Non-Specialist Doctors: Radiation Licence Conditions in Qatar
October 11, 2026
13 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The entry that describes a doctor by what his work requires
One point before anything else. Meeting the conditions in the Decision is what you can prepare for. Whether a licence is granted, and when, is a decision of the competent authority alone, and nothing in this explanation and nothing in any course is a commitment that a licence will be issued or that it will be issued within a given period. What this article does is set out the conditions as the instrument states them and point to the training that bears on them.
Medical item 7 of the schedule attached to Decision 4 of 2007 is the entry for the doctors who use radiation without being doctors of radiation: the surgeon at a mobile imaging unit in theatre, the cardiologist in a catheter laboratory, the physician who screens at the bedside. Its heading describes them twice over, as non-specialists in the field of radiology and as doctors whose work requires work with radiation, and that double description is the whole of how the entry picks out its group.
This entry is the one most often skipped in the files we review, and the reason is structural rather than careless. A radiology department knows it is a radiation department. A theatre list, a catheter laboratory and a ward round do not describe themselves that way, so the person who assembles the licence files for the imaging department has no reason to be looking at them, and the doctor who uses the equipment for twenty minutes a week is not the person who reads schedules attached to decisions.
There is a second reason this entry repays a careful reading, and it is a point of text rather than of practice. Its heading names a group the second of the three general conditions also names, the non-specialist doctors, and the two provisions do different things: the general condition describes people for whom a licence is not required, subject to an exception, and this entry sets conditions for licensing people. We set both out below as they stand. We do not join them into a rule, because the transcribed text does not say how one is to be read against the other.
One point of orientation before the conditions. They are in the schedule attached to the Decision rather than in the body of it: the issuing article says that the conditions for licences to work in the fields of radiation work, attached to this Decision, shall apply. So a reader who opens the Decision and reads the article that issues it finds a referral and no conditions.
The opening formula, and the three conditions
The entry's opening formula requires the conditions to be present in the person who is granted a licence to practise radiation work from among the non-specialist doctors, and the preposition in that formula is worth noticing: it licenses a person from among a described group rather than licensing him as the holder of a named post. The two entries before it read the other way, naming a function. We record the difference in wording and read no rule into it.
Then three conditions: that he shall have passed a training course in radiation protection in the field of the speciality from an approved centre; that he be under the supervision of a specialist and licensed person; and that he pass the prescribed medical examination. That is the whole of the entry. There is no academic condition in it of any kind, and there is no experience condition.
Two of those three are worth reading closely. The course condition is in the past tense, that he shall have passed a course, whereas items 4 and 5 ask that he pass one. We record the difference in wording and read no order and no deadline out of it; the entry sets none and we do not supply one. And the supervision condition is inside the list of conditions of the licence itself rather than a rule attached after it, so on the words of the entry the licence stands on the supervision arrangement and not merely on a document. Its wording describes the supervisor twice over, as a specialist and as licensed, which is not the wording of the trainee provision in the third part of the schedule, and we do not read the two descriptions as one.
Now the comparison that governs this entry. Its condition list is identical word for word with the condition list of the resident doctors entry before it; the two were compared line by line against the transcribed text. So this entry is distinguished from that one not by what it requires but by its heading and its opening formula. A file therefore belongs under the entry whose description the post answers, and a post is described rather than labelled: the conditions themselves will not tell a reviewer which entry he is looking at.
One further point, and it is the one we are most careful with on this entry. The second general condition describes non-specialist doctors and nurses whose work requires their presence in the imaging, radiotherapy or nuclear medicine areas, and says a licence is not required for them unless the radiation worker definition in Article 1 of the Executive Regulation applies to them. This entry describes non-specialist doctors whose work requires work with radiation, and sets conditions for licensing them. The two descriptions are not identical in words, and the transcribed text does not say how they relate. We have not transcribed that definition for this explanation, so we neither set out its content nor build on it. A doctor whose own case turns on this is a doctor we send to the Ministry with both wordings quoted.
The general conditions that reach into this entry
The conditions of this entry are not the whole of what a file for a non-specialist doctor has to answer, because the medical part of the schedule opens with three general conditions that sit above the numbered entries. Their full wording is set out in the general-conditions article of this series and is not repeated here. All three of them bear on this entry, and a file assembled from the entry alone will miss all three.
The first general condition requires the applicant to hold a licence from the health authority to practise the medical work sought, so the radiation licence for this role presupposes a health practice licence for it. The two licences are granted by two different bodies, with two renewal cycles, and a register that holds only the radiation licences cannot show whether this condition is still answered.
The third general condition is the one candidates ask about, and it is narrower than it is usually reported to be. It exempts from the condition of passing training courses in radiation protection one who presents proof that he obtained courses in radiation protection in his university study of not less than three credit hours, which the text glosses as thirty training hours. So on this entry it bears on the training condition, and the text at that place says nothing about any academic condition — and this entry contains none —, and nothing about the prescribed medical examination. The evidence it names is academic, the proof has to be produced, and whether a particular transcript answers it is read by the competent authority.
A note on the exemption in the third general condition, because it is the provision in the medical part that is most often read more widely than it is written. On its words it exempts a person from the condition of passing training courses in radiation protection, and it does so for one who presents proof that he obtained courses in radiation protection in his university study of not less than three credit hours, a figure the text itself then glosses as thirty training hours. Three limits follow from the wording and we state no more than them. It is an exemption from that condition, and the text says nothing there about any academic condition and nothing there about the prescribed medical examination. It operates on proof presented by the applicant, so whether a particular transcript answers it is read by the competent authority and not by us. And it names university study, which is not something the Institute awards: a course delivered by a training provider is not a university course and carries no credit hours, so this exemption is not a route the Institute can put anyone on.
The five entries of this batch, side by side
The table sets the five entries transcribed for this batch against one another on the conditions each of them contains. It is a reading of medical items 4, 5, 6, 7 and 8, each quoted in full in the Arabic version of its own article in this batch, and nothing is added to it. On this entry the row that decides a file is the supervision row, because this entry and the resident doctors entry are the only two of the five that carry it, and their condition lists are otherwise identical word for word. The academic row is empty here, as it is for the two entries beside it, and the row on how the course condition is worded puts this entry with those two and apart from the first two.
Medical items 4 to 8 compared
| Condition | Medical physicist in radiotherapy, item 4 | Specialist doctors, item 5 | Resident doctors, item 6 | Non-specialist doctors, item 7 | Dentists, item 8 |
|---|---|---|---|---|---|
| Academic condition | The first, second or third university degree in the field of the speciality, one per route | The certificate of specialisation, with no field qualifier and no phrase setting the level as a floor | No academic condition in the entry | No academic condition in the entry | No academic condition in the entry |
| Radiation protection course | Required, in the field of the speciality, from an approved centre | Required, in the field of the speciality, from an approved centre | Required, in the field of the speciality, from an approved centre | Required, in the field of the speciality, from an approved centre | Required, in the field of the speciality, from an approved centre |
| How the course condition is worded | That he pass a course | That he pass a course | That he shall have passed a course | That he shall have passed a course | That he shall have passed a course |
| Experience | Not less than ten, five or three years in the field of the work, one figure per route | No experience condition in the entry | No experience condition in the entry | No experience condition in the entry | No experience condition in the entry |
| Supervision | Not in the entry | Not in the entry | Required, under the supervision of a specialist and licensed person | Required, under the supervision of a specialist and licensed person | Not in the entry |
| Prescribed medical examination | Required in each of the three routes | Required | Required | Required | Required |
| Conditions in the entry | Four in each route, and three routes | Three | Three | Three | Two |
What to settle before the file is assembled
Below is the order we use when a department asks us to look at a file on this entry before it is submitted. It is the Institute's own working practice, and the entry sets out no form of file.
Preparing a file on this entry
Start from the equipment, not from the department list
- This entry describes doctors by what their work requires, and the work is done in theatres, catheter laboratories and on wards rather than in the imaging department whose files somebody already keeps. So the list that finds them is a list of the places the equipment goes and the people who use it there.
- Describe what each doctor actually does with radiation rather than recording his title, because the entry picks out its group by a description and not by a post.
Decide between this entry and the second general condition by asking, not by reading
- Both provisions name non-specialist doctors, in wordings that are not identical, and one sets licensing conditions while the other describes people for whom a licence is not required subject to an exception that turns on a definition in another instrument. The transcribed text does not say how they relate and we do not decide it.
- Put the described roles to the Ministry once, with both wordings quoted, and keep the answer with the register. It is one enquiry for a group of posts rather than one per doctor.
Record the named supervisor, and what happens when he is not there
- The entry puts supervision inside its list of three conditions and describes the supervisor as a specialist and licensed. A file with a course certificate and an examination record and no named supervisor answers two conditions of three.
- Theatre and catheter work runs out of hours, so record the arrangement for the hours when the named supervisor is not on site, and ask the Ministry rather than assuming the condition bends.
Record the tense of the course condition and ask what follows from it
- The entry asks that the doctor shall have passed the course, where items 4 and 5 ask that he pass one. It sets no deadline, and we record the difference in wording without reading an order out of it. Where a rota puts a new doctor on a list before his course has run, that is put to the Ministry with the wording quoted rather than settled in the department.
Confirm the provider in writing, because the entry describes it
- The course condition describes the course as coming from an approved centre, and the entry does not define that phrase, does not say who gives the approval, and does not say whether it is a general standing or given for a particular course. So we do not answer for the Ministry. Name the course and its provider together and ask, before the course is booked.
Pair the radiation licence with the health practice licence in one register
- The first general condition makes one the precondition of the other, and they expire on different dates. Record the scope of the health licence and not only its number, because the condition describes it as being for the medical work sought.
- Whoever watches one expiry date should watch both, because a file that was complete on the day it was submitted is not a file that stays complete.
Settle the prescribed medical examination once for the department
- One written answer from the Ministry about which examination is prescribed and at what interval serves every licence holder in the department, while the examination itself is a condition on an individual and each holder keeps his own record.
- The entry names the prescribed medical examination and does not describe its purpose. Our reading is that it is a condition in the person for the licence, that it does not stand in for the training course the entry names, and that it does not stand in for anything in operational protection.
Questions we are asked about this entry
Our surgeons use a mobile imaging unit a few times a month. Does this entry apply?
The entry describes non-specialist doctors in the field of radiology whose work requires work with radiation, and it sets no threshold of frequency, no number of procedures and no number of minutes. So it neither includes nor excludes a post by how often the equipment is used, and we read nothing into that silence. Describe what the surgeon actually does with the equipment, quote the entry and the second general condition together, and ask the Ministry. That is one enquiry for the whole theatre list.
The second general condition says a licence is not required for non-specialist doctors. Does that cancel this entry?
Both provisions are in the same part of the schedule and both name non-specialist doctors, in wordings that are not identical: the general condition adds that the nature of their work requires their presence in the imaging, radiotherapy or nuclear medicine areas, and attaches an exception that turns on the radiation worker definition in Article 1 of the Executive Regulation; this entry describes doctors whose work requires work with radiation and sets licensing conditions. The transcribed text does not say how one is read against the other, and we do not decide it. We have not transcribed that definition, so we offer no reading of it. Ask the Ministry with both wordings quoted and keep the answer.
Who is to be the supervisor for a cardiologist in a catheter laboratory?
The entry requires the doctor to be under the supervision of a specialist and licensed person. It describes the supervisor by those two words and says nothing further: it does not name a post, it does not say which entry of the schedule the supervisor must himself be licensed under, and it does not describe what the supervision consists of. So we do not name a post either. Set out the arrangement you propose, naming the proposed supervisor and the entry his own licence rests on, quote this condition, and ask.
There is no academic condition here. Is a medical degree not required?
The entry contains no academic condition, and we state that as a reading of the entry and stop. Two things sit beside it. The entry describes its group as doctors, so the description itself presupposes a doctor rather than setting a certificate as a condition. And the first of the three general conditions requires the applicant to hold a licence from the health authority to practise the medical work sought, and that licence is granted on the health authority's own criteria, which this Decision does not set out. So the absence of an academic condition in this entry is not the whole picture, and the file still answers that general condition on its own evidence.
Can one licence cover a doctor who also appears on the imaging department's rota?
The entries of this part name different groups and functions, and a doctor whose work answers two descriptions is being described by two entries. The conditions of this entry and of the resident doctors entry are identical word for word, so the documents in a file do not by themselves show which entry it was assembled under, which makes the question worth settling explicitly rather than by inference. Describe both roles as they actually are, quote both entries, and ask the Ministry; and record on the register which entry each licence rests on.
A technical note: the licence is not the protection
A technical note, and it is the most important passage on this page. The conditions in this Decision are licensing conditions, not department work instructions. Meeting them, and any licence that follows, replaces nothing in operational protection, and no course makes anyone safe by itself. One rule governs every judgement about whether a source or a beam is live: it is settled by measurement, never by inference.
The measurement is made by the licensee, through a person qualified to make it, and the instrument has to respond to the radiation actually present and at the energies present. An instrument that reads only photons tells an operator nothing about a pure beta emitter beside it, and a survey meter outside its calibration validity reads a number rather than a dose rate. So the instrument is within its calibration validity and response-checked before work starts.
What does not count is an inference. Not an indicator lamp, not a position readout, not an interlock that has never been tested, and not the fact that the list was worked through as planned. And if the measurement does not establish that the beam is off or the source is shielded, the work stops where it is, no one enters, and the licensee acts on his own emergency arrangements and notifies the Ministry. The place of those duties is not this Decision: they fall to the Law, the Regulation and the conditions of the licensee's own licence, none of which is transcribed for this explanation.
