Practices Before and After the Law in Qatari Radiation Licensing
October 5, 2026
11 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
A structural feature that decides which set of conditions applies to you
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 condition as the instrument states it and point to the training that bears on it.
Several entries in the industrial part of the schedule of Decision 4 of 2007 are not one set of conditions but two. Item 2, the industrial radiographer, and item 3, the assistant, each carry a paragraph headed A, practices before the issue of the Law and a paragraph headed B, practices after the issue of the Law, and the two paragraphs set different conditions for the same job title. The first of those headings also appears in item 5, the well logging operator, which a later batch reads.
This matters more than it looks, because it is the first decision in any licence file and it is almost never made deliberately. A file assembled against the wrong paragraph is wrong from its first page: it may evidence an academic level the applicable paragraph does not ask for and miss the number of years it does. And the choice is not a preference. It follows from what the headings actually say.
Alongside the split, the third part of the schedule, headed Third, other conditions, contains two numbered provisions, 1 and 2, which this article sets out: a trainee licence, and a route for specialties the instructions do not list. Both are short, both are frequently missed, and both bear directly on the experience conditions this batch has been reading.
What the two headings say, and what they do not say
Read the headings literally. They qualify practices, not people and not applications: practices before the issue of the Law and practices after the issue of the Law. The subject of each heading is a practice, and the dividing line is the issue of the Law. So the question the headings ask is about the practice being licensed and its relation to that event, and not about when the applicant was hired, how long he has worked, or when the file was submitted.
Three things the headings do not do are worth stating, because each of them is assumed in practice. They do not set an end date, and the two items quoted here give no date on which paragraph A ceases to be available. They do not describe paragraph A as a transitional concession, and neither the headings nor the conditions quoted beneath them use the language of transition. And they do not make one paragraph lighter than the other: in item 2, paragraph A asks a lower academic level and five times the experience, while paragraph B asks a diploma in a named field and one year, so the two differ in opposite directions and a person who satisfies one may well fail the other.
One further feature of paragraph A appears in items 2 and 3 and not in their paragraph B. Inside the radiography condition, paragraph A offers an alternative: or that he pass the examination the Council decides in respect of those who were trained locally. The Decision creates the possibility of an examination set by the authority for people trained locally, and says nothing else about it: not its syllabus, not who is eligible, not whether a sitting is held. Treat it as a question to the Ministry and never as a plan.
The trainee licence, and the sentence that limits it
The first provision in the third part is one sentence followed by one limitation, and together they answer the question every experience condition in this instrument raises. It reads, in these terms: a licence to practise radiation work as a trainee is granted to a person in whom the conditions of the licence sought are present with the exception of the experience condition. The limitation follows immediately: and in that case he may not practise radiation work except under the supervision of a licensed person.
Read the first sentence carefully, because it is stricter than it is usually taken to be. The trainee licence excepts one condition and one only: the experience condition. Every other condition of the licence sought must be present in the person. So a prospective industrial radiographer under paragraph B who lacks the year of experience may be licensed as a trainee, but he still needs the diploma in a branch of engineering or sciences, the Level II course, the radiation protection course in industrial applications, and the prescribed medical examination. A trainee licence is not an entry route for somebody who has none of those.
The limitation is equally narrow and equally firm: in that case he may not practise radiation work except under the supervision of a licensed person. The text says a licensed person and does not say a particular role, so what the Ministry requires of that supervision on a specific file is a question to put to it rather than one to settle from this sentence. What the sentence does settle is that unsupervised practice is outside the trainee licence altogether.
Specialties the instructions do not list
The second provision in the third part is the one that keeps the instrument from being a closed list. It reads, in these terms: licence applications for the specialties that are not stated in these instructions are referred to the Radiation Protection Committee to decide on them. A second sentence follows: and the Committee shall be informed by international instructions and standards, in particular those issued by the International Atomic Energy Agency. The table at the end of this section sets out what each provision of the third part decides and what it leaves to the competent authority.
The practical reading is this. If your specialty is not one of the entries in the schedule, the answer is not that no licence is possible and it is not that you may pick the nearest entry and apply its conditions to yourself. The answer is that the application goes to the Committee, and the Committee decides. What you can usefully do is make the application easy to decide: name the practice precisely, say what sources and activities are involved, and set out which international guidance you have followed and why. The Decision directs the Committee to seek guidance in that material, and it is not a condition you can satisfy in advance.
The third part of the schedule, and what each provision decides
| Provision | What it decides | What it leaves to the authority |
|---|---|---|
| Trainee licence | One condition is excepted, the experience condition, and every other condition of the licence sought must be present | What the required supervision by a licensed person amounts to on a specific file |
| Supervision limitation | Practising radiation work without the supervision of a licensed person is outside the trainee licence | Which licensed role may supervise, and any further condition attached when the licence is granted |
| Specialties not listed | Applications are referred to the Radiation Protection Committee for decision | The decision itself, and which international guidance informs it in a given case |
Four questions to settle before a file is assembled
These are the questions we settle first when we are asked to look at a file under this Decision, in this order. They are the Institute's working practice and the Decision requires none of them.
