Classifying Radioactive Waste, Reusing It and Returning Sources
October 4, 2026
12 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
Four articles about the life of the material, not the paperwork
The articles before these were about who answers for radioactive waste. These four are about the material itself, and they are arranged in the order a well-run facility would think about it. Generate as little as possible. Decide what each stream is, immediately. Do not call something waste if it can still be used. And where the item is a sealed source, arrange its exit before you buy it.
The last of those is the one that costs money when it is missed, and it is missed constantly, because the duty in Article 89 falls at a moment when nobody is thinking about waste: the moment of purchase. By the time the source is disused and the question becomes urgent, the contract that should have contained the answer has been signed and filed.
Article 86: one sentence, and the word practical
Article 86 is headed controlling the generation of radioactive waste, and it is the shortest article in the Part. The licensee must assure that the generation of radioactive waste is at the lowest practical level.
Short articles are easy to skip and this one has more in it than its length suggests. The duty is on the generation of the waste, not on its handling - which puts it upstream of everything else in the Part. It is a duty about how the work is done, and the decisions that satisfy it are made by people who do not think of themselves as waste managers: whoever chooses the radionuclide, whoever orders the activity, whoever decides whether a procedure uses disposable covers or washable ones.
One caution belongs with this duty before the measure itself, because minimisation is the one optimisation that can be pursued in a way that makes things worse. Reducing volume by handling items more, by decontaminating and reusing what would otherwise be discarded, or by washing activity into the drains moves the problem rather than removing it: it adds contact time and contamination risk for the worker, and it turns solid waste into a liquid discharge that Article 90 then governs. Article 86 asks for the lowest practical level of generation, read with the protection duties in Article 82 - not for the smallest number of bags. The measure is the lowest practical level, and the choice of word is worth noticing. The Regulation's general optimisation standard in Article 6 is the lowest level that can reasonably be achieved with economic and social factors taken into account. Article 90 uses a close variant for discharges - the lowest level achievable within economic and technical limitations. Article 86 says practical, and attaches no qualifier. In the Institute's view the three phrases belong to one family of standard rather than setting three different thresholds, and none of them is satisfied by a facility that has never asked the question; that is our reading and not the text, and the Regulation defines none of the three. What Article 86 says in terms is at the lowest practical level, and nothing more. What the article will not support is the claim that waste volumes are simply what they are.
Article 87: five classes, and the moment the classification is made
Article 87 is headed the classification of radioactive waste and it opens with a phrase that is as important as the classes themselves. Radioactive waste is classified as soon as it is generated into the following.
As soon as it is generated settles a question that decides whether the rest of the Part can work. Classification is not a step performed when a container is full, or when a collection is booked, or when an inspector asks. It is performed at the bench, by the person who produced the item, because that is the only moment at which what the material is, where it came from and what is in it are all still known. Article 92 then builds on the same principle for segregation, requiring waste to be separated into groups at the place of its generation.
The five classes are then set out. The first is permitted or exempt material or waste: material containing levels of radionuclides at concentrations lower than the concentrations determined by the Committee. The second is low-level waste with a short half-life, also called decay waste: low-level radioactive waste containing radionuclides of short half-life and nothing else, that is, radionuclides whose half-life is less than one hundred days, and which decay to the clearance levels within three years of the date of their generation.
Two tests are stacked in class 2 and both have to be met. The nuclide half-life must be under one hundred days, and the waste must decay to clearance levels within three years. The words and nothing else matter as much: a stream that is mostly short-lived but carries a trace of something long-lived is not class 2, and mixing a long-lived nuclide into a decay-store container removes the whole container from the class. That is the single most common classification error in medical practice.
They are independent, and the second is not a consequence of the first: three years is only about eleven half-lives for a hundred-day nuclide, a reduction by a factor of roughly two thousand, so a stream can satisfy the half-life test and still fail the decay test if it starts high enough in activity or concentration. That is why the second test has to be answered with the actual starting activity of the actual container, not with the nuclide's name.
One point follows from that and it is the point most often lost. Class 2 is a storage route, not a release authority. The release itself is the exemption in Article 81, which turns on the content of radionuclides being below the clearance levels determined by the Committee, and that is a measured fact. Three years in a cupboard is the condition that makes the class available; a measurement at the end is what permits the container to leave radiological control. A facility that releases on a date written on a label has not applied Article 81 at all.
