The inspector walks past the tower. He does not stop at the scaffold, the hoist or the shutter deck.
He stops at the generator.
There is a bowser parked tight against the canopy, a refuelling hose across the emergency access route, and a drip mark where a drip tray should be. Nobody put it there deliberately. The set went in clean, and it has been shuffled twice since by trades who needed the space.
That is the part most site teams learn the hard way. The arrangement that passed on Monday is not the arrangement standing on Thursday.
We deliver generator sets to Dubai sites and pick them up again, so we see both ends of this. Here is how a fuel setup observation actually gets closed.
What to do when DCD flags your generator fuel setup on a Dubai site
Make it safe first. Move the bowser and cabling off emergency access routes, restore containment under the tank, and stop refuelling until it runs under a permit. Then close the paperwork, submitting the trade licence copy, tank drawings and location map, application letter and inspection certificate to Dubai Civil Defence.
Work it in this order:
Separate the observation into physical items and documentary items. They move at completely different speeds.
Clear anything blocking fire access or egress, immediately. That is the item most likely to escalate.
Restore containment, so bund, drip trays and spill kit, before the next refuel.
Stop routine refuelling and bring it under the ignition source work permit.
Pull the tank drawings, capacity data and location details from your rental supplier’s file.
Submit the flammable liquid tank approval to DCD and book the inspection.
Physical items you can usually close the same day. Approvals you cannot rush, which is why the physical list goes first.
The document that gets quoted, DDA Circular 354
Most observation notes point back to one circular, so it is worth knowing what it says.
Circular 354, Fire Safety During Construction, was issued by the Dubai Development Authority on 13 May 2020. It makes consultants and contractors responsible for effective implementation of the UAE Fire and Life Safety Code of Practice during construction, modification, alteration and demolition works.
In plain terms it asks for the following.
- Fire risk assessments conducted and adhered to.
- Ignition sources, including hot work and electrical installations, equipment and works, carried out through a work permit procedure.
- The entire construction area marked as a No Smoking Area.
- Safe storage and handling of flammable and combustible material, away from ignition sources.
- Dubai Civil Defence approval obtained for bulk storage of flammable material.
- Safe fire access road for Civil Defence approach, means of egress for evacuation, fire detection and alarm systems, and fire protection systems.
On consequences it says only that failure to comply may lead to imposition of applicable sanctions and penalties. Anyone quoting you a specific fine figure from this circular is quoting something that is not in it.
Cite the construction chapter by its title
When you reference the code chapter in your close out response, call it “Fire and Safety Codes During Construction and Maintenance”.
Do not cite it by chapter number. The numbering differs between the 2011 and 2018 editions, and quoting a number from the wrong edition is an easy way to look like you have read neither. The 2018 edition is the current one.
For context, Federal Decree-Law No. 35 of 2024 addressed the Civil Defence Authority at federal level and Law No. 4 of 2025 established the Dubai Civil Defence General Command. Site level expectations have not loosened as a result.
The ten reasons DCD flags a site generator setup
Most of the observations we hear about come from the same short list.
Fuel and containment
Bulk diesel stored without DCD approval. Circular 354 requires DCD approval for bulk storage of flammable material. Fix by submitting the tank approval, and by not increasing storage on site while it is pending.
No secondary containment. A tank with nothing under it means any leak goes straight to ground. Fix with an integrally bunded or double wall tank, drip trays under connections, and a spill kit at the fuel point.
Fuel too close to ignition sources. Generator exhausts, hot work and site kitchens are all ignition sources. Fix by relocating the fuel store and re-marking the zone.
Procedure and people
No fire risk assessment, or a stale one. A site that has changed shape three times is not covered by the assessment written at mobilisation. Fix by reissuing it against the current layout.
Refuelling treated as routine work. It is an ignition source activity. Fix by bringing it under the work permit procedure with a named, trained person.
Smoking not controlled. The whole construction area is a No Smoking Area under the circular, not just the fuel bay. Fix with signage, a designated area outside the works, and supervision that enforces it.
Access, electrical and equipment
Emergency access or egress blocked. Generator, bund, bowser or cabling sitting on the fire route is the one item that escalates fastest. Fix immediately, before anything else on the list.
Trailing leads and unprotected distribution. Cables run across roads with no ramps, and boards without ELCB or RCD protection. Fix with ramps, IP rated boards and protected outgoing circuits.
