Medical Exposure in Qatar: Responsibility and Justification
September 26, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting

The patient is not covered by a dose limit - and that is the point
Everything in the occupational section of this series rests on limits: an area classification, a dosimeter, a figure not to exceed. The medical section starts somewhere else. A patient receives a dose deliberately, for his own benefit, and no numeric limit applies to it. What controls it instead is a chain of responsibility and a test called justification.
Article 39 is headed Responsibilities, and it opens by telling the licensee to satisfy himself of what follows. Note the verb: the licensee - the hospital, the clinic, the centre - has to satisfy himself. The first item is the gate: no patient may be given a medical radiation exposure for diagnosis or treatment unless a medical practitioner has prescribed that exposure.
Items 2 and 3 then bind the practitioner. Item 2 requires the medical practitioner to achieve full protection and safety for patients both when prescribing a medical radiation exposure and while it is being carried out. Item 3 requires him to satisfy himself that the medical exposure of patients is the minimum necessary to achieve the required diagnostic aim. Minimum necessary to reach the diagnostic aim - that sentence is the whole of optimisation in a clinical setting.
Two experts the article names, and the report nobody wants to write
Items 6 and 7 are where hospitals find an obligation they did not know they had. For therapy, item 6 requires the requirements for calibration, dosimetry and quality assurance to be set by a qualified expert in medical physics, or under his supervision, wherever radiation is used therapeutically - including external beam therapy and brachytherapy.
For diagnosis the requirement is lighter in form but still named: item 7 requires the requirements for radiographic imaging and quality assurance to be carried out on the advice of a qualified expert in either diagnostic radiology physics or nuclear medicine physics, as the case requires. Therapy needs the medical physicist to set the requirements or supervise them; diagnosis needs his advice.
Item 8 closes the loop in the direction people forget - upwards. The medical practitioner must notify the registrant or the licensee of any shortcoming or need relating to compliance with radiation protection standards, so far as the protection and safety of patients is concerned, and of what must be done to secure that protection. A radiologist who knows a machine is drifting is not merely entitled to say so; the Regulation puts it on him.
Article 39: the eight things the licensee must satisfy himself of
In the words of the text, in short
- No patient is exposed for diagnosis or treatment unless a medical practitioner prescribed it.
- The practitioner is bound to achieve overall protection and safety for patients, when prescribing and while carrying out.
- The exposure is the minimum necessary to achieve the required diagnostic aim.
- Suitable equipment and devices are used.
- Medical staff and their assistants are provided as needed, either qualified health professionals or sufficiently trained.
- Calibration, dosimetry and quality assurance for therapy are set by, or under the supervision of, a qualified medical physics expert.
- For imaging, the requirements and quality assurance are carried out on the advice of a qualified expert in diagnostic radiology physics or nuclear medicine physics.
- The practitioner notifies the registrant or licensee of any shortfall or need relating to compliance with radiation protection standards for patients.
Article 40: the test, and the three things it rules out
Article 40 states the test in one sentence: medical radiation exposures must be justified by weighing the diagnostic or therapeutic benefits they produce against the radiation harm they may cause, taking into account the benefits and risks of the available alternative techniques that involve no radiation exposure. Benefit against harm - and against the alternatives that use no radiation at all. An ultrasound that would answer the question is part of the test, not a separate conversation.
Then four qualifications. The first points outward, to the relevant guiding principles, such as those laid down by the World Health Organization. The second has the sharpest edge in daily practice: no radiological examination may be carried out for occupational, legal or health-insurance purposes, irrespective of clinical purpose, unless it has been established that it will yield useful information about the health of the individual being examined.
Read that against the routine chest film ordered for a work permit or an insurance file. The Regulation does not forbid it outright - it requires someone to have established that it yields useful information about that person's health. If it does not, the exposure has no justification under Article 40.
The third qualification governs mass screening: no intensive radiological screening of population groups may be carried out unless the expected benefits, for the individuals screened or for the population as a whole, are sufficient to offset the economic and social costs, including the radiation harm of that screening. The fourth covers medical research and points to the Declaration of Helsinki and to the guidance issued by CIOMS and the World Health Organization, plus any national medical body the Council designates.
Questions people actually ask
Is there a dose limit for patients in Qatar?
No. Dose limits do not apply to medical exposures from a licensed practice; the controls are justification under Article 40 and keeping the exposure to the minimum necessary for the diagnostic aim under Article 39(3).
Can we X-ray an employee for a work permit or an insurance file?
Only if it has been established that the examination provides useful information about that individual's health. Article 40(2) names occupational, legal and health insurance purposes specifically.
Do we need a medical physicist?
For therapy, yes in substance: calibration, dosimetry and quality assurance must be set by a qualified medical physics expert or under his supervision. For imaging, the requirements and quality assurance are carried out on the advice of a qualified expert in diagnostic radiology or nuclear medicine physics.
Who decides that an examination is justified - the referring doctor or the radiologist?
The Regulation requires a medical practitioner to prescribe the exposure, and puts protection and safety on the practitioner both when prescribing and while carrying it out. In practice the two roles share it, and the article gives the practitioner a duty to report shortfalls upwards.
How the Institute can help
The medical section of the Regulation is written around roles: a practitioner who prescribes, a physicist who sets the physics, and a licensee who has to satisfy himself that both are in place.
The Institute trains the Radiation Safety Officer for the medical sector (RSO), and supports hospitals and clinics on the paperwork side of Articles 39 and 40: written referral and justification criteria, a quality assurance file, and the notification route that Article 39(8) requires.
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 25 September 2026. Reviewed by Dr. Said Kaddouch, PhD in Medical Physics, radiation protection expert.
