Guidance Levels, Records and Medical Examinations in Qatar
September 27, 2026
11 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
Three articles that answer three different questions
These three do not sit next to each other in the Regulation, and that is why they are read together here. Article 48 answers what must be kept. Article 51 answers what the numbers are compared against. Article 52 answers a question the other two never raise: whether the examination should have been done at all, when the person in front of the machine is not a patient with a complaint but an applicant, an employee, or a woman who may be pregnant.
Article 52 is also the heaviest of the three. It carries the only express sanction in this chapter of the Regulation, and the sanction is the licence itself.
Article 48: four categories, and a period given in words not years
Article 48 opens by requiring the licensee to keep and make available, for a period the Council determines, records containing the items that follow. Two verbs again - keep, and make available. And then the detail that matters most and is quoted wrongly most often: the period is the one the Council determines. No number of years appears in this article.
This is worth stating plainly because the occupational side of the same Regulation does give a figure. Article 35, on occupational records, says they are kept for not less than thirty years. A hospital that assumes the thirty years of Article 35 also governs its medical exposure records under Article 48 has imported a number the article does not contain - which may be safe in practice, but is not what the text says, and the Council's determination is what governs.
The four categories split by modality. Diagnostic radiology: the information necessary to allow the dose assessment to be retrieved, including the number of exposures and the duration of fluoroscopic examinations. Note what is singled out - fluoroscopy time. Nuclear medicine: the types of radiopharmaceuticals used and their activities.
Radiotherapy gets the longest item: a description of the planned treatment volume, the dose delivered to the centre of that volume, the maximum and minimum doses delivered to it, the doses delivered to other relevant organs, the fractionation of the dose, and the total treatment time. And the fourth category is the one departments forget entirely: the exposure of volunteers in medical research.
Article 51: the level you may fall below, not only exceed
Article 51 requires the licensee to set guidance levels for medical exposure, such as those adopted in IAEA Safety Series No. 115, to revise them in line with technological developments, and to have medical practitioners use them for guidance. That reference is the only figure in the article, and it is a document number, not a dose.
Then comes the item that reverses what most people assume a guidance level is for. Item 1 requires corrective action where the doses or activities fall far below the guidance levels and the exposures provide no useful diagnostic information and do not achieve the intended medical benefit for patients. Far below the level, with a useless image, is a fault to be corrected - because the patient took a dose and got nothing for it.
Item 2 handles the direction everyone expects: the licensee is to consider carrying out reviews where the doses or activities exceed the guidance levels, to the extent needed to achieve optimal patient protection and to maintain levels appropriate to good practice. Note the verb: consider carrying out reviews. Exceeding a guidance level is not in itself a breach; failing to look into it is.
Item 3 says where the levels come from, and it rules out picking a number off a poster. For diagnostic radiology including computed tomography, and for nuclear medicine, the guidance levels are derived from data drawn from wide-scale quality surveys - covering entrance surface doses, the cross-sectional dimensions of the beams emitted by each individual device, and the activities of the radiopharmaceuticals given to patients - for the most frequent examinations in each field. Per device, for the commonest examinations.
Article 52: the examination that can cost the licence
Article 52 governs examinations done not because a patient is ill, but because a job, a post or a procedure calls for them. The opening is a prohibition, not a permission: no licensed authority or body may carry out a diagnosis, treatment or examination for the purposes of a job or work that involves radiation exposure, except where no other technique or means of examination is available, or where it would produce positive results of real benefit to the person treated in that way.
The article then adds the optimisation test in its own words: the radiation dose is to be as low as reasonably achievable within the economic, social and technical means available.
The second paragraph is the one that carries a penalty. When examining women, the practitioner must first verify whether or not there is a pregnancy; where pregnancy is established, whatever its stage, he must not carry out radiological examinations, unless there is a pressing necessity decided by the treating specialist and no alternative method is available - and a breach of that may lead to cancellation of the licence. Four conditions, and a consequence.
The third paragraph covers routine periodic screening with no clinical referral: the licensee must, from time to time, assess the information the examinations have produced, so as to rely on it in determining the method of treatment, or modifying it, or stopping the examination in the interest of that person. Stopping is one of the three permitted outcomes, named in the text.
The fourth paragraph puts mass screening behind a gate that is not the hospital's to open. The licensees must take into account whether the benefits of the screening outweigh its harms, and such screening may not be carried out except with the approval of the Secretary General, on the recommendation of the Committee and in accordance with the conditions and restrictions it lays down, including limiting the screening to a defined group of people. A campaign planned by a clinic and announced to the public without that approval is outside the Regulation.
The three articles side by side
| Article | What it governs | The point most often missed |
|---|---|---|
| 48 | The records a medical licensee keeps and makes available, in four categories | The period is the one the Council determines - no number of years appears in the article |
| 51 | Guidance levels for medical exposure, derived per device from wide-scale quality surveys | Doses far BELOW the level, with no useful image, require corrective action too |
| 52 | Examinations for employment or work, pregnancy, routine screening, and mass screening | Cancellation of the licence may follow irradiating a pregnant woman without pressing necessity |
Questions people actually ask
How many years must we keep medical exposure records?
Article 48 does not say. It says the records are kept for a period the Council determines. The thirty-year figure that appears elsewhere in the Regulation belongs to Article 35, which is about occupational records for workers, not medical exposure records for patients. The period for Article 48 is a question for the Council, and a facility should hold its determination in writing.
Is exceeding a guidance level a violation?
Not in itself. Item 2 of Article 51 asks the licensee to consider carrying out reviews when doses exceed the guidance levels, to the extent needed for optimal patient protection and good practice. What the article does not tolerate is exceeding the level and doing nothing about it. And note the mirror duty in item 1: doses far below the level, producing no useful diagnostic information, require corrective action as well.
Can we x-ray a pregnant woman at all?
Article 52 says the practitioner must first verify whether there is a pregnancy, and if pregnancy is established - whatever its stage - must not carry out the radiological examinations, unless there is a pressing necessity decided by the treating specialist and no alternative method is available. The article then adds that a breach may lead to cancellation of the licence. So: possible, but only on those conditions, and the decision belongs to the treating specialist and should be recorded.
We want to run a free screening campaign. What do we need?
Article 52 requires two things. First, that the licensees weigh whether the benefits of the screening outweigh its harms. Second, and this is the gate: the screening may not be carried out except with the approval of the Secretary General, on the recommendation of the Committee, and on the conditions and restrictions it lays down - including limiting the screening to a defined group of people. Plan the approval before the campaign, not after.
How the Institute can help
Of the three, Article 52 is the one that reaches beyond the radiology department: it touches occupational health, pre-employment testing, and any screening campaign the organisation runs. Reading it before a campaign is planned costs nothing; reading it afterwards can cost the licence.
Advanced radiation protection training for the RPO / RSO in the medical sector, briefings for occupational health and HR teams on what Article 52 allows and forbids, and a review of the records a department keeps against the four categories of Article 48.
Scope of what the Institute does: training and consulting. Field radiation surveys are carried out through specialist partners working in the field. The Institute does not carry out laboratory analysis, instrument calibration or equipment testing.
This explanation is published for awareness by the radiation protection team at ALDuha Institute for Training and Environmental Consulting. The English text is an explanation, not a certified translation: the Arabic text published in the Official Gazette governs in case of any difference, and the official Arabic wording of every article discussed here is quoted in full on the Arabic version of this article. This article does not replace the official text or advice from the competent authority. Last updated 27 September 2026. Reviewed by Dr. Said Kaddouch, PhD in Medical Physics, radiation protection expert.