Extinguishers missing or out of date. No fire point at the generator or the fuel point. Fix by fitting serviced extinguishers and marking the position.
Documentation gaps. No attested site plan, no tank drawings, no inspection certificate from an approved company. Fix by requesting the pack from your supplier, which is usually a same day request.
The DCD flammable liquid tank approval, and the four documents
Dubai Civil Defence approves tanks for flammable liquids and hazardous materials through its hazardous materials control service. Documents are submitted, the site plan is verified, and an inspection confirms the arrangement on the ground. Submission is online through the Dubai Civil Defence portal at dcd.gov.ae, and the published contact number is 800 997.
One thing to be clear about, because it is where teams argue in front of an inspector. Not every generator on a Dubai site sits behind a tank approval. The published trigger is bulk storage of flammable material, and where that line falls is set by your DCD submission and your main contractor, not by a figure somebody read on a blog. If nobody on the project can answer where it was drawn, that is the real finding.
Trade or industrial licence copy
Produced by the contractor or the applicant company. The simplest item on the list, and the one most often left until last — see our guide on what trade licence you need to rent equipment in the UAE if you are still confirming which one applies to your entity.
Tank drawings and location map
The drawings normally come from the rental supplier, since the supplier owns the tank and holds its technical data. The location map is site specific and comes from the contractor, showing where the tank sits relative to the works, the access roads and occupied areas.
Application letter
Written by the applicant company, describing the tank, the material stored and the site.
Inspection certificate from an approved company
The tank inspection certificate issued by an approved company. Ask your supplier whether the set going to your site is already covered, before it is loaded rather than after it is flagged.
Nobody publishes a processing time for this, so do not promise your client one. Get the documents right first time instead, because a returned submission costs far more than a careful hour.
What actually fixes it on site
Split the observation into what stops work and what is paperwork. Then close the first list today.
Containment and tank type
Integrally bunded or double wall tanks are the easy answer, because the containment travels with the tank instead of being built on site and forgotten. Canopy generators with a built in bunded base do the same for the set itself.
Add drip trays under the connections and couplings, since that is where the drips actually come from.
A bund sized to hold more than the tank’s full contents is standard main contractor expectation, usually written as a percentage above capacity. Treat it as good practice and confirm the figure against your project’s DCD submission and the current 2018 code rather than quoting it as a clause.
Position
Away from ignition sources. Away from occupied areas, accommodation and site offices. Off the emergency access route and off the means of egress.
On stable, level ground, with cabling in ramps rather than lying across a road where a low bed will run over it.
Separation distances are where numbers get repeated confidently and cited wrongly. Agree them with your consultant and your DCD submission for the specific site rather than lifting them from a generic article.
The fire and electrical package
A fire point at the generator and a second at the fuel point, with serviced extinguishers in date and the position marked. Type and quantity should follow your fire risk assessment and consultant direction rather than a rule of thumb.
Earth spike and earthing lead fitted and connected, not coiled in the toolbox. No smoking and warning signage on the enclosure and at the fuel bay.
Distribution boards IP rated for outdoor use, with ELCB or RCD protection on the outgoing circuits, and cable ramps wherever a lead crosses a route.
Refuelling as a controlled activity
Refuelling is where most of the risk actually sits, and it is usually the least controlled activity on the list.
Bring it under the ignition source work permit. Write the procedure down, name the trained person who does it, and do it with the set shut down unless the manufacturer’s instructions say otherwise.
If a bowser or tanker delivers fuel to your site, its documentation matters too. Transport of hazardous materials by vehicle involves testing and approval at the Warsan registration centre before a transportation permit card is issued. That applies to the vehicle, not to a static day tank, so do not let a supplier tell you a tanker approval covers your tank on the ground.
What the rental supplier should be doing, and what to ask for
A generator is not just the machine. Ask any supplier, ours included, for the following before the set is loaded.
Documents the supplier hands over
- Tank drawings and capacity data for the DCD submission.
- Location plan input, so the supplier tells you what the set actually needs around it.
- The tank inspection certificate from an approved company, where the supplier holds one.
- Service records for the set.
- Earth continuity and insulation test records.
If a supplier cannot produce these on request, that is your answer about how the next observation will go.
What arrives with the machine
The set should turn up as a package, not a bare machine with a delivery note. That means bunded base, extinguishers, earth spike and lead, spill kit, drip trays, signage, cable ramps and protected distribution.
