commission Environmental Regulations 2025 (RCER-2025), Volume I, Regulations and Standards
- RCER-2025, Volume II, Environmental Permits and Licenses Program, Appendix D
- RCER-2025, Volume III, Penalty System and Service Charges
This guide is general information written from the regulation texts listed above. It is not legal advice. Regulations change, and the official text always prevails. Spotted something out of date? Request a change.