Maintenance, Testing and Accident Management of Sources in Qatar
October 2, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The two articles that cover the twenty years in the middle
A source has three moments that get attention: the day it arrives, the day something goes wrong, and the day it leaves. Between the first and the third there are usually two decades in which nothing happens, and that is the period these two articles are about. Article 74 governs the years in which nothing happens. Article 75 governs the hour in which something does.
They belong together because each one is how the other is paid for. A maintenance regime exists so that the accident does not arrive; a readiness regime exists because maintenance is not a guarantee. A facility that has the first and not the second is relying on never being unlucky. A facility that has the second and not the first will get to use it.
Article 74: two items, and the phrase that sets the period
Article 74 is headed maintenance, testing and surveillance, and it binds the licensee to two things. The first is to carry out maintenance, surveillance, tests and all kinds of service, whenever the need for that arises, to make sure that the source is still in its condition, meeting the protection and safety requirements of the design throughout the period of the life of the source.
Three phrases in that sentence do real work. Whenever the need for that arises sets no interval, which cuts both ways: there is no annual box to tick, and there is no defence in having ticked one. Still in its condition sets the test, and the text fixes its measure: meeting the protection and safety requirements of the design. The Institute's practical recommendation is to record the condition the source was accepted in, because proving it is still in its condition is easier against a reference record. And throughout the period of the life of the source sets the duration, which does not end when the source stops being used.
That last point is where the article meets a real and common problem. A disused sealed source sitting in a store is still within the period of its life for the purposes of this article. It is still under the licensee's responsibility, its condition can still change, and the duty to be sure it is still in its condition has not lapsed because the department stopped using it. A store full of sources nobody tests because nobody uses them is the single most common finding in this part of the Regulation.
The second item is the one that decides whether the first is believed: carrying out the programmes and the works of maintenance, surveillance and testing according to documented methods supported by the requirements of quality control. Documented methods - so a competent technician who knows what he is doing but works from memory does not satisfy this item. Supported by quality control - so the method also has to say how its own result is checked.
A note on what the Institute does and does not do here, because this article is exactly where the line falls. Testing a source and calibrating the instrument that tests it are services carried out by others: the Institute does not perform laboratory analysis, instrument calibration or equipment testing. What belongs to us is the training of the people who run the programme and the review of the documents the programme produces.
What changes in a sealed source that nobody uses? Its envelope. The capsule is welded metal, and over its years it meets damp, heat, vibration and knocks in handling; what has to be confirmed is that its containment still holds. That is what a leak test is for: a wipe taken from the surface of the source or of its container and measured in a laboratory, so that removable activity, if it appears, means material has left the containment. Two questions follow, and both have technical answers. The first is: the source has decayed, so why test it? Decay does reduce the hazard for short-lived nuclides - iridium-192, with a half-life of about 74 days - and does nothing worth counting over the life of a facility for cobalt-60 at about 5.3 years, caesium-137 at about 30 years, or americium-241 at about 432 years, which are the nuclides that actually fill stores. The second is: ours is short-lived, so it is finished. The end of the radiological hazard does not end the record duty, the inventory duty or the disposal route; Article 74 asks about condition and about documents, and decay does not write a document.
What Article 74 asks a file to contain
The baseline
- A practical recommendation: record the condition the source was accepted in. The measure stated in item 1 is the protection and safety requirements of the design.
The written method
- A documented method for each kind of maintenance, surveillance and test, as item 2 requires.
- Inside each method, how its own result is checked - the quality control limb of item 2.
The record that it happened
- Results kept for every source, including the ones no longer in use - the duty runs throughout the life of the source.
- The reasoning behind the chosen frequency, since the article sets none and says whenever the need arises.
Article 75: one duty for everyone, three more for the large and complex
Article 75 is headed accident management, and it is built in two parts that are often read as one. The first sentence binds every licensee without exception: he must be prepared to take any works or procedures necessary to face any emergency accidents, to deal with them, and to correct operating errors.
