Qualified Expert: Industrial and Medical Entries Compared
October 9, 2026
12 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The same role, licensed twice, in two differently worded entries
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 granted or that it will be granted 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.
The schedule attached to Decision 4 of 2007 licenses a qualified expert in radiation protection twice. Once in the industrial applications, as item 11, and once in the medical applications, as item 9. A hospital physicist and a refinery safety manager who sit down to read the Decision will therefore end up on two different pages, and the two pages are not written alike.
That is the reason for this page. In practice the two entries are treated as one requirement with a change of sector, and the assumption is reasonable: both license a qualified expert, both are written in two routes, both name a second and a third university degree, and both measure courses by a total of months. But the differences are not decorative. The two entries name different fields of speciality, they tie their experience conditions to different things, the masters route of one of them adds a limit to its course condition that the other does not, and on the single most consequential line of all, whether the doctorate route carries an experience condition, the two entries are opposite.
One structural point before the comparison. The medical part of the schedule opens with conditions headed as general, placed before its numbered entries, and two of them bear on the medical expert directly: the first requires that the applicant be licensed to practise the medical work in question, and the third addresses an exemption from a condition about radiation protection training courses. Those general conditions are quoted here by reference, because this page is about the expert entries. They are the subject of their own article in this series and are not explained here.
One point of orientation before the conditions themselves: they are in the schedule attached to the Decision rather than in the body of it. The preamble records that it was issued having regard to the Executive Regulation and in particular to Article 25 of it, and on the recommendation of the Radiation Protection Committee, and the issuing article does one thing only: 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.
Item 9 of the medical applications, in its own words
The entry is headed a qualified expert in the field of medical radiation work in its three divisions, diagnosis, therapy with radiation and nuclear medicine, so the heading itself names three divisions of medical radiation work. The conditions formula then reads the following conditions must be present in the person who is granted a licence to work as a qualified expert in radiation protection in medical applications. The heading and the formula are worded differently, as happens elsewhere in this schedule, and we record that and build nothing on it.
The masters route then sets three conditions. The academic condition is that he hold the second university degree, the masters, in a speciality that suits the nature of the work, such as the nuclear or medical or radiation sciences. The course condition is that he have taken part in radiation protection courses in the field of the speciality totalling not less than three months. And the experience condition is that he have practical experience in the field of radiation protection in medical applications of not less than five years, followed by the word or and a colon.
Two things in that course condition deserve isolating, and both are small enough to be read past. The first is the addition of in the field of the speciality after the courses: the medical masters route qualifies the courses by a field of speciality, and the industrial masters route of item 11 names radiation protection courses without that qualification. The second is that the verb is written with an attached particle, has taken part in courses, with an attached particle, where item 11 writes has taken part in courses. We record both differences in wording and we read no rule into either, because a difference a reader may observe is not a difference he may interpret on behalf of the instrument.
The doctorate route of item 9 then sets three conditions, not two. The academic condition is that he hold the third university degree, the doctorate, in a speciality that suits the nature of the work, such as the nuclear or medical or radiation sciences. Then comes an experience condition: that he have practical experience in the field of radiation protection in medical applications of not less than three years. And then the course condition: that he have taken part in radiation protection courses totalling not less than one month.
Three observations on that route. It contains an experience condition, where the doctorate route of item 11 contains none; that is the comparison this page exists for and it is a comparison of transcribed wording with transcribed wording. The period named is three years, where the masters route of the same entry names five. And the order of the conditions differs from the masters route of the same entry: the experience condition precedes the course condition here and follows it there. The third is an observation about sequence in the copy we hold, and sequence is not an order of importance, so we record it and say nothing further about it.
A note on a condition that is absent, and it is the place on this page where a reader is most likely to take more from the text than it carries. The prescribed medical examination appears as a condition of its own in items 13, 14, 15, 16 and 17 as transcribed in this explanation. It does not appear in item 11 or item 12 of the industrial part, nor in item 9 of the medical part, on any route of any of the three. That is the whole of what we record. We do not call it an exemption, because an exemption is something an instrument grants and these entries say nothing. We do not say the examination is not required of a person seeking one of these licences, because an entry that is silent has not spoken and the Law, the Regulation and the conditions of a given licence are not in front of us on this page. And we do not say the absence was intended, because intention is not something a reader may attribute to an instrument. The transcription note in our source file records that the doctorate route of these three entries does not mention the examination and that the text is so in the original, so this is not an artefact of our copy. If your own case turns on it, that is precisely the question to put to the Ministry, quoting the entry in full and asking whether the examination is required.
Two general conditions of the medical part, quoted by reference
The medical part of the schedule places conditions headed as general before its numbered entries, and two of them bear on a reader of item 9. They are quoted here and not explained, because the general conditions are the subject of their own article in this series and an explanation of them does not belong on a page about the expert entries.
The first reads it is a condition for a licence for radiation work in the medical field that the applicant for the licence be licensed to practise the medical work required by the National Health Authority. The body named there is the name as at the date of issue; the body concerned today is the Ministry of Public Health. That is an administrative note about who is addressed now and it is not offered as a reading of the Decision.
The third reads a person who provides proof that he obtained coursework in radiation protection in his university study of not less than three credit hours, that is thirty training hours, is exempted from the condition of passing training courses in the field of radiation protection. One feature of its wording is worth recording on this page and no more than recording. The provision is worded as an exemption from a condition about passing training courses. The course condition in item 9 is worded as having taken part in courses with a total of months. Those are not the same words. Whether the exemption provision reaches the course condition of item 9, and if so what it does to a total of months, the provisions as transcribed here do not state, and we do not state it for them. For a candidate whose university study included such coursework that is the question to put to the Ministry, quoting both provisions in full.
Item 11 against item 9, route by route
The table sets the industrial expert entry against the medical one. It is a reading of item 11 of the industrial applications and item 9 of the medical applications, both quoted in full on the Arabic version of these articles, and nothing is added to it. The rows record where the wording differs. They do not place the two entries in an order, and a shorter route is not a lighter one.
The industrial expert and the medical expert
| Condition | Industrial, item 11, masters | Industrial, item 11, doctorate | Medical, item 9, masters | Medical, item 9, doctorate |
|---|---|---|---|---|
| The fields named after the particle of likeness | Engineering and physics with its branches | Nuclear or radiation sciences | Nuclear or medical or radiation sciences | The same wording as the medical masters route |
| The phrase at minimum | Appears | Does not appear | Does not appear | Does not appear |
| How the courses are written | Has taken part in radiation protection courses | The same wording | Has taken part in radiation protection courses, written with an attached particle, and qualified by a field of speciality | Has taken part in radiation protection courses, written with an attached particle, without the speciality qualification |
| Total of courses | Not less than three months | Not less than one month | Not less than three months | Not less than one month |
| Experience: present or absent | Present | No experience condition in this route | Present | Present |
| Experience: what it is tied to | The field of radiation protection | Not applicable on this route | The field of radiation protection in medical applications | The same wording as the medical masters route |
| Experience: the period | Not less than five years | Not applicable on this route | Not less than five years | Not less than three years |
| Order of the last two conditions in the route | Courses, then experience | Not applicable on this route | Courses, then experience | Experience, then courses |
| Source of the courses | The entry says nothing about it | The entry says nothing about it | The entry says nothing about it | The entry says nothing about it |
| Prescribed medical examination | Does not appear in the entry | Does not appear in the entry | Does not appear in the entry | Does not appear in the entry |
| Conditions in the route | Three | Two | Three | Three |
What the comparison is good for
The point of setting the two entries side by side is not to rank them. It is that a reader who has read one of them has not read the other, and the four places where that matters are the ones in the table above: the fields named in the academic condition, the qualification of the courses by a field of speciality on one masters route, what the experience condition is tied to, and whether the doctorate route carries an experience condition at all. A person who holds a qualification and a record that answer one entry may be presenting them against the other.
The experience line is the one to be most careful with, in both directions. The doctorate route of the industrial entry contains no experience condition and the doctorate route of the medical entry contains one of not less than three years. That is a difference between two provisions and nothing more. We do not say that the medical route is stricter, because strictness is an ordering and the entries order nothing. We do not say that the industrial route is a route without experience, because that is a statement about what the authority will require and the grant of a licence is its decision alone. And we do not offer a reason for the difference, because neither entry gives one.
The practical consequence for a hospital is narrower than the comparison and more useful. The experience condition on both routes of the medical entry is tied to the field of radiation protection in medical applications, which is the industrial wording with a further qualification added to it. Whether a record of radiation protection work that is not described as being in medical applications answers the medical condition is a scope question for the Ministry, so the useful step is to record what the work actually was and to ask. And the medical masters route qualifies its courses by a field of speciality, which is a description the course record has to be able to answer.
Preparing a medical expert file
Read the medical entry, not the industrial one
- The two entries name different fields in their academic conditions, tie their experience to different descriptions, and differ on whether the doctorate route carries an experience condition. A file built from the industrial entry is a file built against the wrong words.
Document the experience in the medical description the entry uses
- Both routes of the medical entry tie the experience to the field of radiation protection in medical applications. So the record states the dates, the institution, that the experience was practical, and specifically what the radiation protection work in the medical setting consisted of, by division where that is how the work was organised.
- The periods differ between the two routes of the medical entry, five years and three, so the period the record has to reach follows from the route the file is presented on.
Make the course record answer the speciality qualification
- The masters route of the medical entry qualifies the courses by a field of speciality, which the industrial entry does not. So each course in the record needs its subject recorded and not only its title, alongside the provider, the dates, the contact hours and the certificate.
Ask about the general conditions as their own question
- The medical part places conditions headed as general before its numbered entries, the first requiring that the applicant be licensed to practise the medical work in question and the third addressing an exemption worded as an exemption from a condition about passing training courses. Whether and how those reach the expert entry is a question for the Ministry, quoting the provisions in full.
Questions we are asked about these two entries
Is the medical expert licence harder to obtain than the industrial one?
The entries place themselves in no order and neither will we. What they show is a set of differences: the academic conditions name different fields, the medical masters route qualifies its courses by a field of speciality where the industrial one does not, the experience conditions are tied to differently worded descriptions, and the doctorate route of the medical entry contains an experience condition of not less than three years where the doctorate route of the industrial entry contains none. Those are differences between provisions, not degrees on a scale, and the question to settle is which entry describes the work rather than which is harder.
Our physicist holds the industrial expert licence. Does it cover our nuclear medicine unit?
The two entries sit in two different parts of the schedule and set differently worded conditions, and the heading of the medical entry names three divisions of medical radiation work. Whether a licence granted under one entry reaches work the other describes is a question the entries do not address, so it is for the Ministry. Two things in the wording bear on how you ask. The experience condition on both medical routes is tied to the field of radiation protection in medical applications, and the medical part places a general condition requiring the applicant to be licensed to practise the medical work in question. Describe the person, the licence he holds and the work the unit does, in one letter, and ask.
I studied radiation protection at university. Does that exempt me from the course condition?
The medical part contains a provision worded as an exemption from a condition about passing training courses in the field of radiation protection, for a person who provides proof of university coursework of not less than three credit hours, with thirty training hours stated in brackets. The course condition in item 9 is worded differently: it speaks of having taken part in courses with a total of months. Those are not the same words, and whether the exemption reaches that condition, and what it would do to a total of months, the provisions as transcribed here do not say. So we do not answer your question and we do not want you to assume either answer. Quote both provisions in full, attach the transcript showing the credit hours, and ask the Ministry.
