The Radioactive Waste Emergency Plan in Qatar
October 4, 2026
11 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The article that assumes something will go wrong
Every article in Part Five up to here has been written on the assumption that the arrangements hold: waste is classified, segregated, stored in a compliant room, discharged within limits, recorded and reported. Article 97 is the article that assumes they will not hold on some particular day, and asks what has been prepared for that day. It is also the article that asks most directly for people to have been trained for a situation rather than for a task - the Part requires trained personnel in item 3 of Article 82, and this is where the training is named by the work it covers.
The distinction matters because waste incidents do not look like source incidents. A source incident usually has a clear object at the centre of it - a capsule out of its shield, a device that will not retract. A waste incident is more often diffuse: a container that has leaked overnight, a decay store that has flooded, a bag that went into the wrong stream and left the building, a drum whose label no longer matches its contents. These are not situations a facility can improvise its way out of at the time, because the first question - what is in this - is the one the records were supposed to have answered in advance.
So Article 97 should be read as the article that cashes in the rest of the Part. The classification under Article 87, the segregation at the bench under Article 92, the performance log under item 9 of Article 93 kept outside the store, and the package identification numbers under item 7 of Article 94 are all things whose value is highest in the hour this article is about.
Article 97: the plan, the capabilities, and the approval
Article 97 is headed the emergency plan for radioactive waste, and its first paragraph stacks four duties in one sentence. The licensee must provide a plan for the radiological emergencies that may arise from this waste, and must provide the human, technical and material capabilities necessary to respond to emergency situations, and must submit this plan to the Council for its approval, and must also train the response individuals or teams on all response work, including the work connected with removing radiological contamination and regaining control over the radioactive waste.
Take the four separately, because a facility can satisfy any one of them and fail the article. A plan, for the radiological emergencies that may arise from this waste - so the plan is scoped to waste, and a general fire plan or a general radiation plan is not automatically it. Capabilities, in three kinds: human, technical and material. Submission to the Ministry for approval - and note the word is approval, so like the quality assurance programme in Article 94, which is submitted for endorsement, this is a document that leaves the building and comes back approved. And training of the response individuals or teams on all response work.
The two things the training must expressly include are named, and they are named because they are the two that get left out. The first is the work connected with removing radiological contamination. The second is regaining control over the radioactive waste - which in a waste context means knowing where every container is and what is in it after the event, and being able to show it. A team that has been trained to evacuate and cordon has been trained for the first ten minutes; the article asks for training on all response work.
One word of caution on the material capabilities, and it is the Institute's reading rather than the text. Response material for a waste incident is not the same material as for a source incident, and a facility that holds a source emergency kit often finds it is short for a waste event: absorbents and over-packs for a leaking container, labelled empty containers to re-package into, and the means to seal and mark a replacement package that the inventory and the performance log can still account for. Nothing in Article 97 lists those; what the article asks is that the capabilities be the ones necessary to respond, which requires somebody to have thought about which events are credible here.
The decontamination instructions, which are not in this article
The second paragraph of Article 97 is one line and it is a delegation. The instructions for removing radiological contamination are issued by a decision of the President on the recommendation of the Committee.
This is the same structure the series met in the transport chapter, and the same warning applies. The first paragraph requires the response teams to be trained on the work connected with removing radiological contamination. The second paragraph says the content of that work is set elsewhere. So a facility cannot build its decontamination training from this article: it has to hold the instrument in force. In the Institute's library the decontamination decision is Decision 3 of 2007, and the principle matters more than the reference, because an instrument issued by decision is amended and replaced independently of the 2003 Regulation. Ask the Ministry for the instrument in force and keep a copy with the licence file, exactly as with the transport instructions.
There is a second reason to hold the instrument rather than improvise. Decontamination generates waste, and usually more of it by volume than the original spill: wipes, absorbents, protective clothing, and the wash water if washing was used. That new waste re-enters the Part at the top - it has to be classified as soon as it is generated under Article 87, segregated under Article 92, and either held, discharged within limits under Article 90 or disposed of under Article 91. A response plan that cleans up without saying where the clean-up waste goes has moved the problem into the corridor. This is a point the Institute raises in nearly every plan review, and it is our observation rather than a provision of the article.