Notice the third thing in that list, because it is not an accident at all: correcting operating errors. The article puts the ordinary mistake in the same sentence as the emergency, which is a quietly sophisticated piece of drafting. Most radiological incidents are not sudden events; they are an error that nobody corrected while it was still small.
Then the article narrows. For large and complex sources it adds three duties. The licensee must prepare, in advance, an accident management manual that delivers an effective response to the source's safety requirements in the probable accidents. He must provide and keep ready the equipment, the tools and the diagnostic means that may be needed to control the course of an accident and both its actual and its possible effects. And he must give the operating and emergency personnel sufficient training in the methods and steps to be followed when an accident occurs.
The Regulation does not define large and complex, and that is worth saying plainly rather than inventing a threshold. What a facility can do is decide the question in writing, against the test Article 65 itself uses - the magnitude of the possible or potential exposures and their likelihood - and keep the reasoning. In the Institute's view, not in the words of the article, an industrial radiography source, a teletherapy or brachytherapy unit, a large irradiator and a well-logging source are hard to defend as neither large nor complex, and a single low-activity check source in a cupboard is hard to bring within the description. The determination belongs to the regulator.
A caution that this series applies to every article of this kind. The duty in item 2 is to have the equipment and the means of diagnosis ready. Which equipment, where it is kept and how the store is secured are matters for the facility and the Ministry; this explanation states the duty and does not describe the arrangement.
Article 75: who owes what
| Duty | Every licensee | Large and complex sources |
|---|---|---|
| Readiness to face emergencies and to correct operating errors | Yes - first sentence of the article | Yes |
| A prepared accident management manual | Not required by this article | Yes - item 1 |
| Equipment, tools and means of diagnosis ready | Not required by this article | Yes - item 2 |
| Training of operating and emergency personnel on the steps | Required instead by Article 29 and item 3 of Article 53 | Yes - item 3, expressly |
Questions these articles get asked
How often does Article 74 require a source to be tested?
The article gives no interval. It says maintenance, surveillance, tests and all kinds of service are to be carried out whenever the need for that arises, and throughout the period of the life of the source. The practical consequence is that the frequency is yours to set and yours to justify: set it from the source type, the manufacturer's instructions, the conditions of your licence and the way the source is actually handled, and keep the reasoning with the records.
Our source has been out of use for years. Do we still have to maintain and test it?
Yes. The duty in item 1 runs throughout the period of the life of the source, not the period of its use, and the source remains under your responsibility as licensee. A disused sealed source can deteriorate in storage, which is precisely what the duty to be sure it is still in its condition is for. Disused sources also raise the separate question of returning them to the supplier under Article 89, which is worth looking at in the same review.
Is our source large and complex? Who decides?
The Regulation does not define the phrase and sets no activity threshold for it, so no honest answer can quote one. The workable approach is to decide it in writing on the test Article 65 uses - the magnitude of the possible or potential exposures and their likelihood - to keep that reasoning in the file, and to confirm the position with the Ministry rather than discover a disagreement during an inspection. Where the judgement is close, the three items of Article 75 are not expensive to meet.
Is the accident manual under Article 75 the same thing as the emergency plan?
They are two documents with different readers. The manual in item 1 of Article 75 is an operational document about this source: what the probable accidents are and what is done about each. The emergency plan in Article 76 is approved by the Ministry, covers on-site, off-site and beyond the area, and names responsibilities for notifying authorities and starting intervention. Many facilities write one and assume it answers both articles; it rarely does.
How the Institute can help
Article 74 is the article inspections are built on, because it leaves a paper trail that either exists for every source or does not - including the ones in the store that nobody uses. Article 75 is the one that is usually met for the big source and missed for the operating error.
Radiation Protection Officer training covering source safety and accident management, advisory support in writing the documented methods required by item 2 of Article 74 and the accident management manual under Article 75, and a desk review of the source records that sets every source on your licence against the documents Article 74 expects - disused sources included. Field inventory, measurement and testing are carried out through 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 2 October 2026.