Does in the field of speciality mean the courses must be in nuclear medicine specifically?
The masters route of the medical entry qualifies its courses with that phrase and the entry does not define it. It does not say that the speciality is the division of medical radiation work a person is employed in, and it does not say that it is the speciality of his degree. So we will not tell you which, and the practical answer is to record the subject of every course you have taken rather than only its title, so that whichever reading the competent authority applies, the record can answer it. The doctorate route of the same entry states the course condition without that phrase, which is a difference in wording between two routes of one entry that we record and read no rule into.
Our hospital role is not described by any entry in the medical part. What then?
The third part of the schedule provides for that: licence applications for the specialities that are not stated in these instructions are referred to the Radiation Protection Committee to decide on them, and the Committee shall be guided by international instructions and standards, in particular those issued by the International Atomic Energy Agency. So the route is referral, the decision is the Committee's, and the guidance it is directed to is named in the provision. The provision does not give you the alternative of applying to yourself the conditions of whichever listed entry looks closest, and in our practice that assumption is the error we see. In the medical part that assumption usually takes one shape: taking the expert entry to govern because it is the entry whose heading names all three divisions of medical radiation work, without reading the conditions it actually sets or the general conditions placed before the numbered entries.
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 site work instructions. Meeting them, and any licence that may follow, replaces nothing in operational protection, and no course makes anyone safe by itself. One rule governs every judgement about where a source is and what is coming off it: it is settled by measurement, never by inference.
The measurement is made by the licensee, through a person qualified to make it, with an instrument within its calibration validity and response-checked before work starts, and the instrument has to respond to the radiation actually present and at the energies present. A meter calibrated on the energies of a gamma source may read far below the truth at the much lower photon energies in a diffraction or fluorescence instrument, or not respond at all. An alpha emitter is not reliably detected by a gamma probe or a beta probe. Where neutron-emitting material may be present, or a beam energy high enough to produce neutrons, a gamma-only meter can read clean beside an unshielded source. And intake, by inhalation or by ingestion, is not something a surface monitor shows at all, so it sits with the air sampling and internal-dose arrangements of the licensee.
What does not count is an inference. Not a mechanical indicator, not a position switch, not a painted mark, not a label on a container, and not the fact that the work went as planned. And for an electrically generated source the rule is not softened but changed. A tube with the supply cut reads clean and establishes nothing about the next minute. What makes the device safe to work on is that the means of switching it on has been taken out of service and kept under the control of the person doing the work. 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.
The medical setting is the one in which the person the radiation is aimed at is not a worker and is not monitored, which is why one thing about the expert role there belongs here. An expert opinion in a diagnostic, therapy or nuclear medicine department is an opinion about a practice in which a dose is delivered deliberately, to a patient, by design. Nothing in this Decision addresses that delivery, and this page does not either: the clinical side of medical exposure sits in legal instruments and standards other than this one.
What does belong here is the part the rule above governs: the occupational and public side. A nuclear medicine department holds unsealed material, and unsealed material brings contamination and intake, which a dose-rate measurement does not address at all. So the monitoring has to match the material and not only the geometry. Surface contamination is looked for with a probe that responds to the emission of the nuclide actually in use. Intake is not something a surface monitor shows, so it sits with the air sampling and internal-dose arrangements of the licensee. That is a bioassay question, such as a thyroid count where radioiodine is handled, and not a personal dosimeter one.
And a therapy installation is the place where an inference is most tempting and least safe. Where the beam is produced by a machine that is switched, a measurement made with the supply cut reads clean and establishes nothing about the next minute. What makes the room safe to enter for work on the machine is that the means of energising it has been taken out of service and kept under the control of the person doing the work, under the licensee's own written procedure. Where the therapy source is a sealed source rather than a machine, there is no supply to cut and the rule above applies unchanged. The source is emitting whether the console says so or not. A source-position indicator is one of the inferences that rule does not accept. These are duties on the licensee under the Law, the Regulation and the conditions of the facility licence, and their place is not this Decision.