The work behind this entry is done where the radiation is not the point of the room, and that is what puts the protection where the room was not built for it. In theatre and in a catheter laboratory the beam runs while the team is around the table, the patient is the main scatterer, and the dose to everyone standing there is governed by the distance, the shielding worn and in place, and the time the beam is on. Those are decisions made by the operator at the table, and the two of them that matter most are the ones nobody announces: the foot held down longer than the image needed, and the hand that stays in the field. A mobile unit brings all of that into a room that was not built for it, so the shielding that a room built for imaging provides is absent and the distance is whatever the layout allows. Before anyone works on the equipment itself, the state relied on is established by cutting the power and by removing the means of energising it, and then confirmed by measurement; an indicator lamp on the unit is an inference this rule does not count. Two further points. A doctor who screens at a bedside takes the equipment to a place where other patients and other staff are present, and the area that needs controlling is not the shape of a room. And where the department also holds a sealed source alongside the machine, that source has no off state at all and is treated as live until a measurement says it is shielded; nothing done to the machine changes its state, so cutting the power to the unit is no evidence about the source, and entry is governed by the source and not by the machine. Where the measurement does not establish the state relied on, the work stops where it is, nobody enters, and the licensee acts on his emergency arrangements and notifies the Ministry.
How the Institute can help
Two findings recur on files for this entry, and the first of them is that there are no files. A hospital that keeps a careful register for its imaging, radiotherapy and nuclear medicine staff has usually never assembled one for the doctors this entry describes, because they sit on other departments' establishment lists and nobody there is looking at a schedule attached to a radiation decision. The second is a file that exists and names no supervisor, against an entry that puts supervision inside its list of three conditions, so two of the three are answered and the file reads as complete.
The Institute delivers radiation protection training, walks the places the equipment actually goes and reads each doctor's work there against medical item 7 and against the three general conditions, drafts the enquiry to the Ministry on how this entry and the second general condition are read against one another for a described post, on who the supervisor it names is to be, on the standing of a named course at a named provider and on the prescribed medical examination, and advises on the register that pairs each radiation licence with the health practice licence it depends on. The supervision this entry requires is an arrangement of the licensee rather than anything a training provider supplies, and the Institute awards no clinical certificate, no university qualification of any level and no credit hours. What the Institute delivers is radiation protection training, and whether a particular course at a particular provider answers the course condition in a numbered entry is for the Ministry to say.
Scope of what the Institute does: training and consulting. Field radiation surveys are carried out through specialist partners. The Institute does not carry out laboratory analysis, instrument calibration or equipment testing.
A note on the source of the course, because all five of the entries transcribed for this batch name one. All five of them ask for a training course in radiation protection in the field of the speciality, and all five describe where it is to come from with an Arabic phrase this explanation renders as from an approved centre. The entries transcribed for this explanation do not define that phrase, do not say who gives that approval, and do not say whether it is a general standing or given for a particular course. Where the description appears, it qualifies the provider of the training and no other party. The English wording is a rendering chosen for this explanation and is not a term of art: our practical reading is to ask in the Arabic wording of the entry, naming the specific course and the specific provider together, and to keep the answer in writing, because what the instrument leaves open the authority settles. The Institute is a licensed training provider and describes itself that way and no other way.
A second note on a name, and this one belongs to the medical part in particular. The first of the three general conditions ties a radiation licence to a licence to practise the medical work sought, and it names the body that grants that licence as the National Health Authority. That is the name the body carried when the Decision was issued in 2007. The authority that licenses health practitioners today is the Ministry of Public Health. So the medical part of this schedule points at one authority for the health practice licence and another for the radiation work licence, and they are not the same body. The old name is kept only inside the verbatim Arabic quotation in the general-conditions article of this series.
A note on the authorities the text names, because the provisions transcribed for this explanation do not use one single word for the radiation authority. What they name is the Radiation Protection Committee: the preamble records that the Decision was issued on its recommendation, and the third part of the schedule refers applications for specialities that are not stated in the instructions to it. The preamble also refers to the Executive Regulation of Decree Law 31 of 2002, issued by decision of the President of the Supreme Council for the Environment and Natural Reserves, number 4 of 2003, and the body that name belongs to no longer exists. Competence today sits with the Ministry of Environment and Climate Change, and the unit concerned is named in the organisational decisions as the Radiation Protection Department. The older names are kept only inside the verbatim Arabic quotations on the Arabic version of this article; in the Institute's own advice the authority is written as the Ministry.
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 prevails in the event of any difference, and every wording quoted from the Decision on this page is quoted verbatim in the Arabic version of it. The three general conditions of the medical part are referred to here and set out in full in the general-conditions article of this series. This explanation is introductory. It is not a legal opinion, it does not replace the conditions of your own licence, and it does not replace review by the regulator. Last updated 11 October 2026.