About thirty years ago, he was told to bury his amputated leg himself. Without explanation, without asking if he could or wanted to. The amputated body part was once carried home in silence, as a personal obligation, even though it is one of the most dangerous types of medical waste - pathoanatomical waste, which carries serious risks to human health and the environment, because it can contain bacteria, viruses and other organisms that cause disease.
Three decades later, amputated body parts are no longer, at least officially, buried in backyards, but there is still no systemic solution. Although the Ministry of Health has been aware of the problem for a decade, the management of pathoanatomical waste remains unregulated and non-transparent.
At the largest healthcare institution in the country, the Clinical Center of Montenegro (KCCG), some of this waste is buried in a grave purchased in Zagorič, through a service contract with a private individual. The grave's capacity is already full, and there are no plans for further burial.
At the same time, according to the findings Center for Investigative Journalism of Montenegro (CIN-CG), part of the pathoanatomical waste from the KCCG, but also from certain private health institutions, ends up with the company "Hemosan" from Bar, which exports this waste from the country as chemical. This practice is not provided for by applicable regulations, and is additionally controversial, because it is not mentioned in the medical waste management plans of any public health institution, which only state the burial of this type of waste.
It is not known where part of the pathoanatomical waste, mainly from private health institutions, ends up. The Ministry of Health has no control over private institutions, while the environmental inspection has not monitored the handling of this type of waste in the past five years.
What is happening at the KCCG is only the most visible part of the problem, because pathoanatomical waste is generated wherever surgery, pathology and autopsy are performed. And the state, although it has prescribed that it is a hazardous waste, has never established a mechanism to ensure that it is handled in a uniform, controlled and legal manner. The result is a chaotic practice in which different health institutions act at their own discretion.
Director of OZON Aleksandar Perovic points out that it is surprising that The European Commission report does not point to this issue, but also to the monopolistic position of two companies dealing with medical waste disposal in Montenegro - "Ekomedik" and "Hemosan", taking into account the importance and potential consequences.
"Monopolistic influence can be seen in the context of other chapters, not just 27, e.g. in chapter 23 where the danger of corruption should be seen. The pompously announced establishment of a working body at the Supreme State Prosecutor's Office ("The VDT (VDT) that will deal with the fight against eco-crime should also be used in such complex situations in society," he notes.
Ekomedika is authorized to dispose of infectious, potentially infectious waste and sharps.
"Hemosan" exports pathoanatomical waste as chemical
“Hemosan” is authorized to accept, transport, store and export chemical and pharmaceutical waste. Hemosan does not have a license to export pathoanatomical waste.
However, as CIN-CG was told by the Environmental Protection Agency (EPA), “Hemosan” is registered in the register of collectors, traders and intermediaries of pathoanatomical waste, but under the code used for non-hazardous waste, even though the Law clearly defines this type of waste as hazardous.
"Regarding the export of non-hazardous waste, it is not subject to permits and their export is free. Hazardous waste has since been subject to a permit, however, so far this authority has not issued a single permit for this type of waste," said an EPA permit advisor. Danilo Veljic.
The Agency did not explain, given that European regulations, which we have also adopted, stipulate that hazardous medical waste, including pathoanatomical waste, is classified under a code with an asterisk, why pathoanatomical waste is treated as non-hazardous.
Contracts found by CIN-CG show that KCCG continuously engaged “Hemosan” for the collection, disposal and export of pathoanatomical waste from 2021 to 2025. KCCG confirms that some of the pathoanatomical waste is immersed in formalin (a carcinogenic chemical compound) and handed over to “Hemosan”, while the rest is buried. In that five-year period, according to their data, almost 17 tons of pathoanatomical waste were generated.
CIN-CG experts warn that soaking tissue in formalin does not change its nature - pathoanatomical waste does not become chemical.
KCCG acknowledges that the current model is not sustainable, that the graves are almost full and that the capacities of funeral companies do not provide a safe and environmentally friendly solution. They also state that some of the waste that is exported is an additional cost for the state.
"Hemosan" initially replied that they "do not work with medical waste," but after a CIN-CG reporter spoke to the company owner on the phone, they Zoran Nikitović stated that we have their contracts with KCCG on pathoanatomical waste, they replied that "they exclusively dispose of liquid pathoanatomical waste, which includes only small tissue samples that are stored in the chemical formalin according to regulations, so this type of waste is categorized according to the waste catalog under code 16 05 06* - laboratory chemicals consisting of or containing hazardous substances, including mixtures of laboratory chemicals".
"Hemosan" did not want to say with whom they still have signed contracts for the export of pathoanatomical waste, "due to data privacy policy."