Prior coordination with the people who will actually turn up
The third paragraph deals with the incidents a facility cannot handle alone. As for waste incidents that require the participation of individuals or parties other than the licensee, there should be prior coordination with those individuals or parties, with the role of each of them determined, and the necessary training carried out for them.
Three requirements again, and the first word governs all three: prior. Coordination after the event is not coordination. Determining the role of each party on the day is not determining it. And the third requirement is the one almost always missing - the necessary training is to be carried out for them, meaning for the outside parties, not only for the licensee's own staff. A plan that names an external fire service, an ambulance service or a contractor and has never put a single person from any of them in a room has done the naming without the coordination.
Why the Regulation insists on this is worth saying, because it is not bureaucracy. The people who arrive first at a waste incident are usually not radiation workers. They are a security officer, a cleaner, a maintenance technician, or an external emergency service, and their trained instinct is to make the area safe by moving things and washing surfaces - both of which can spread contamination and destroy the information the records depend on. Prior coordination is what converts that instinct into a short, correct instruction, in this order: get anyone who is hurt out and treat them first, because injury comes before contamination; then step back, do not move the item, and do not wash the spill or the surfaces; keep people out, and keep anyone who was already in the area at the doorway until they have been checked, because shoes carry contamination into the corridor; if skin was splashed, wash that skin gently with soap and water straight away; and call this number. Washing a surface turns a contained spill into a liquid stream; washing skin is the one washing that should not wait. That instruction is worth more than any equipment in the first half hour, and it only exists if somebody arranged it before the day.
The duties Article 97 puts in a waste emergency plan
The plan itself
- Scoped to the radiological emergencies that may arise from this waste - not a general fire plan and not a general radiation plan by default.
- Submitted to the Ministry for approval, in the same way the quality assurance programme under Article 94 is submitted for endorsement.
Capabilities and training
- Human, technical and material capabilities - the three the article names, chosen against the events that are credible at your facility.
- Training on all response work, expressly including removing radiological contamination and regaining control over the waste.
- The decontamination instrument in force, obtained from the Ministry - the content is in that decision, not in Article 97.
Outside parties
- Coordination carried out in advance, with the role of each party written down.
- Training carried out for those outside parties too, which is the requirement most often missed.
- A short instruction for whoever arrives first, in order: get anyone who is hurt out and treat them first; do not move the item and do not wash the spill or the surfaces; keep people out and hold anyone who was in the area at the doorway until they are checked; wash splashed skin gently with soap and water at once; call this number.
When the waste plan may be folded into the general one
The last paragraph of Article 97 provides a relief, and it is the paragraph a small facility should read most carefully, because it is the one that makes the article proportionate. It is permitted, after the Council's approval, to include the emergency plan for radioactive waste within the general radiological emergency plan, for parties licensed to handle quantities of radioactive materials or sources with limited radioactivity, which do not generate radioactive waste presenting appreciable risks to people or the environment.
Three conditions govern the relief, and all three have to hold. The Council's approval is required, so this is a permission to be obtained and not an option to be taken. The party must be licensed to handle quantities of radioactive materials or sources with limited radioactivity. And the waste generated must not present appreciable risks to people or the environment. Note that the second and third are separate tests: limited activity in what you handle does not by itself establish that the waste stream is low risk, and the article asks for both.
The word appreciable is not defined, and this explanation will not supply a binding definition for a word the instrument left open. What can be said is the practical shape of the question: it is a question about the waste stream, which means it is answered from the classification under Article 87 and from what is actually in the store, and it is answered by the Ministry rather than by the facility, since the Ministry's approval is the condition. The sensible course is to propose the merger with the classification evidence attached, and keep the answer.
One caution on using the relief well. Folding the waste plan into the general radiological plan is a permission about where the plan lives, not a permission to drop its content. The first paragraph still requires capabilities and training on all response work including decontamination and regaining control over the waste, and the third paragraph still requires prior coordination with outside parties. A general plan that gained a heading and no waste content has used the relief to lose the article. In the Institute's view the merged plan should still be readable as answering the waste questions on its own - what is held, where, what could go wrong with it, who responds, and where the clean-up waste goes - that is our recommendation, not a requirement of the article.
