Transporting Radioactive Material and Where Waste Rules Begin
October 4, 2026
10 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
Four articles that mostly point somewhere else
These four articles close one part of the Regulation and open another, and they share an unusual feature: most of their content is not in them. Article 78 prohibits transport except in accordance with three bodies of rules, two of which sit outside this instrument. Article 79 lists what a separate decision must contain. Article 81 grants an exemption whose threshold is set by the Committee. Only Article 80 is self-contained, and what it contains is a map.
That is worth saying at the start, because the mistake the Institute meets most often with this stretch of the Regulation is to read it as if it were the rulebook. It is not. It is the article that tells you which rulebooks bind you, and a facility that has read these four articles and nothing else has learned where to look rather than what to do.
The four also mark a real boundary in the instrument. Articles 78 and 79 are the last two articles of Part Four, on the safety of radioactive sources. Articles 80 and 81 are the first two of Part Five, on the management of radioactive waste - a part of twenty articles that governs what happens to material once it stops being useful. The two subjects meet in practice more often than the structure suggests, because waste has to be moved.
Article 78: one prohibition, three sources of rules
Article 78 is headed the transport of radioactive material, and it is a single sentence of prohibition. No radioactive material may be transported by any means of transport inside the State or across its borders except in accordance with the provisions of this Regulation, the instructions on the safe transport of radioactive material, and the rules of safe international transport of radioactive material if the transport is international.
Read the three sources of rules separately, because they are cumulative and not alternative. The Regulation applies. The national transport instructions apply. And if the movement crosses a border, the international rules apply on top. Compliance with one of the three is not compliance with the article.
Two phrases widen the article well beyond what people expect. By any means of transport takes in the company van as surely as the air freight consignment: there is no exemption for a short road movement in a private vehicle, and a portable gauge carried between two sites in the boot of a car is radioactive material being transported. And inside the State puts purely domestic movement squarely inside the prohibition, which is the limb we find overlooked most often, because import and export attract paperwork and a drive across town does not.
This article also has to be read next to the licensing chapter rather than on its own. Article 7 makes transporting radioactive material one of the acts that may not be done without a licence from the Council, and Article 16 sets the lead time for a transport licence application - at least one week for long half-life material used for non-medical purposes, and at least one day before receipt for short half-life material used for medical purposes, with same-day application permitted in cases of extreme necessity. So Article 78 governs how you move it; Articles 7 and 16 govern whether you may and when to ask.
Article 79: the article that creates no transport rule
Article 79 is headed the transport instructions, and it is the clearest example in the whole Regulation of an article that delegates. The instructions on the safe transport of radioactive material are issued by a decision of the President of the Council, and the article then lists seven things that decision must contain: the technical terms needed to implement the provisions on safe transport; the criteria for classifying, packaging and transporting radioactive material by every means of land, sea or air transport inside the State or across its borders; the scope of application of the instructions, the types of packages they cover, and the radioactive material they do and do not cover; the characterisation of radioactive material and the exemptions it includes; the provisions on packaging radioactive material and the permitted limits; the provisions on characterising consignments or any cargo of radioactive material that is to be transported; and the instructions, procedures and conditions for shipping radioactive material.
The practical consequence has to be stated bluntly, because it is where published summaries of this Regulation go wrong. Not one packaging limit, package type or classification criterion is contained in Article 79. The article says what the instructions must deal with. Any statement of the form Article 79 requires packages to be labelled in such a way, or Article 79 sets the activity limit at such a figure, is false: the obligation comes from the instructions issued under it, and the figure comes from them too.
Where are those instructions? In practice the current instrument on the transport of radioactive material in Qatar is a separate decision, and the one in the Institute's library is Decision 11 of 2025. The point of principle matters more than the reference, though: the transport instrument is amended and replaced independently of the 2003 Regulation, so a facility that moves material needs to hold the current decision rather than rely on a summary of this article. Ask the Ministry for the instrument in force and keep a copy with the licence file.
