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How an RMW Treatment Facility Streamlines CoD Management

This is the final article in our three-part series on CoDs and Chain of Custody Protocols.

When a medical waste generator uses a waste services provider that has its own treatment facility, there are specific implications for Certificates of Destruction (CoDs). Besides the obvious risk mitigation due to the waste not being transported long distances, there are quite a few other considerations. Here’s what it means for the medical waste generator.

An RMW Treatment Facility Streamlines the Process

Using a waste services provider with its own treatment facility can streamline the medical waste disposal process. Instead of relying on multiple vendors for collection, transportation, and disposal, everything is managed by a single provider. This can simplify logistics and paperwork, including CoDs.

Single Point of Contact for CoDs

With an integrated provider, the medical waste generator typically deals with a single point of contact for all aspects of waste management, including CoDs. Communication and coordination become more efficient.

CoD Management by the RMW Treatment Facility

When the waste services provider has its own treatment facility, they are responsible for issuing CoDs to the medical waste generator. These CoDs serve as evidence that the waste has been properly treated and disposed of according to regulatory requirements.

Compliance Responsibility

While the waste services provider takes on the responsibility for issuing CoDs, it’s essential for the medical waste generator to ensure that the provider is compliant with all relevant regulations. This includes confirming that the treatment facility meets environmental and safety standards. The generator should also be certain that the provider follows proper waste management protocols. Case in point, a large healthcare provider recently reached a $49 million settlement for improper disposal of medical waste and patient records.

Record Keeping and CoDs

Medical waste generators who use professional services should maintain records of the CoDs they receive. Even though the provider issues the CoDs, the generator is still responsible for retaining these documents for the required retention period. Typically, regulatory requirements specify three to five years.  

Audits and Inspections

Regulatory agencies or auditors may still review medical waste generators’ CoDs, even if the provider has its own treatment facility. These audits and inspections are conducted to verify compliance with waste management regulations and ensure the waste has been handled and disposed of properly. Some waste generators have internal audit teams or hire third-party auditors or consultants to assess their compliance.

Liability and Accountability

While an integrated provider can simplify waste management, it does not absolve the medical waste generator of its responsibility of proper waste disposal. Generators have cradle-to-grave responsibility. This means that if there are any compliance issues or violations, both the waste services provider and the medical waste generator can be held accountable.


In summary, when a medical waste generator uses a waste services provider with its own RMW treatment facility, the provider takes on the responsibility of issuing CoDs. However, the generator should still be vigilant in ensuring that the provider complies with all regulations. They should maintain proper record-keeping and be prepared for audits or inspections by regulatory agencies. The process is a collaborative effort between the generator and the provider to ensure that medical waste is managed safely and in accordance with the law.


At TriHaz, we are partners in the communities we serve. We collaborate with our customers to provide custom medical waste solutions that are cost-effective, efficient, and compliant. Have questions about your medical waste management process and chain of custody protocols? We can help. Contact us today to learn more.