Overboard holding tank discharge

[Mr B]

Thats different to what you asked, You want to pump out your tank,

Submersible Sludge pump off Ebay.com They will give all the specs on how high they will lift, They are very cheap these days,
Or you can get one with a hose that will drop into your tank if the Pump wont fit it,

I would go the hose into your tank, Pump on deck, Not as messy as cleaning a pump thats been in the tank,
Two miles offshore you can discharge your tank over the side,

[a64pilot]

Thanks Peggy, but that is the identical link I posted.

Guys I got, I understand the intent of the law.
Intent however is not the letter of the law, the letter of the law is clear, it gives you three options to secure the valve and allows locking the heads.
No other means are acceptable.
There are several other rather silly examples I believe, it is the same with most CFR's. I want to think for example that I'm not allowed to store my life vests in the container they come in, although I may be wrong. They stem from trying to do the right thing, but often get over complicated trying to cover loop holes and do not cover many possibilities.

I'm not trying to be argumentative, just I'm refurbishing my entire waste system, they way that is was manufactured it can't be in compliance as one valve does not have a removable handle. I guess now my best course of action is to epoxy something that I can zip tie the valve handles to after drilling a hole in them, yes it's silly as the devil, a zip tie is not going to prevent anything, but a ticket

[rwidman]

Originally Posted by a64pilot

............. the letter of the law is clear, it gives you three options to secure the valve and allows locking the heads.
No other means are acceptable............

That is not what it says.

Read my post again.

[nautical62]

Personally I would not purposely build a system to discharge overboard from the deck pump out. For overboard disposal, my favorite system is a simple gravity feed. Simply open the through hull below the holding tank and let the contents drain out where legal and appropriate. A pump can clog, can break down, adds two more hose clamp points that could leak and requires pumping. Much simpler to let it drain if possible. Secure per regulations when required.

I get thinking about the hazard of below waterline through hulls, but most boats have several and this one you can keep closed when you are not personally looking at it if you so desire.

[a64pilot]

Originally Posted by rwidman

That is not what it says.

Read my post again.

Right, that is your interpretation, mine is they give you four acceptable methods, pick one.
I feel if I have this CFR printed and keep a copy to show Barney and have used one of those four methods, I'm good.
Lawyers make their living arguing semantics, I don't .

Try looking at it this way, if you don't use one of those four who determines acceptability? A reasonable person?
What if I put a ribbon on the seat holding it down, isn't that securing the head, or I put a sticker on it that says don't flush unless three miles off shore and not in a no discharge zone, will that work?
I'm being sarcastic intentionally to show that if you don't use one of the four, then it's up to Barney to decide if your legal or not, and he may have a burr up his butt and decide your method is not acceptable.
Your transiting through, you going to fight it? Of course not, and he knows that.

Now I'll be the first to say that in my opinion, your method is likely to be realistically more effective than a silly wire tie, but my opinion doesn't mean anything

[Safari38LH]

Put a thru hull in so you can discharge the head directly overboard when you are offshore. We have two Y valves, one for the head, directly overboard or to the holding tank. The other Y valve is for the holding tank, either overboard via macerator or to pump out fitting on deck.

[peghall]

I made no attempt to interpret the reg, I only published it exactly as written. So exactly what did I post that you are "yes, but(ting?"
Peggie
"If you can't explain it to a six year old, you don't completely understand it yourself." --Albert Einstein
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[David B]

Originally Posted by nautical62

Personally I would not purposely build a system to discharge overboard from the deck pump out. For overboard disposal, my favorite system is a simple gravity feed. Simply open the through hull below the holding tank and let the contents drain out where legal and appropriate. A pump can clog, can break down, adds two more hose clamp points that could leak and requires pumping. Much simpler to let it drain if possible. Secure per regulations when required.

I get thinking about the hazard of below waterline through hulls, but most boats have several and this one you can keep closed when you are not personally looking at it if you so desire.

My preference also. Our system uses Jabsco 'Quietflush' (someone in Jabsco was obviously trying to be a comedian there !), which macerate as they pump into the tanks. Simple valve on through-hull to dump where appropriate, or vacuum pump-out through the top via a deck fitting.

Only potential issue is the hose leading from the bottom of the tank to the through-hull. If not used regularly, contents could compact leading to blockage, but ours is regularly emptied that way so no problem. Ideal would be to have a valve at the bottom of the tank also, but access is usually an issue there. Having said that, I must have a look when we are on-board next - there may be some possibilities for an extended shaft valve, and it would be better than reaching down into the bilge in a seaway (pushbutton electric valve with timer would be nice, but now we are getting carried away )

[rwidman]

Many (perhaps most) boats cannot be pumped out (or drained) from the bottom of the holding tank because the tank sits on or very near the hull. There's no room for fittings or pumps. Also, it would be very difficult to operate a seacock that's under a holding tank.