Item 3 deserves a separate word, because it is the item that answers the question people actually have. The instructions must state their own scope and which radioactive material they do not cover. So the question is this material within the transport instructions at all has an answer, and the answer is in the instructions, not in a judgement made at the loading bay.
Article 79: the seven contents of the transport instructions
| Item | What the decision must contain | The question it answers |
|---|---|---|
| 1 | The technical terms needed to implement safe transport | What the words in the instrument mean |
| 2 | Criteria for classifying, packaging and transporting by land, sea or air, inside the State or across its borders | How the material is classified and packed |
| 3 | Scope of the instructions, the package types covered, and the material they do and do not cover | Whether the instructions apply to us at all |
| 4 | Characterisation of the material and the exemptions included | What we are carrying, and what is exempt |
| 5 | Packaging provisions and the permitted limits | What the package must be and hold |
| 6 | Characterising consignments or any cargo to be transported | What the paperwork with the load must say |
| 7 | Shipping instructions, procedures and conditions | How a shipment is actually sent |
Article 80: the scope of the waste part, and a list worth reading slowly
Article 80 opens Part Five and sets its scope. The provisions of this Part apply to all practices and works connected with the management of radioactive waste, including all operations of collecting, segregating, characterising, classifying, conditioning, preparing, treating, storing and disposing of the radioactive waste generated by all radiological practices in the medical, industrial, agricultural, pharmaceutical, research, educational and other fields.
Two lists are doing work in that sentence and both are worth reading slowly. The first is the list of operations - nine of them - and it is the reason a facility cannot say it does not manage waste. Collecting is on the list. So is segregating, and so is storing. A clinic that puts a used vial in a labelled bin and leaves it in a cupboard to decay is collecting, segregating and storing radioactive waste, which means Part Five applies to it even though nobody in the building would describe themselves as being in waste management.
The second list is the list of fields, and it ends with and other fields. Medical, industrial, agricultural, pharmaceutical, research, educational - and then an open ending. There is no sector that is outside Part Five by virtue of being a sector; what takes a practice outside is the exemption in Article 81, and that is measured in activity concentration or total activity, not in industries.
The article then adds two qualifications that change the picture for two industries. These provisions also apply partially to the management of radioactive waste resulting from the activities of mines and mills. And the waste resulting from the nuclear fuel cycle is subject to additional provisions and conditions, to be issued by a decision of the President.
The word partially for mines and mills is not defined, and in the Institute's view the article signals a different regime without setting it out - which is what the separate decisions on naturally occurring radioactive material are for. The fuel-cycle limb is clearer and runs the other way: those provisions are additional, so the Part applies and more is added on top. Neither limb is a gap to shelter in.
Article 81: the exemption, and the number that is not in it
Article 81 is headed exceptions and exemptions and it is one sentence long. Radioactive waste is exempted from the provisions of this Regulation if its content of radionuclides is below the clearance levels determined by the Committee.
The structure of this article is the same one the series has met before, in Article 77 on intervention doses: the rule is here, the number is elsewhere. Clearance levels are defined in Article 1 as the set of values determined by the Committee, expressed in terms of activity concentrations or total activities or both, at or below which radioactive sources may be released from regulatory control. So the exemption is real and it is usable - but only by a facility that holds the current values in writing.
Note the definition says at or below which. The exemption is not only for material that is comfortably under; it reaches material at the level. That is a point of drafting worth having right, because it is the difference between a batch that can be released and a batch that must be held.
Two warnings on using this article. The first is that the exemption is radiological and nothing else: material released from regulatory control under Article 81 does not thereby stop being chemical, biological or sharp, and the closing paragraph of Article 90 makes the same point expressly for discharges. A cytotoxic vial whose activity has decayed below clearance is still a cytotoxic vial. The second is that the exemption has to be demonstrated rather than assumed: the claim that a stream is below clearance is a measurement result, and a measurement result has to come from somewhere. That measurement is laboratory work.
What Articles 78 to 81 ask a licence file to hold
For moving material
- A copy of the transport instructions in force, obtained from the Ministry - the rules are there, not in Article 79.
- The transport licence, and the application lead times of Article 16 built into how movements are planned.
- A note of which movements are domestic and which cross a border, since Article 78 adds the international rules to the second kind.
For the waste side
- A statement of which of the nine operations in Article 80 the facility actually performs - collecting and storing count.
- The clearance levels in force from the Committee, in writing, because Article 81 cannot be applied without them.
- For anything released as exempt, the measurement that supports the claim and the non-radiological hazards that survive it.
Questions these articles get asked
We only move a portable gauge between our own sites in a company car. Does Article 78 apply?
Yes. Article 78 says no radioactive material may be transported by any means of transport inside the State or across its borders except in accordance with the three sources of rules it names, and it makes no exception for short domestic movements, for private vehicles or for moving between sites you own. Transport is also one of the acts listed in Article 7 as requiring a licence. What changes with a small domestic movement is which provisions of the transport instructions bite - and that question is answered by item 3 of Article 79, the scope of the instructions, so it is answered by reading the instructions in force.
Where do we find the packaging and labelling rules? Are they in Article 79?
No, and this is the most important thing to be clear about in these two articles. Article 79 contains no packaging rule, no label specification and no activity limit. It lists the seven subjects that the President's decision on safe transport must contain, and the rules themselves live in that decision. Request the instrument in force from the Ministry, keep it with the licence file, and treat any summary that attributes a packaging limit to Article 79 itself as wrong.
Our hospital lets short-lived waste decay in a cupboard and then puts it in the ordinary bin. Is that waste management under Article 80?
Yes. Article 80 lists collecting, segregating and storing among the operations the Part applies to, and decay storage is storage. Two separate provisions then bear on the rest of what you describe. Article 87 classifies waste as soon as it is generated and gives decay waste its own category, so the classification has to be made at the start rather than assumed at the end, and item 5 of Article 82 is what requires it to be recorded. And release into the ordinary waste stream is the exemption in Article 81, which requires the content of radionuclides to be below the clearance levels determined by the Committee - a measured fact that has to be demonstrated, not a date on a calendar. One more provision bears on the cupboard itself. Article 93 forbids storing radioactive waste except in the manner that achieves the protection of human health and the environment, and in particular not near corrosive, explosive or flammable materials, with the boundaries of the storage area clearly shown and the points of approach controlled. A decay cupboard is a waste store and those requirements apply to it - a cupboard in a room that also holds solvents is the arrangement the article names first.
What are the clearance levels in Qatar?
This Regulation does not state them. Article 1 defines clearance levels as the set of values determined by the Committee, expressed as activity concentrations or total activities or both, at or below which radioactive sources may be released from regulatory control, and Article 81 then hangs the waste exemption on those values. So the figures come from the Committee's decisions and from the conditions of your own licence. Obtain them in writing and keep them with the waste records; any number attributed to Article 81 itself has been imported from elsewhere.
Does Part Five apply to a university teaching laboratory?
Article 80 names the educational field expressly, and closes its list of fields with and other fields, so there is no sector-based way out. A teaching laboratory that generates radioactive waste is within the Part. What may take a particular stream out is Article 81 - content below the clearance levels determined by the Committee - and that is a question about the activity concentration and the total activity in that stream, not about the institution being a university.
How the Institute can help
These four articles produce two practical gaps we see repeatedly. The first is a facility that moves material regularly without holding the transport instructions in force, because a summary of Article 79 was treated as the rules. The second is a facility that does not consider itself to be in waste management at all, while doing three of the nine operations Article 80 lists.
Radiation Protection Officer training that covers transport duties and the waste chapter, advisory support in assembling the transport and waste documents a licence application needs, help in writing the statement of which operations under Article 80 your facility performs, and a documentation review that maps what you hold against Articles 78 to 81 one by one. Measurement of activity in a waste stream, and any laboratory demonstration that material is below clearance, come from specialist partners.
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.
A note on the authority named in the text. The Regulation says the Council, meaning the Supreme Council for the Environment and Natural Reserves. That body 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 inside the quotations because it is what the instrument says; everywhere else, read it 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 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 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 4 October 2026.