How the Institute can help
Two findings recur where these two entries are concerned. The first is a file built from the industrial entry for a medical appointment, because the role has the same name in both parts of the schedule, which leaves the academic condition evidenced in the wrong named fields and the experience evidenced against a description looser than the medical entry uses. The second is settling, in either direction and before the question is put to the Ministry, whether the exemption provision in the general conditions reaches the course condition of the medical entry; the two are worded differently and neither says what the other does.
The Institute delivers radiation protection training, reads a candidate's position against item 9 route by route and against item 11 where the two are being confused, builds and maintains the running course record a total of months is evidenced from with the subject of each course recorded. It drafts the enquiry to the Ministry on whether a named degree falls inside the fields the medical academic condition names, on what the speciality qualification on the medical masters route reaches, on whether the exemption provision in the general conditions reaches the course condition of item 9 and on whether the prescribed medical examination is expected where the entry does not name it. A word on the limits of what the Institute issues. The entries read here name no particular course, so neither a course nor a certificate is offered on this page as answering their condition, and the Institute does not state that any programme of its own satisfies a condition that names a total of months. What the Institute delivers is radiation protection training; what a given certificate or a given set of courses does against a given condition is for the Ministry to say, and the Institute does not issue academic degrees of any level, which is the other half of every route in these two entries.
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 three wordings of the course condition, and it is the single most useful distinction in this batch. The items transcribed in this explanation do not state the course condition in one way. Item 13, in both its limbs, and item 14 require that he pass a radiation protection officer course in industrial applications from an approved centre. Items 15, 16 and 17 require a training course in radiation protection in industrial applications from an approved centre, item 15 writing it with an additional phrase rendered here as in the field of. And items 11 and 12, the two industrial entries this batch reads, require something written differently again: that he have taken part in radiation protection courses totalling not less than three months on one route and that he have taken part in radiation protection courses totalling not less than one month on the other. The third wording is not a narrower or a wider version of the first two. It is a different kind of condition: it speaks of having taken part rather than of passing, it speaks of courses in the plural with a total duration rather than of one named course, and it names no subject beyond radiation protection. We record the three wordings and we do not resolve them: we do not say that a certificate answering one answers another, we do not place them in an order, and we do not say what any particular certificate does against any particular condition, because the items do not say. What follows practically is narrow and worth acting on: read which wording your own entry uses, and put the question of whether a particular certificate or a particular set of courses satisfies it to the Ministry in the words of the item, in writing, before a course is paid for.
A note on the source of the courses in the entries read here. Items 13, 14, 15 and 17, as transcribed in this explanation, describe the centre a course is to come from with an Arabic word this explanation renders as approved, and item 16 carries that description on one of its two courses and not on the other. Item 11 carries no such description at all, and neither does item 9 of the medical part: the course condition on each of their routes names the courses and says nothing about where they are to come from. Item 12 of the industrial part carries none either. Silence in an instrument is neither a permission nor a prohibition, so we record it and we read it neither way. In particular we do not say that the absence of the description means any provider will do, and we do not say that the description is to be read into the entry from its neighbours. Our practical reading is to name the courses and their providers in the enquiry and to ask in the words of the item, because what the instrument leaves open the competent authority settles. The English word is a rendering chosen for this explanation and is not a term of art. The Institute is a licensed training provider and describes itself that way and no other way.
A note on the authority. The transcribed preamble of the Decision 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, and it does not state who issued Decision 4 of 2007. So this explanation does not say that body issued it, and its name appears nowhere in this explanation outside a verbatim quotation but in this note. The authority addressed today is the Ministry of Environment and Climate Change, and the unit concerned is named in the organisational decisions as the Radiation Protection Department; that is an administrative statement about who is addressed now and it is not offered as a reading of the Decision. 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 an official 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 9 October 2026.