The Audit of the Effectiveness of Medical Waste Management in Montenegro, from March last year, prepared by the State Audit Institution (SAI), states that the General Hospital "Blažo Orlandić" in Bar has also concluded a contract for the delivery of pathoanatomical waste with the company "Hemosan".
The hospital in Bar did not respond to what waste they were handing over to "Hemosan" and whether they were still doing so, nor why they did not inform the EPA about the change in the Medical Waste Management Plan.
The SAI Audit emphasizes that the management of pathoanatomical waste in the coming period carries the greatest risk to public health and the environment, considering that it was not adequately managed in Montenegro in the previous period.
However, despite the serious shortcomings in medical waste management pointed out by the SAI, the competent institutions have hardly reacted, and the Government and Parliament have not even held a single session or committee to address these serious health risks.
"Moj lab" also hands over waste to "Hemosan"
Only three private clinics responded to CIN-CG's inquiry about how they dispose of pathoanatomical waste.
The "Moj Lab" laboratory confirmed that they also have a multi-year contract with "Hemosan" and that, from 2022 to the beginning of last year, 349,5 kilograms of this type of waste were handed over to them.
Kodra Hospital told CIN-CG that it had purchased a burial site for the disposal of this waste, and that it had collected 770 kilograms of pathoanatomical waste from the beginning of 2022 to the end of 2025.
"The collected pathoanatomical waste is handed over to the company Funeral Services Podgorica, which transports and places this waste in a grave that the 'Kodra' hospital specifically purchased for the placement of this type of waste," the response states.
However, Funeral Services says that they do not transport and dispose of pathoanatomical waste, but only open graves.
"Funeral Services Podgorica did not perform any activities, except for opening graves, while the companies that applied for our services carried out the transport and storage of remains in graves," said the executive director of that company. Radonja Vulikic.
"ARS medika" told CIN-CG that they do not have this type of waste, because they have a signed contract with a pathology laboratory. When the journalist insisted on clarification, they said that they have a contract with that private laboratory, but that they do not know who disposes of this type of waste for them.
According to data from the Business Network, "Hemosan" has had a profit of almost 3.800.000 euros in the last ten years.
No one controls, no penalties even for the most serious irregularities
Although Hemosan claims to be under regular inspection supervision, documentation obtained by CIN-CG shows that this company was not subject to environmental inspection from 2020 to 2024. Pathoanatomical waste almost never appears in the inspection records during that period, which we obtained through free access to information.
In fact, pathoanatomical waste was not even subject to inspection by that inspection in these five years, but was only mentioned in one report from 2024, when the General Hospital (GH) "Blažo Orlandić" in Bar was inspected.
The inspectors noted that it was recorded that in 2023, among other things, about 200 kilograms of pathoanatomical waste was generated, but that "the inspector was not provided with information on how pathoanatomical waste was handled."
The Ministry of Health, as well as the Ministry of Ecology, Sustainable Development and Northern Development, had not responded to CIN-CG's numerous questions about the management of pathoanatomical waste by the time the article was published.
Hazardous classified under codes for non-hazardous
According to the Waste Management Law, hazardous medical waste (infectious, chemical, pathoanatomical, cytotoxic waste, pharmaceutical waste and sharp medical waste) should be handed over to a natural or legal person, who has an EPA permit for the processing and treatment of medical waste in accordance with the law.
According to the Regulation on the conditions, methods and procedures for the treatment of medical waste, pathoanatomical waste is disposed of in cooling chambers, in facilities for the thermal treatment of pathoanatomical waste, as well as in crematoriums or by burial in a cemetery in accordance with a special regulation.
According to the Regulation on Waste Classification and Waste Catalogue, hazardous waste is marked with an asterisk.
However, in practice, pathoanatomical waste is often in a gray area, so our healthcare institutions use codes for this waste that do not exist or are not used for hazardous waste, neither according to our nor European regulations.
In the medical waste management plan from 2025 to 2028 of the KCCG, pathoanatomical waste is entered under the code 180102*, which does not exist according to the classification, and under the code under which this type of waste should be located, only infectious waste is placed and sent to the company "Ekomedika".
The plan states that pathoanatomical waste is being disposed of in the cemetery in Zagorič, but that there will soon be no room for this type of waste there either. In the previous plan, which covers the period from 2023 to 2026, pathoanatomical waste is classified under another code, 18 01 02.
"The very fact that pathoanatomical waste is actually 'buried' somewhere indicates that the competent institutions are actually 'mourned' and with due respect for the symbolism, we should probably all express 'participation in mourning' for the inability to regulate this important area in a way that is adequate for today's civilizational achievements," Perović points out.
From a man who buried his own amputated leg to dubious contracts and unclear jurisdictions, the path is long and clouded by institutional silence, and it raises the question - why, decades later, this matter is still being resolved through temporary arrangements, instead of clear public policy.
Bonus video:
