A Damaged Dosimeter in Qatar: Three Methods in Article 5

Three methods, not one

If a worker's dosimeter is damaged, the text sets three methods for estimating what went unmeasured.

They sit in article 5 of the instructions issued by Decision 2 of 2005, in three numbered items.

The first computes a limit for the period in which the dosimeter was damaged and adds it to the replacement reading.

The second adopts the reading of the other dosimeter for a worker carrying an additional one.

The third refers to the records showing the exposure levels for the worker or for others in similar conditions.

Why this situation needs a text at all

A dosimeter is a personal device the worker carries, and in practice it is read periodically by an approved dosimetry service.

That describes practice rather than anything stated in article 5.

If it is damaged the record breaks, and a period is left without a figure.

Our reading is that the text provides a written method so that filling the gap is not left to the judgement of each facility.

That is our reading, not a purpose article 5 states.

The first method and its unnamed limit

The first item provides that where a dosimeter is damaged, the highest internationally permitted dose limit for the period in which it was damaged is computed, and the result is added to the reading of the replacement dosimeter given to that worker.

The computation has two steps: computing a limit for the period, then adding it to the replacement reading.

The text calls what is computed the highest internationally permitted dose limit and does not name its amount.

So we do not describe it as the most the worker could have received in that period.

The text refers here to no particular document.

So we write no figure for it, and we do not say it equals one of the limits in article 4.

We see that as an open point in the text, and it is for the licensee and its competent authority.

The second and third methods

The second item provides that the reading of the other dosimeter is adopted for a worker carrying an additional one, where one of the two is damaged.

The test is that the worker was already carrying two dosimeters, not that one is issued after the damage.

The text does not require an additional dosimeter to be carried; it states the rule for whoever carries one.

The third item provides that reference is made to the records showing the radiation exposure levels for the worker, or for others working in similar working conditions.

The reference point is the worker's own record or that of others in similar conditions.

The word the item uses there carries no stated unit, so we do not read it as a dose per unit of time.

The text states no binding order among the three methods and no condition giving one priority.

What is estimated and why

The estimate in this article fills a period that has no direct reading.

It does not replace measurement; it is a procedure for when measurement is not possible.

The difference between the two is written in the record, and an estimate is marked as an estimate.

This is our reading of practice, since the article does not mention the form of the record.

The three items differ in the source of the estimate rather than in its purpose.

The source of the first is a limit computed for the period added to the replacement dosimeter reading, and of the second the other dosimeter reading.

The third is an earlier record of the worker or of others in similar conditions.

Not naming the item relied on leaves a figure with no basis.

Four points left as they stand

First: the article names no body whose reading is adopted, and does not mention a dosimetry service in its wording.

Second: the article states no period for the estimate and no deadline for entering it in the record.

Third: the article does not say what is done with the damaged dosimeter itself.

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

Where the text is silent we build neither a duty nor an exemption.

A worked case: a dosimeter damaged mid-cycle

A worker's dosimeter is damaged in the middle of a reading cycle, and a replacement is issued for the rest of it.

The first method computes a limit for the period in which it was damaged, then adds it to the replacement reading.

We write no figure here, because the text does not name the amount of that limit.

If the worker was carrying a sound additional dosimeter, the second item is closer to their situation.

If not, the third item refers to the records.

The case is assumed for the example, the reading is ours, and it is the licensee who decides it.

Four practical steps

The local procedure sets out what happens the moment a damaged dosimeter is reported.

The period in which the dosimeter was damaged is recorded with its start and end dates.

The applicable item is chosen and the reason for choosing it is written down, since there are three items and not one.

The estimate is entered in the dose record, marked as an estimate rather than a direct reading.

The licensee and its radiation protection officer do this. That is what we train for, not what we do.

What to review after the estimate

A check is made that the estimate was entered in the worker dose record.

Article 5 states no year and no annual average, and anything beyond that is our reading of practice.

A check is made that the basis of the estimate is written down: article 5 of the instructions issued by Decision 2 of 2005 and the item applied.

A check is made that the limit computed for the period was added to the replacement dosimeter reading as the first item requires.

And that both parts of the sum are shown in the record alongside the total.

This is our reading of practice; the article sets the method and does not set the form of the record.

What the worker is told

The worker is told that a period was estimated, and under which item.

They are not told that their dose is safe or that it has exceeded a limit.

Their reference point for their official record is the radiation protection officer at the licensee.

We do not build on the article any worker entitlement it does not state.

What is the highest internationally permitted limit?

The text does not name its amount, and we see that as an open point in the text.

We write no figure for it and do not infer it from a limit in article 4.

Are the three methods ranked in priority?

The text states no binding order among them and no condition giving one priority.

Each of the first two items states a situation in its wording, at the opening of the first and at the end of the second, so each item is read against the situation that fits.

Does every worker need an additional dosimeter?

The item imposes no such duty; it states the rule for whoever carries one.

We build neither a duty nor an exemption on its silence.

May the estimate come from a colleague in another department?

The item speaks of those working in similar working conditions, so the test is similar conditions rather than the department.

Judging that similarity is our reading, and the text sets no criterion for it.

Does the article penalise damaging a dosimeter?

These instructions contain no penalty and no compliance period.

The article sets the method of estimation rather than a judgement on anyone.

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.

In our transcribed file one word in the second item carries a doubled mark. That is orthography rather than wording, and we build nothing on it.

Another page on this site covers individual monitoring dosimeters: /blog/individual-monitoring-dosimeters-qatar

A third page covers the types of dosimeter: /blog/tld-osl-electronic-dosimeters

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 5, 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 estimate the dose for a period in which a dosimeter was damaged, and we adopt no replacement reading. 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.