The third class is low and intermediate level waste with a short half-life: waste that does not decay to the clearance levels within three years, and which contains radionuclides emitting beta particles and gamma radiation with half-lives of less than thirty years, or emitting alpha particles with a radioactivity of less than 400 becquerels per gram, and whose total radioactivity does not exceed 4000 becquerels for each package of this waste.
Two numbers appear there and they are in two different quantities, which is the trap. 400 becquerels per gram is a concentration - activity divided by mass. 4000 becquerels per package is a total activity, as the text writes it. The two are not comparable and must never be combined into a single figure. This explanation reproduces both as the instrument states them and does not reinterpret either; where a classification decision turns on these values, the right course is to put the stream and the figures to the Ministry rather than to resolve the question from a summary. One more thing about this limb is open on the face of the Arabic and we do not close it here: whether the 4000 becquerel cap qualifies the alpha limb alone or the class as a whole is not settled by the wording, which is a further reason the stream belongs in front of the Ministry.
The fourth and fifth classes then divide on heat. Class 4 is low and intermediate level waste with a long half-life: waste containing radionuclides at concentrations higher than those for class 3, which does not generate heat at a rate exceeding three kilowatts per cubic metre of waste. Class 5 is high-level waste: waste containing radionuclides at concentrations higher than those for low and intermediate level, short half-life waste, which generates heat at a rate exceeding three kilowatts per cubic metre of waste. Heat is the dividing line because heat is what a disposal facility has to be engineered to remove.
A word on who meets which class in Qatar. Class 5 is the class of the nuclear fuel cycle and of large-scale reprocessing, and Article 80 already subjects fuel-cycle waste to additional provisions issued by the President. Class 4 is not. Class 3 admits alpha emitters only below 400 becquerels per gram, and beta and gamma emitters only with half-lives under thirty years - so a disused long-lived alpha source, a radium-226 needle or an americium-241 gauge or well-logging source, sits above class 3 and therefore in class 4, with no fuel cycle anywhere in the picture. The ordinary medical licensee is usually working in classes 1 to 3, and for him the classification work that matters is the boundary between class 2 and class 3, because it decides whether a container can be held to decay and released or has to be managed as waste with a destination. For an industrial or research licensee holding long-lived sources the boundary that matters is the one between class 3 and class 4, and putting a legacy radium or americium source in class 3 is the error to watch for.
The five classes of Article 87, as the article defines them
| Class | The test the article applies | What it means in practice |
|---|---|---|
| 1. Permitted or exempt | Concentrations lower than those determined by the Committee | Releasable, once measured - and the Committee's values are needed |
| 2. Low level, short half-life, decay waste | Half-life under one hundred days, nothing else present, and decays to clearance within three years | Held to decay, then released only after a measurement shows the content is at or below the Committee's clearance levels - elapsed time is not the release criterion; and a trace of a long-lived nuclide removes the whole container from this class |
| 3. Low and intermediate level, short half-life | Does not decay to clearance within three years; beta and gamma emitters with half-lives under thirty years, or alpha emitters under 400 Bq per gram; and total activity not over 4000 Bq per package | Managed as waste with a destination; the two figures are in different quantities and are never combined |
| 4. Low and intermediate level, long half-life | Concentrations above class 3, not generating heat above three kilowatts per cubic metre | Where disused long-lived sources land - a radium-226 or americium-241 source is class 4, not class 3 |
| 5. High level | Concentrations above low and intermediate level, short half-life, generating heat above three kilowatts per cubic metre | Fuel cycle; Article 80 adds further provisions by decision of the President |
Article 88: three prohibitions, and the one that is a classification rule
Article 88 is headed the recycling and reuse of radioactive material, and despite the heading it is written entirely as prohibitions. The licensee using radioactive material is bound: not to open or dismantle any hermetically sealed source; not to consider this material as radioactive waste if it is possible to reuse it by himself or by any other party; and not to transfer radioactive material to another beneficiary party except with the Council's approval, and after confirming that the party is licensed by the Council.
Item 1 is absolute and it has no exception written into it. Not to open or dismantle any hermetically sealed source. The sealed capsule is the engineered containment that keeps the radioactive material from being dispersed, inhaled or ingested - it is a containment, not a shield, and a sealed source still delivers an external dose through its wall, which is why shielding, distance and time remain separate controls in their own right. The integrity of that containment is what Article 74 asks to be maintained throughout the life of the source. Opening it destroys that containment in one motion: it converts a sealed source into unsealed material and creates a contamination and intake hazard where there had been an external-dose hazard only. Where a source genuinely has to be opened - for recovery, or by a manufacturer - that is work for the supplier or for a party licensed for it, arranged through the Ministry, and never a local decision.
Item 2 looks like a courtesy and is in fact a classification rule with teeth. Not to consider this material as radioactive waste if it is possible to reuse it. The practical effect is that a facility cannot declare a usable source to be waste in order to be rid of it, and the test is not whether the facility itself has a use - it is reuse by himself or by any other party. So the question before declaring a source waste is whether anyone could use it, and this is where Article 89 becomes the answer: the supplier is the other party, and the return arrangement is the route.
Item 3 is the one that catches a transfer between two perfectly respectable parties. Two conditions, both of them prior: the Council's approval, and confirmation that the receiving party is licensed by the Council. A source handed to a sister company, lent to a university, or passed to a contractor without both of those has not met the two conditions this item sets, however sensible the arrangement looks; whether a particular transfer breaches the item is for the Ministry to determine. Note also the connection to Article 20, which forbids a licensee from disposing of sources finally, transferring them to another or lending them to another without a licence to do so.
Article 89: the clause that has to be in the purchase contract
Article 89 is headed returning hermetically sealed sources to the supplier, and it is the most commercially consequential article in the Part. The licensee must, when purchasing sealed sources, include in the contract a provision for returning the radioactive source to the supplying party after his need for it ends, if its radioactivity exceeds the limits determined by the Committee, within a period not exceeding fifteen years from the date of purchase.
The timing of the duty is the whole point. It arises when purchasing. It is a procurement obligation, discharged by a clause in a contract, at a moment when the source is new and nobody is thinking about its end. A facility that has sources on its licence and no return clauses in the contracts that brought them in has a gap in its file against this article, and the duty cannot be met retrospectively by goodwill - the supplier's acceptance was something to secure while the supplier still wanted the sale.
Three elements of the clause itself are set by the article. The trigger is after his need for it ends - not the end of a warranty and not a fixed date. The condition is if its radioactivity exceeds the limits determined by the Committee, which is another of this Part's references outward: the limits come from the Committee, and a facility cannot know whether a given source is within the duty without holding them. And the outer bound is fifteen years from the date of purchase, which is a long time in the life of a company and a reason to record the obligation somewhere it will be found.
The second paragraph turns the clause into something the authority can verify, and it contains a deadline most readers miss on first pass. The licensee must submit to the Council a copy of the parts of the contract that refer to this, or of the supplying party's document accepting the recovery of the source, and obtain the Council's written approval before the date of the contract or the import of the source.
Before the date of the contract or the import of the source. So the written approval is a condition precedent, and the sequence the article contemplates runs: agree the return clause, submit it, obtain written approval, and then contract or import. A purchase order raised and a source shipped before that approval has inverted the order the article sets. This is the single most useful thing to fix in a procurement process, because it costs nothing at the start and is very expensive to remedy at the end: a disused source with no return route, which can then be moved on only by an application to the Ministry for disposal under Article 91.
Articles 86 to 89: what each one asks a facility to be able to show
Before the waste exists
- Article 86: evidence that the question of reducing generation was asked - nuclide choice, ordered activity, and reusable rather than disposable where the practice allows and where the change does not add contact time, contamination risk or liquid discharge.
- Article 89: a return clause in the purchase contract, the supplier's acceptance document, and the Ministry's written approval dated before the contract or the import.
At the moment it is generated
- Article 87: the class recorded as soon as the waste is generated, with the nuclide and the basis - not decided later at the store.
- For anything placed in decay storage, a record of every nuclide put into the container, written at the point of generation - class 2 requires short-lived nuclides and nothing else, and that is a condition controlled by what is allowed into the container, not something that can be established by looking at a full one.