Questions this article gets asked
We already have a radiation emergency plan. Do we need a separate waste plan?
Possibly not, but the merger is a permission to be obtained rather than a position to assume. The last paragraph of Article 97 allows the waste emergency plan to be included within the general radiological emergency plan after the Council's approval, and only for parties licensed to handle quantities of materials or sources with limited radioactivity whose waste does not present appreciable risks to people or the environment. So propose it, attach the classification evidence from Article 87, and keep the approval. And note what the merger does not change: the capabilities, the training on all response work including decontamination and regaining control over the waste, and the prior coordination with outside parties are all still required.
Where do we find the decontamination procedures the training has to cover?
Not in Article 97. The second paragraph says the instructions for removing radiological contamination are issued by a decision of the President on the recommendation of the Committee, so the content lives in that decision. This is the same delegating structure the series met in the transport chapter. The decontamination decision in the Institute's library is Decision 3 of 2007, but the instrument in force is what binds you and it is amended independently of the 2003 Regulation, so request the current one from the Ministry and keep it with the licence file. Any summary that attributes a decontamination method or limit to Article 97 itself is wrong.
Does the training requirement really extend to the external fire service?
The third paragraph says that for waste incidents requiring the participation of individuals or parties other than the licensee, there should be prior coordination with those individuals or parties, with the role of each determined, and the necessary training carried out for them. The word for them refers to those outside individuals or parties, so yes, where your plan relies on them. What that training looks like is a matter for you, them and the Ministry, and in the Institute's experience the useful minimum is short and specific rather than long: what is held here, what the hazard is, that an injured person is taken out and treated before anything else, that nothing is moved and no surface is washed before the radiation protection officer arrives, and that splashed skin is the one thing that is washed at once. That is our view of what works, not a requirement of the article.
A container leaked in the store overnight. What does the Regulation ask of us first?
Several provisions bite at once and they sit in different articles, which is why the plan under Article 97 exists: the response has to be written before the night it is needed. In outline, Article 97 is what should already tell you who responds and how, with the decontamination work covered by the instrument in force. The clean-up material you generate is new waste and re-enters the Part at the top - classified as soon as it is generated under Article 87, segregated under Article 92, and then held, discharged within limits under Article 90 or disposed of under Article 91. If anything left the store uncontrolled, or if the container's contents cannot be accounted for, the reporting duties in Article 96 are engaged, and those run on their own deadlines: notify immediately, written report within ten days for loss, theft or disappearance, and within twenty-four hours for a release above the clearance levels or a discharge above the Committee's limits. This outline is not a substitute for your own approved plan, and a specific incident should go to the Ministry.
Our waste store is in a leased building. Who provides the material capabilities?
Article 97 puts the duty on the licensee: the licensee must provide the human, technical and material capabilities necessary to respond. A lease does not move that, in the same way that engaging a waste contractor does not move the responsibility placed on the licensee by Article 82. What a tenancy does change is the practical side: access, the building's own emergency arrangements and the people who will arrive first are all partly outside your control, which is exactly the situation the third paragraph of Article 97 addresses with prior coordination, roles determined and training carried out for the outside parties. Put the building operator in that category and write the arrangement down.
How the Institute can help
Two findings recur on this article. The first is a plan that covers sources and not waste: it describes a capsule out of its shield and says nothing about a leaking container, a flooded decay store or a bag that left in the wrong stream. The second is a plan with no answer to where the clean-up waste goes, which means the response generates an unclassified stream at the worst possible moment. The third, less common but more serious, is a plan that names external parties it has never trained, which is the one requirement of the third paragraph that almost nobody has met.
Radiation Protection Officer training that covers the waste chapter and the emergency duties, advisory support in drafting the waste emergency plan for submission under Article 97 or in proposing the merger into the general plan with the evidence the last paragraph needs, help in writing the short first-responder instruction and the prior coordination record for outside parties, and a plan review that maps your plan against the four duties of the first paragraph and the three of the third, one by one, including where the clean-up waste is routed. Response drills on your site and any measurement during or after an incident draw on specialist partners; the Institute does not carry out laboratory analysis, instrument calibration or equipment testing.
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 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 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 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.