Most of us are dealing with factory made boats, not designing and building boats so we have to deal with what we have. My boat has no valves so wiring them shut is not an option. Installing a valve is not an option either.

[David B]

I am wondering if the trend with some production boats now is to have the tanks up higher, so they do gravity drain. Let's face it, bilges are getting pretty shallow these days unfortunately, so there is not a lot of room down there. Beneteau, Jeaneau etc seem to have theirs all up high.

There is room under ours for a valve - just a matter of whether access would be better than the current seacock at the other end of the discharge hose. Another thing for my list to check now. Improving production boats is a reasonably pleasant pastime I find

[a64pilot]

Originally Posted by peghall

I made no attempt to interpret the reg, I only published it exactly as written. So exactly what did I post that you are "yes, but(ting?"
Peggie
"If you can't explain it to a six year old, you don't completely understand it yourself." --Albert Einstein
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I posted the CFR as well, same link you did as it was the first Google popped up as opposed to the .gov site, I live with CFR's, it is what I do for a living.
What I am butting is the CFR gives you three ways to deal with securing the valve, and failing that allows you to lock the door to the heads. No valve? Lock the heads then, don't invent your own method, it may be better, but its not covered in the CFR, and the CFR does not have language like "or any other means that safely prevents inadvertent discharge". If it did have language like that, then you would be free to come up with your own solution
Not doing any of those four things leaves you at the discretion of the inspector, who may determine your not in compliance. It is possible I believe that they may determine that without a valve you have been discharging, and I believe the fine for that is substantial?
If you use one of the four cited examples, then there is no discretion, your in compliance.

Is this tilting at windmills? Probably.

What we do in my job when an FAR isn't achievable, or applicable is we get a letter from our Aircraft Certification Office stating what measures are acceptable in lieu of, or we have achieved an equivalent level of safety by other means etc. An exemption if you will.

I believe LEO's at different levels can cite you, am I correct, even the Local Sheriff? It doesn't take the USCG?

I'd like myself to see the verbiage in the CFR changed to say "or other means that will safely prevent inadvertent discharge" myself

[a64pilot]

An issue with high mounted waste tanks is that the head will have to pump the effluent up hill, meaning the hose will always be full and the Joker valve is even more important as its the only back flow valve, isn't it? If your tank was lower than the head, then if you were careful with hose routing, it could drain after each flush and now no back flow, and I assume your hose will last longer before it permeates?
Not sure though if any tanks are actually lower than the heads though?

[SV DestinyAscen]

Eh the CFR lists some safe harbors. But I've yet heard of a single enforcement action about someone with a closed seacock getting in trouble because they didn't have a lock, zip tie or handle removed. I mean - if the locked bathroom works, masking tape over the toilet pump probably counts too. Me thinks the regs are written primarily targeting operators of commercial vessels like a cruise ship/ferry/tug where institutional compliance is more of a concern.

[Opie91]

Originally Posted by a64pilot

Not doing any of those four things leaves you at the discretion of the inspector, who may determine your not in compliance..........
If you use one of the four cited examples, then there is no discretion, your in compliance.

This is what it boils down to.

Unlike aviation where inspectors are mostly skilled professionals, the discharge laws are enforced by many agencies/municipalities that have their own agenda.

[a64pilot]

Originally Posted by Opie91

This is what it boils down to.

Unlike aviation where inspectors are mostly skilled professionals, the discharge laws are enforced by many agencies/municipalities that have their own agenda.

That is why I am going to go the zip tie the valves route, as is right now I don't have a valve in the Macerator hose, they are cheap and I have a Lowes 1" Ball valve that I will install for the sole purpose of being able to zip tie it closed, even though the valve will serve no other purpose.
My choice, I have had run in's with Barney Fife rarely, but it irritates me when I do, so the valve is worth it to keep from being irritated and trying to explain the intent of the CFR to him or her.
I was going to lock the compt. the valves are in until I reread the CFR, and what it says is lock the door to the toilets, which is nonsense of course, cause that assumes no holding tank I assume?
So yes like all FAR's, CFR's etc. they are open to interpretation. I'm just trying to make it so the local LEO that knows nothing at all about marine sanitation won't give me a ticket, cause what they really want is me not anchoring in their County.