Before anything leaves
- Article 88 item 2: a record of why a source was classed as waste rather than reusable by anyone.
- Article 88 item 3: the Ministry's approval, and the receiving party's licence, both before the transfer.
Questions these articles get asked
We bought our sources years ago with no return clause. What now?
The duty in Article 89 attached at the time of purchase, so it cannot be retrospectively satisfied, and the honest position is that the file has a gap in it. What can still be done is worth doing in this order. Ask the supplier whether it will accept the source back and get the answer in writing, because a supplier's acceptance document is one of the two things the article contemplates submitting. Record each source's purchase date, so that where the fifteen-year outer bound is still open the position is known. Put the clause into every contract from now on, with the Ministry's written approval obtained before the contract date as the second paragraph requires. And raise the legacy sources with the Ministry rather than wait, because the alternative route is the disposal application under Article 91 and that is a conversation better had early.
Can we put a single container in decay storage for mixed short-lived waste?
Mixed among short-lived nuclides, yes in principle; mixed with anything long-lived, no. Class 2 in Article 87 requires waste containing radionuclides of short half-life and nothing else, with half-lives under one hundred days, decaying to clearance within three years. A single long-lived item removes the whole container from the class, and the container then has to be managed under the class it actually falls in. Article 92 points the same way from a different direction: segregation is into groups at the place of generation, each type kept in a separate container and the containers labelled on the Committee's conditions. The practical control is at the bench, not at the store door - and the release at the end of the hold is a separate control again: the hold time is set by the longest-lived nuclide in the container, the container is labelled with every nuclide put into it, and the release needs a measurement against the Committee's clearance levels rather than an elapsed date.
Our source is disused but still works. Is it waste?
Item 2 of Article 88 says the licensee is not to consider the material as radioactive waste if it is possible to reuse it by himself or by any other party. So a working source that somebody could use is not waste, and declaring it waste would not sit with that item. The routes the Regulation gives you are transfer to a licensed beneficiary under item 3 of the same article - with the Ministry's approval and confirmation of that party's licence, and read with Article 20 - or return to the supplier under Article 89. Note that Article 74 keeps the maintenance, surveillance and testing duty running throughout the life of the source, so a disused source in a store is still being maintained and recorded while this question is resolved.
Does the 4000 becquerel figure in class 3 really mean the whole package?
That is what the Arabic text says: total radioactivity not exceeding 4000 becquerels for each package of this waste, set beside a concentration of less than 400 becquerels per gram for alpha emitters. The two are different quantities and we reproduce both as written without reinterpreting either. We will not paper over the obvious, though: a total of 4000 becquerels per package is a very low figure in this context, and a facility whose classification decision turns on it should put the stream, the nuclide and the figures to the Ministry and get the reading in writing rather than resolve it from this or any other summary. Attributing a corrected or converted figure to Article 87 would be inventing a number the instrument does not contain.
A university wants to borrow a source we no longer use. May we lend it?
Only with two prior steps, and a third provision reinforces them. Item 3 of Article 88 forbids transferring radioactive material to another beneficiary party except with the Council's approval and after confirming that the party is licensed by the Council. And Article 20 forbids a licensee who holds sources from disposing of them finally, transferring them to another or lending them to another without a licence to do so. So the sequence is: confirm the university holds the appropriate licence, obtain the authority's approval, and only then move the source - with the transfer recorded in the source register required by Article 68. The sequence above is the one the Regulation contemplates; what it does not contemplate is doing it on a handshake.
How the Institute can help
Article 89 is where we find the most expensive gap in this Part, and it is always the same gap: sources on the licence whose purchase contracts contain no return clause, because the duty fell at procurement and procurement was not told. Article 87 is the second, and there the finding is usually a decay store whose containers were classified when they were full rather than as soon as the waste was generated.
Radiation Protection Officer training covering waste classification and the management of disused sources, advisory support in drafting the return clause and the submission that Article 89 requires before the contract date, help in setting up a classification record that is completed at the point of generation as Article 87 requires, and a review of your source register and purchase contracts against Articles 86 to 89 one by one. Measurement of activity or concentration in any stream, and any laboratory determination of nuclide content, 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.