It also means familiarisation on isolation, emergency stop and refuelling, given to the people who will actually operate it rather than whoever signed for delivery.
A set that arrives complete rarely gets flagged. A set that arrives bare gets completed by whoever is free that afternoon, which is how a bowser ends up on a fire route.
Who carries the responsibility
Circular 354 places implementation on the consultant and the contractor. That is the duty an inspector holds you to, and it does not transfer.
The supplier carries equipment condition, documentation and a safe delivery configuration. A hire agreement can put the supplier on the hook commercially for a missing bund or certificate, but it does not move the Circular 354 duty off the contractor.
Both sides own part of it. The contractor owns the arrangement on the ground and the submission. The supplier owns what rolls off the truck and the file behind it.
How this usually plays out on a Dubai site
A night shift fit out in a mall. The generator goes in on the first night, positioned correctly, bowser at a sensible distance, cables ramped.
Over the following nights it is moved twice, because a delivery needs the bay and then a scaffold gang needs the corner. Nobody re-checks the layout after the second move, and the bowser ends up on the fire route with the hose across it.
The observation is raised on a walk round. The cabling is re-routed and the bowser moved that same night, because physical items are fast.
The tank drawings and capacity data are pulled from the supplier’s file and sent through, and the documentary side is dealt with properly rather than at speed. That is the split worth remembering. Access and containment close in hours. Approvals do not.
What we check before a set leaves our yard
Bund intact and dry, no leaks at the connections. Extinguishers present and in date, not expired and hanging there for appearance.
Earthing lead in the machine and not in someone’s toolbox. Signage fitted before loading. Tank drawings and capacity data in the file, ready the day a contractor asks.
None of it is complicated. It just has to happen in the yard, because it never gets done properly on a live site at ten at night.
Frequently asked questions
Does a site generator need Dubai Civil Defence approval? Not automatically. DDA Circular 354 requires DCD approval for bulk storage of flammable material, so the question is whether your fuel arrangement counts as bulk storage on your project. That line is set by your DCD submission and your main contractor. Confirm it in writing before the set arrives, not after.
What documents does DCD require for a flammable liquid tank? A copy of the trade or industrial licence, the tank drawings, a location map, an application letter from the company, and a tank inspection certificate issued by an approved company. Documents go in, the site plan is verified, and an inspection follows. The published DCD contact number is 800 997.
How much diesel can be stored on a construction site in Dubai? There is no single figure worth repeating, and articles quoting one are usually quoting each other. The requirement is DCD approval for bulk storage, with the applicable limits and arrangements confirmed through your project submission and the current 2018 UAE Fire and Life Safety Code of Practice.
Who is responsible for the fuel setup, the contractor or the rental company? Both, in different ways. Circular 354 puts implementation on the consultant and contractor, and that duty does not transfer through a hire agreement. The supplier is responsible for equipment condition, documentation and delivering a safe configuration. Most disputes come from a supplier delivering a bare set.
What does DDA Circular 354 require during construction? Fire risk assessments, a work permit procedure for ignition sources including hot work and electrical works, the whole construction area marked No Smoking, safe storage of flammable material away from ignition sources, DCD approval for bulk flammable storage, and safe fire access, egress, detection and protection systems.
The bowser is not ours. Does that matter? Not to the inspector. What is on your site during your works is your arrangement to control, whatever the vehicle’s plates say. Hazmat vehicles carrying fuel are tested and approved through the Warsan registration centre before a transport permit card is issued, but that approval covers the vehicle, not your tank.
Talk to us before the next set is delivered
If you are reading this with an observation note in your hand, the fastest help is a supplier who can send the tank drawings and capacity data today.
If you are reading it before mobilisation, the better conversation is what arrives with the set. We hire generators to Dubai sites with the surrounding package rather than the bare machine, so bunded base, extinguishers, earthing, spill kit, drip trays, signage, cable ramps and protected distribution, plus the documents your DCD submission will ask for.
The same sites usually need boom lifts, scissor lifts, man lifts, forklifts, excavators and water tankers, and it is simpler when one supplier positions all of it around the same access routes.
Dream Way Equipment and Machinery Rental LLC Ras Al Khor Industrial Area 2, Dubai Phone: 056 857 8181 or 054 581 9331 WhatsApp: +971 56 857 8181 Email: info@dreamwayrental.com Available 24/7, including breakdown and mobilisation support
Send us the set size, the site location and your access constraints, and the document pack goes out before the truck does.