After the Licence: Obligations, Inspection, and Penalties
September 18, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The licence is where the obligations begin
A licence is not the end of the procedure but the start of it. Article 8 of the Law imposes six continuing obligations on the licensee, among them appointing a person responsible for radiation protection and writing a return clause into import contracts. Breach of this article carries a penalty stated in figures.
The six obligations
Two points are missed often enough to be worth stating separately. The plan does not take effect until it is approved: the second obligation is explicit that neither the plan nor the rules take effect until approved by the Council. A plan prepared and applied internally but never approved is not, in law, in force.
And the return clause is written at the time of purchase, not at the time of disposal. The sixth obligation requires the clause to be in the import contract. A facility that signed a contract without it later finds itself holding a disused source with nowhere to send it.
Law 31 of 2002, Article 8 - the licensee's obligations in applying the provisions of the Law
| # | The obligation |
|---|---|
| 1 | Observing the precautions necessary to ensure the safety of individuals and of those working with radiation, and the protection of the environment from the risks of radiation exposure, and complying with the instructions the Council lays down |
| 2 | Putting in place a detailed plan and internal rules for radiation protection for the licensed materials — and these do not take effect until approved by the Council |
| 3 | Providing all the technical equipment needed for radiation monitoring, dose measurement and personal protective equipment, proportionate to the nature of the work |
| 4 | Providing the technical and health services needed to protect workers and the public, and keeping the records the Council specifies |
| 5 | Appointing a person responsible for radiation protection, who is bound to implement the radiation protection rules and procedures when an incident occurs that exposes workers or the environment to radiation risks |
| 6 | Including in contracts for the import of radioactive materials or sources a clause requiring their return to the supplying party when the need for them ends |
Who counts as the responsible person
Article 1 of the Executive Regulation defines the radiation protection officer as the qualified technician appointed by the competent body or department, or by the employer, in the institutions and facilities that use radioactive sources, to supervise the application of the prescribed radiation protection systems and to assist in giving advice in that field.
The key phrase is the qualified technician. Appointment alone does not satisfy the definition; qualification is part of the definition itself.
Inspection: who, and with what power
The Regulation defines the radiation protection inspector as the person authorised by the Chairman, on the recommendation of the Secretary General, to carry out the inspection of the institutions and facilities that hold radioactive materials or sources or radiation devices, or that carry on work in the field of radiation in any form.
Article 16 of the Law grants these officers the status of judicial police officers, and provides that they have the authority to inspect all places carrying on an activity in the fields of radiation work, the right to enter all places where violations occur, to draw up seizure reports, and to take the legal measures prescribed in respect of them.
The penalties, in figures
Both penalty articles open with the same clause, and it changes how the figures below should be read: without prejudice to any more severe penalty provided for in the Penal Code or in any other law. What follows is what this Law provides. It is not a ceiling on what a court may impose where another law is harsher on the same conduct.
Article 10 doubles the penalty in two situations: on a repeat offence, and where the commission of the offence has caused a person any disease, impairment, or total or partial disability resulting from radiation exposure.
The same article then settles how a repeat offence is counted across different provisions: the offences under Articles 6, 8 and 9 are treated as equivalent to one another. So a facility penalised once under Article 8 and later under Article 6 is, for the purpose of doubling, a repeat offender - not a first offender under a different provision.
Law 31 of 2002, Articles 10 and 11
| The breach | The penalty as the text states it |
|---|---|
| Breach of Article 8 — the six obligations | Imprisonment for a period not exceeding one year and a fine not exceeding one hundred thousand riyals, or one of these two penalties |
| Breach of Articles 6 and 9 — working without a licence, and exceeding contamination limits | Imprisonment for a period not exceeding five years and a fine not exceeding two hundred thousand riyals, or one of these two penalties |
| Giving a false certificate, statement or incorrect report (Article 11) | Imprisonment for not less than one year and not more than three years, and a fine of not less than fifty thousand and not more than two hundred thousand riyals, or one of these two penalties |
Two administrative measures, separate from the criminal penalty
What the Council may do without a criminal case
Administrative seizure — Article 12
- Where radioactive materials, sources or radiation devices are imported, held or traded without a licence, the Council may seize them administratively and deposit them in the stores of the relevant body or any other place it considers suitable — and it may decide to return the imported material to its origin at the violator's expense.
Action at the licensee's expense — Article 13
- If the licensee does not take the necessary protective precautions, the Council may take the necessary measures at the licensee's expense.
Liability of the representative of a legal person — Article 14
- The representative of the legal person is punished as an accomplice to the principal offender, and is exempted if he proves that the offence occurred without his knowledge, against his will or to his detriment, or that he had delegated his competence to another and made reasonable efforts, without success, to prevent it.
Frequently asked questions
Is it enough to appoint a radiation protection officer by name?
The official definition requires a qualified technician. An administrative appointment without qualification does not meet the description given in the Regulation.
Our protection plan is written and applied — is that enough?
The second limb of Article 8 provides that neither the plan nor the rules take effect until approved by the Council.
We bought a source under a contract with no return clause — what now?
The sixth obligation requires the clause to be in the contract. Dealing with the position starts with reviewing the contract with the supplier, and the documentation is what is asked for at inspection.
Is the penalty doubled merely because an exposure occurred?
The text ties doubling to the commission of the offence resulting in a person suffering any illness, infirmity or total or partial disability arising from radiation exposure, and to repeat offence.
How the Institute can help
This series covers the compliance route from the beginning: whether you need a licence, which type, on which route and within what period, and what falls due once it is issued. The next instalment turns to Part Three of the Regulation — protection against occupational, medical and public exposures.
Related services: Radiation Protection Officer (RPO) training for the industrial sector and Radiation Safety Officer (RSO) training for the medical sector, preparation of the radiation protection programme, and radiological emergency plans.
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 this article does not replace the official text or advice from the competent authority. First published 18 September 2026; revised 19 September 2026 to add the opening clause of Articles 10 and 11 and the provision treating the offences under Articles 6, 8 and 9 as equivalent.