Excess or Abnormal Exposure in Qatar: The Article 6 Procedures

Three procedures when a reading is excessive or abnormal

Where excess or abnormal exposure appears in personal dose measurement, the text sets three procedures.

The opening of article 6 provides that the following procedures are followed in order to take the appropriate decision on the matter.

The first draws on the readings of colleagues' dosimeters in the same radiation conditions, with the time factor.

The second draws on the fixed area monitors distributed in the work area, with average working hours.

The third is for the case where the excess dose is confirmed, and it carries removal, examination and notification.

Why the reading is checked before any decision

A single high reading may come from damage to the dosimeter, or from leaving it in the work area away from its wearer.

Or from wearing it incorrectly. That is our reading of practice; the article states no cause.

The first two items compare the reading against two other sources before any decision is built on it.

The third item is by its wording conditioned on confirmation, not merely on the figure appearing.

The text states no binding order among the three items.

Our reading is that the comparison comes before confirmation, and the article states no order between the two.

The first item and its stated computation

The first item provides that use is made of the readings of the dosimeters carried by workers in the same radiation conditions.

It then sets the computation: the average dose is worked out by adding the individual doses and dividing the total by the number of workers.

What the item means by the average dose is an arithmetic average of the workers' doses rather than a dose per unit of time.

It then imposes a condition on that computation: the time the worker concerned spends on radiation work compared with their colleagues must be taken into account.

The average alone is not enough, and the time factor is a stated condition rather than something we add.

Dropping the time factor treats someone who spent an hour and someone who spent a day alike.

The second and third items

The second item provides that use is made of the fixed area monitors distributed in the work area where the worker was working, taking average working hours into account.

Its reference point is the place rather than people, and its condition is average working hours.

Fixed area monitors watch the place rather than the person, so the time the worker spends there is needed before any estimate for that worker is read from them.

The item attaches average working hours to them. This is our reading of how the item is built; the text gives no reason.

The third item provides that where it is confirmed that the worker received an excess dose, they are immediately removed from radiation work, the necessary medical examinations are carried out, and the Council is notified.

The three verbs in this item are put in the passive, and the item names no one to carry them out.

The word immediately in the text attaches to the removal, and the text states no period for the notification.

The item calls for the necessary medical examinations, and the text names no particular examination and no body to carry them out.

Four points left as they stand

First: the article does not define excess or abnormal exposure and sets no numerical threshold for it.

Second: the article does not say who decides that the matter is confirmed, or how that is documented.

Third: the article states no period for the notification and no form for it.

We carry no notification period over from another text, and we do not deny that one exists there.

Fourth: the article does not say when the worker returns to radiation work after removal.

And the six articles of these instructions contain no penalty and no compliance period.

What the article does not create

The article creates no committee and names no one to review the case.

It mentions no form for an incident file and no retention period for it.

What we have said about a file and documentation is our reading of practice.

We build neither a duty nor an exemption on the article's silence.

The article sets the source of the comparison and sets no particular tool for the computation.

A worked case: an average with assumed figures

Four colleagues of the worker concerned are in the same radiation conditions, and their assumed doses in the period are 2, 3, 2 and 3 mSv.

The reading of the worker concerned, the one under review, is not in that total, and drawing that distinction is our reading of the item's wording.

Their total is ten millisieverts, and dividing by four gives two and a half millisieverts.

The four are the count of those whose doses were summed.

The time factor is then taken into account: someone who spent twice what their colleagues spent is not measured by the average alone.

The figures here are assumed for the example, and the computation follows the item's method rather than any figure in it.

The text sets the method and gives no example, and this is our reading with figures we declare.

Judging an actual case rests with the licensee and its competent authority.

Four practical steps

The local procedure sets out what happens the moment an excess or abnormal reading appears.

The readings of workers in the same conditions are collected and the average is worked out by the stated method.

The time factor for each of them is written down, since the condition is stated in the item.

The fixed area monitors in the work area are read and the average working hours are written down.

The radiation protection officer at the licensee leads all of this. That is what we train for, not what we do.

What is required once it is confirmed

Once it is confirmed that the worker received an excess dose, the worker is immediately removed from radiation work under the item.

The item is in the passive and names no one to carry the removal out.

The necessary medical examinations are carried out, and the text names no particular examination and no body to carry them out.

We carry out no examination, refer no one to a doctor, and assess no one's condition.

The item requires the Council to be notified, and the body today is the Ministry of Environment and Climate Change.

A file is kept for the incident holding the readings, the computation, and the basis of the decision.

That is our reading of practice; the article mentions no incident file and no retention period.

What counts as excess exposure under the article?

The article does not define it and sets no numerical threshold, and we see that as an open point in the text.

Dose limits sit in article 4, and we do not assemble a definition for this article out of them.

Is the colleagues' average enough on its own?

No. The average is an input, and the item requires the time the worker concerned spends compared with their colleagues to be taken into account.

When is the case notified?

Notification is stated in the third item upon confirmation, and the text states no period for it.

The word immediately attaches to the removal rather than the notification, and we carry no period over from another text.

Does the worker return to the job after removal?

The article does not mention a return or its conditions, and we build no ruling on its silence.

That decision rests with the licensee and its competent authority.

Does the article penalise an excess exposure?

These instructions contain no penalty and no compliance period.

The article sets a procedure for taking the appropriate decision rather than a punishment.

How we cite and transcribe

Article numbering restarts after the two enacting articles, so we say article 4 of the instructions issued by Decision 2 of 2005.

The Decision was issued on the basis of Law 31 of 2002 on radiation protection. Its basis also includes the executive regulation of that Law issued by Decision 4 of 2003, and the recommendation of the radiation protection committee.

The figures on this page come from the national text alone, and we build no ruling on an international standard.

Where a body is named in the wording we transcribe, the name is the one in force when the Decision was issued. The competent body today is the Ministry of Environment and Climate Change, Radiation Protection Department.

In our transcribed file the third item spells one word of the body's name in a non-standard form, and we reproduce it as it stands.

Another page on this site covers workplace monitoring: /blog/radiation-workplace-monitoring-qatar

The articles of these instructions do not name the radiation protection officer. What we say of that role describes practice rather than wording in these articles.

What we do and what we do not

ALDuha Institute for Training and Environmental Consulting is a training and consulting provider. The training is licensed.

We do not measure a dose, issue dosimeters, read a dosimeter, or calibrate one.

We do not carry out medical examinations, assess an individual exposure, or issue a worker dose record.

Who carries the duty

Monitoring and tracking exposure is the duty of the licensee, its radiation protection officer, and the approved dosimetry service.

That allocation describes practice rather than the wording of article 6, which is written in the passive and names no duty holder.

We do not measure on a facility's behalf, nor through anyone else, and we do not contract to read its workers' dosimeters.

The licensee turns to specialist partners where needed, and chooses the approved dosimetry service itself.

We give no promise that a licence will be issued, and no promise of a timeframe.

How to read the figures here

What is published here explains a binding text, and any figure in it is a general regulatory limit.

It is not a reading of anyone's dose, an assessment of their situation, or permission to carry on working.

An individual's reference point is the radiation protection officer at the licensee and their official dose record.

Failing that, the regulator: the Ministry of Environment and Climate Change, Radiation Protection Department.

We do not decide that an exposure is excessive, carry out an examination, or notify the authority on a facility's behalf. We train people to read the three items.

Notice

This is an introductory explanation of a published text. It is not a legal opinion, and it does not replace consulting the competent authority.