The Licensee's Ten Obligations in Qatar: Reporting and PPE
September 25, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
Ten obligations, in one article
Article 34 is headed The licensee's obligations in protecting against occupational exposures, and then does something the rest of the Regulation rarely does: it lists, in ten numbered items, what the licensee owes the people who work for him. Read as a list it looks administrative. Read as a claim someone may one day make against a facility, every item is a document that either exists or does not.
The first item is the one that costs money: the treatment, at the licensee's own expense, of persons exposed to radiation doses above the permitted limits the Council approves. The article then says who decides what that treatment is: the cases requiring examination and treatment are determined by a special medical committee formed by the Minister of Public Health at the request of the Secretary-General.
And it does not stop at treatment. Where a person suffers a radiation injury as a result of the licensee's negligence, or of his failure to observe the radiation protection rules, and that injury leads to total or partial disability or to death, the provisions of the Labour Law apply, without prejudice to the application of the other relevant laws. Negligence moves the matter out of the Regulation and into the Labour Law, with other laws left open on top of it.
Twenty hours, not twenty-four
Item 2 is the one to put on the wall. It requires the Council or the Civil Defence Department to be notified by telephone in the shortest possible time when an accident occurs, and then fixes the outer edge: that period must not exceed twenty hours from the occurrence of the accident. Twenty. The number people usually recite is twenty-four, and it is not what the text says.
The phone call is not the end of it: the telephone report must be followed by a written notification to the Council within a period not exceeding three days. Two steps, two deadlines, and the written one goes to the Council specifically.
What triggers the clock is wider than an injury. The text names four situations: an exposure that has caused, or may yet cause, a dose above the permitted dose limits; and then the loss of any source of ionising radiation, damage to it, or loss of control over it. A source that cannot be found on a Thursday afternoon starts the same twenty hours as a person who was overexposed.
The report must also carry content, not just notice: the details of the accident must be set out, and the causes that led to it stated. Details and causes. A facility that has never written that paragraph before will write it badly under pressure - which is the argument for a one-page form prepared in advance.
Article 34(2): what to do, to whom, and by when
| Step | To whom | Deadline in the text |
|---|---|---|
| Telephone report | The Council or the Civil Defence Department | In the shortest possible time, and not more than twenty hours from the accident |
| Written notification | The Council | Within a period not exceeding three days |
| What it must contain | Both steps | Details of the accident and the causes that led to it |
Two programmes, and a quiet veto
Items 4 to 7 build two standing programmes. The first is physical: a programme of physical supervision that determines the nature of the precautions to be taken to verify compliance with the dose-limitation instructions, assesses the effectiveness of the precautions taken, and determines the extent of the protective precautions required, in proportion to the scale of the hazards expected. The second is medical: a programme of medical supervision in the licensed institution, to assess the health of the workers in it.
Item 5 adds a duty that catches facilities out at the worst moment: any material change to the nature of the work, its place, its terms or the circumstances stated in the licence application must be reported to the Council at the earliest possible opportunity, and the facility's radiation protection programme amended accordingly. Moving a source to a new room is not an internal matter.
Item 8 is the veto: no worker may be employed, or kept in employment, in work involving exposure to ionising or non-ionising radiation in a manner contrary to the medical rules. It works in both directions - hiring and continuing - and it is the reason the medical file has to be readable by whoever makes staffing decisions, not filed somewhere no one opens.
Item 10 completes it by naming what the approved medical supervisor may ask for: the information he requests, including the details of the job description of any worker in the institution and his personal file. The doctor is entitled to the job description, not only to the dose reading.
Article 34, the ten items in short
What the licensee must do
- 1. Treat anyone exposed above the permitted limits, at his own expense; a special medical committee formed by the Minister of Public Health decides which cases need examination and treatment.
- 2. Report by telephone within twenty hours, and in writing within three days.
- 3. Put up warning signs, drawings or notices for the monitored areas, internationally recognised and in accordance with the Council's booklet, clearly and intelligibly, to show the scale and the nature of the exposure risk.
- 4. Establish a physical supervision programme proportionate to the expected hazards.
- 5. Review inspection and physical supervision periodically, and tell the Council of any material change to the work described in the licence application.
- 6. Establish a medical supervision programme, and provide the information needed in cases of accidents and occupational diseases.
- 7. Provide medical supervision on the general foundations of occupational medicine, taking account of past and present exposure to toxic chemicals and other hazardous physical conditions.
- 8. Not employ - or keep employing - a worker in radiation work in a way that breaches the medical rules.
- 9. Verify that the occupational medical examination is carried out periodically, and whenever injuries or occupational diseases occur.
- 10. Give the approved medical supervisor the conditions to do the work, including job descriptions and personal files.
Article 38: equipment, and the duty to need it less
Article 38 lists what must be provided: protective clothing, lead aprons, gloves, protective shields for the parts of the body, and the protective equipment used for monitoring. And it adds a condition that is often skipped: the workers must be told what protection those items provide. Handing over an apron is not compliance; telling the worker what that apron does and does not stop is.
Then comes the sentence that reverses the usual reading of protective equipment: the licensee must also keep reliance on personal protective equipment, for protection and safety purposes during normal operations, to a minimum, by providing well-designed controls and suitable working conditions. Personal equipment is the last line, not the first. In normal operation the Regulation wants the design and the working conditions to do the work - shielding, distance, layout, procedure - and the apron to matter less.
For an inspection this is a useful distinction to have thought about in advance. A facility that answers that it gives everyone an apron has answered the first half of Article 38 and left the second half unanswered.
Questions people actually ask
Is the accident report deadline twenty hours or twenty-four?
Twenty. Article 34(2) sets the telephone report at a period not exceeding twenty hours from the occurrence of the accident, followed by a written notification to the Council within three days.
Do we report a lost source even if nobody was exposed?
Yes. The article names the loss of a source, damage to it, and loss of control over it as separate triggers, alongside an exposure that has caused, or may yet cause, a dose above the limits.
Who pays for treatment after an overexposure?
The licensee, at his own expense in the words of item 1, with the cases that require examination and treatment determined by a special medical committee formed by the Minister of Public Health at the request of the Secretary-General.
We provide lead aprons. Is that enough for Article 38?
It is half of it. The article also requires workers to be told what protection the equipment gives, and requires reliance on personal equipment to be reduced to a minimum in normal operation through good design and suitable working conditions.
How the Institute can help
Most of Article 34 is documentation that either exists before an incident or is written under pressure after one. The Institute helps facilities in Qatar put the pieces in place while there is time.
That means: a written radiation protection programme covering physical and medical supervision, a one-page accident reporting form with the twenty-hour and three-day deadlines on it, a review of warning signage against the Council's booklet, and RPO and radiation worker training so the people on shift know what starts the clock.
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. Last updated 25 September 2026.