Source Security, Records and Worker Information in Qatar
October 1, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
Control, then memory, then awareness
Three articles answer three consecutive questions: how the source stays under control (64), how what happened to it is documented (68), and what the person using it must know (69).
A scope limit for this article: Article 64 is explained here as a regulatory duty. This article does not address physical protection arrangements for sources, which are not published, consistent with international nuclear security principles.
Article 64: three verifications, the second the riskiest in practice
The text requires sources to be kept securely so as to prevent unauthorised use or transfer, or theft or damage, and details three verifications.
First, continuity of supervision, and then a standalone duty: inform the Council immediately of information relating to the cessation of control over any source, or its loss, theft, disappearance, or loss of control over it. Several situations, not one. Loss of control is the broadest: a source whose location is known but which nobody can reach or return to a safe condition is a source over which control has been lost. The word immediately is absolute here, with no stated grace period.
A note on wording: "the Council" in the Regulation is the Supreme Council for the Environment and Natural Reserves, as defined in Article 1. Its environmental and radiation competences subsequently passed to the Ministry of Environment and Climate Change, and a facility's operational reference today is the Ministry's Radiation Protection Department. The word is retained inside verbatim quotations.
Second, no transfer before verifying the recipient's licence. This is the item most likely to be breached unintentionally. Selling a source, lending it to a maintenance contractor, handing it to a service provider, moving it to a sister company: these are situations likely to fall within the meaning of transfer, though how each is characterised is for the regulator and the licence conditions. The text places the burden of verification on the transferor. The ordinary precaution is one easy step: request and retain a copy of the licence.
Third, a periodic inventory at intervals specified in the licence. The interval is not an internal choice; it is written in your own licence.
Article 68: the register is not an inventory
The text requires a register continuously updated, containing four items. What separates it from a stock list appears in item 2, which requires the names of the persons who carried out modifications and the date of their implementation, and any accidents occurring during them.
Names of the people and the date of execution. That is a maintenance audit trail, not an asset list. Any modification to a shield, a device or a protective means must be attributable to a person and a date, and accidents occurring during them are recorded in the same register.
Item 1 requires recording the movement of sources, not only their data. Item 3 requires recording the observations made during inspection and monitoring, not merely a verdict of satisfactory; leak testing of sealed sources falls under it, though analysis of leak-test swabs is laboratory work outside the Institute's scope. Item 4 ties the register to the periodic inventory required by Article 64.
Article 69: informing is not training
Five things the source user must be told, and one of them distinguishes this article from those before it: the assurances provided by physical measures and periodic medical examinations.
The worker is told not only the hazards and the precautions but also what actually protects them and what the medical examination provides. That serves a psychological purpose as much as a practical one: a worker who understands why they wear the personal dosimeter and attend the examination complies more reliably than one who is simply told to. Periodic medical examination is health surveillance, not a means of reducing dose and not a substitute for personal monitoring.
Item 5 adds and the obligation to comply with them, so informing includes telling the worker that the instructions are binding, not advisory.
Informing is not training. Training and qualification are owed under Articles 61 and 62; informing under Article 69 is a separate duty covering even an already trained user. The text sets no interval for it, and in practice it is repeated whenever the source or the procedure changes so that the article's purpose is met.
Questions this article gets asked
May a source be lent to a contractor or service provider?
The text prohibits transferring any source to any party before verifying that the party holds the required licence. The burden is on the transferor, and in practice the verification should be documented so it can be produced at an inspection.
When must the regulator be informed?
On cessation of control over a source, or its loss, theft, disappearance, or loss of control over it. The text says immediately, with no stated period.
What is the difference between the source register and worker exposure records?
The Article 68 register concerns sources: their data, movement, modifications, inspections and inventory. Worker exposure and medical records are the subject of other articles in the Regulation.
Does informing workers replace training?
No. They are separate duties: training and qualification under Articles 61 and 62, informing under Article 69, which includes telling the worker that the safety instructions are binding.
How the Institute can help
Documented control, written memory, communicated awareness. The three articles describe a facility that knows where its sources are, what has happened to them, and who knows how to handle them.
Licensed training covering source control and record keeping, and advisory support in building the source register, the transfer verification routine and the worker briefing that Article 69 requires.
Scope of what the Institute does: licensed 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.
This article is an explanatory overview based on the official Arabic text of Executive Regulation No. (4) of 2003. It is not legal advice and does not replace your licence conditions or review by the regulator. English quotations are unofficial translations; the Arabic text prevails.