Order of settling a file under Decision 4 of 2007
Which entry of the schedule is the person being licensed under
- The conditions attach to a named function, so the entry has to be identified before anything is collected. A site job title is not the same thing as an entry in the schedule.
- If no entry fits, that is the third part of the schedule and the route is referral to the Committee, not the nearest entry.
If the entry has two paragraphs, which one applies
- The headings describe practices and divide them by the issue of the Law. This is the question to put to the Ministry when it is not obvious, because every other condition in the file depends on the answer.
Is the experience condition met, or is a trainee licence the step
- The trainee licence excepts the experience condition and nothing else, so the test is whether every other condition of the licence sought is already present. If one of the others is missing, the trainee route does not cover it.
- Decide at the same time how the trainee period will be recorded, because the records that evidence the experience later have to exist while it is being gained.
Which conditions need a written answer from the Ministry
- Three recur across this batch: recognition of a named course at a named centre, the content and interval of the prescribed medical examination, and the existence and scope of the examination the authority sets for those trained locally.
- Ask them in the Arabic wording of the Decision and keep the replies with the licence file. An answer that exists only as something somebody was told on the telephone is not a record.
Questions we are asked about this structure
Has paragraph A expired?
The two items quoted here give it no end date and do not describe it as transitional. What limits it is the heading itself, which ties it to practices before the issue of the Law. Whether a particular practice today falls under that heading is for the Ministry to say, and an answer in writing is worth more than an inference from the age of the instrument.
Can we put a new hire under paragraph A because he has long experience?
The headings qualify practices, not people. Long experience is relevant to the experience condition inside whichever paragraph applies; it is not what selects the paragraph. Choosing the paragraph by the applicant's career is the most common way a file ends up assembled against conditions that do not govern it.
Does a trainee licence let someone work while he studies for the course?
No, on the wording. The trainee licence is granted to a person in whom the conditions of the licence sought are present except the experience condition. A course that has not been passed is not a condition that is present, so the person is not within the trainee provision as it is written. The exception is for experience and for experience only.
Who counts as the licensed person supervising a trainee?
The text says a licensed person and stops, so it does not restrict the supervision to a named entry of the schedule and it does not describe what the supervision consists of. Those are matters for the authority, and a facility that intends to rely on trainee licences should ask the Ministry what it requires and record the answer rather than decide it internally.
Our practice is not in the schedule. Does that mean no licence is available?
It does not. The third part of the schedule provides for exactly this: applications for specialties the instructions do not list are referred to the Radiation Protection Committee to decide, and the Committee is directed to be guided by international instructions and standards, in particular those issued by the International Atomic Energy Agency. So the route exists and the decision is the Committee's. What is not available is helping yourself to the conditions of the nearest listed entry.
How the Institute can help
Two findings recur when we review files under this Decision. The first is a paragraph chosen by the applicant's career rather than by the practice, which makes every later page of the file evidence of the wrong conditions. The second is a trainee licence treated as a general entry permit rather than as an exception to one condition, so a person is put forward as a trainee while a course or the medical examination is still outstanding.
The Institute reads a file against the paragraph that actually applies, advises on how a trainee period is recorded so the experience is evidenced when the full licence is sought, drafts the enquiry to the Ministry on the three questions this Decision leaves to it, and prepares the submission for a specialty that is referred to the Radiation Protection Committee. It also delivers the radiation protection training for industrial applications that the entries in this batch require. Level I, II and III industrial radiography certification is a separate qualification obtained from a centre that provides it, and the Institute does not issue it.
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 technical note. The conditions in this Decision are licensing conditions, not site work instructions. Meeting them, and the licence that may follow, replaces nothing in operational protection: every exposure has a controlled-area boundary that is monitored with a working survey meter, and the exposure is not finished, and the site is not approached, until a measurement confirms that the source has returned to its shield. The return of the source is not inferred from a mechanical indicator, from resistance felt on the crank, or from counting turns. These are obligations on the licensee under the Law, the Regulation and the conditions of his own licence, and their place is not this Decision.
A note on one word. The Decision repeatedly requires a course to be taken from a centre it describes with an Arabic word that this explanation renders as approved. The Decision does not name who gives that approval and does not say whether it is a general status or given for a particular course. In the Decision this description qualifies the training centre and no other body. The English word 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 Decision, naming the specific course and the specific centre, 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 note on the authority named in the text. The word the Decision uses for the authority is the Council. It is the word of a 2007 instrument whose preamble refers to the Executive Regulation issued by decision of the President of the Supreme Council for the Environment and Natural Reserves, number 4 of 2003. The body that word names 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 word Council is kept only where this explanation renders what the instrument itself says, because that is the instrument's own word; in the Institute's own advice it is written as the Ministry. Read Council as the Ministry throughout.
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 condition discussed here is quoted in full on the Arabic version of this article. 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 5 October 2026.