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Old 25-10-2016, 18:31   #1
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help marine toilet compliance

I have an older boat on the hard with a toilet that goes straight to the ocean.

What options do I have to be in compliance.

Specifically can I lock or disable the toilet since I only do day sails and have no need for a toilet. Be nice to just lock the toilet so in future if I do ocean cruising I can just unlock it.

Install a porta potti ?

Really do not want install a holding tank or macerator.

Thanks for any help.

arch
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Old 25-10-2016, 18:52   #2
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Re: help marine toilet compliance

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Originally Posted by arch007 View Post
I have an older boat on the hard with a toilet that goes straight to the ocean.

What options do I have to be in compliance.
Specifucally can I lock or disable the toilet since I only do day sails and have no need for a toilet. Be nice to just lock the toilet so in future if I do ocean cruising I can just unlock it.
Install a porta potti ?
Really do not want install a holding tank or macerator. arch
In that case your best option would be to replace the toilet with an "MSD" version portapotty. The "MSD" designation in the model number means it's fitted for pumpout and designed to be permanently installed, which means that although it's still called a PORTApotty, you don't have to carry anything off the boat to empty it. A 5-6 gallon model holds 50-60 flushes...you'd need at least a 30 gal tank to hold that many from a manual marine toilet. No plumbing needed except a vent line and pumpout hose--so no new holes in the boat...and -0- maintenance needed except for rinsing out the tank--which you can do with a bucket while it's being pumped out. Cost including the pumpout hose and vent line is about $200--a fraction of what you'd spend for toilet, tank and all the related plumbing needed. And the best part is, you have all the advantages of a toilet and holding tank without giving up a square foot of storage space. Check out the Thetford 550P MSD and the Dometic/SeaLand 565MSD.
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Old 25-10-2016, 19:46   #3
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Re: help marine toilet compliance

Thanks.

But what do I do about my existing toilet ????????????

I do not want to take it out since I may need it in future for ocean cruising.

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Old 25-10-2016, 20:24   #4
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Re: help marine toilet compliance

If you want to leave the toilet in place, just close the seacock and lock it closed.

I'd be inclined to install a holding tank so you can use it. It's not a hard job and having a working toilet makes the ladies happy even on just a day sail.

Get a copy of Peggie's book. It will tell you how to install the holding tank the right way.
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Old 25-10-2016, 20:25   #5
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Re: help marine toilet compliance

If you’re cruising with one or two people you could go with a composting head. Means pulling the existing head, but no reason to go back once you’ve gone compost.
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Old 25-10-2016, 20:38   #6
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Re: help marine toilet compliance

You said it's an older boat....which means the toilet has been sitting as long as the boat's been sitting. All the rubber parts in the pump have dried out and started to crumble. So unless the toilet is a $1000 all bronze "throne," you could replace it for less than it would cost you to get it into working order now...you can buy a new one for about $150. But if you do that, you'd have to add a holding tank and all the related plumbing too.

Sp the only smart thing to do is toss it, install an MSD portapotty (tidy self-contained toilet and tank)...and swap that out for a new toilet if/when you ever set sail for far off ports.
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Old 25-10-2016, 21:12   #7
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Re: help marine toilet compliance

My Hunter 27 is like that, direct discharge only, but I am adding an internal tank. The macerating pump is actually part of my new commode, and so saved me having to purchase it as a separate part (though I suppose that means that if it kicks off, I have to replace it perhaps with a more specialized pump unit than some off the shelf Harbor Freight device).

I attempted to move the petcock valve on the through-hull discharge today, and it is firmly stuck closed. I guess that takes care of that, no thru hull discharge! If I want to pump out offshore, I will have to use some form of other pumping unit, and that is gonna kinda suck, I think... and smell to boot.

I am curious, though, as the H27 models near my 1978 timeframe supposedly came with a 13 gallon tank (though, like the standard wheel steering, mine was absent several amenities when built). I have a great number of options at the moment as the refit is not yet complete, but the next step is to install a holding tank and I don't know how large of one to install. I was thinking 13 was perhaps a little on the small side, and thinking perhaps a 20+ tank would be better because at least I would have the option for the additional 7+ gallons, just in case I was having issue locating a pump station (as I, again, cannot discharge over the side, even offshore).

What opinions do folks have about holding tank size, and what has worked for you, what is too small, and is there a "too big" rating or indication? There will be two people using this unit, one male, one female, if that makes a difference, and we are going to be part time living aboard (job issue), coastal cruising, and perhaps hitting the Caribbean, Gulf of Mexico, and MAYBE seeing some of Mexico or perhaps South America if the drug lords and criminals are not making trouble at the time of interest. I sure wish that through-hull valve worked...
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Old 26-10-2016, 05:37   #8
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Re: help marine toilet compliance

Reprint of an article I wrote a couple of years ago... As far as I know, all info still applies (I could be wrong, not the first time)

Quote:
The "Poop" on "Poop"

Started a thread looking for some info on Boot Key moorings and it devolved into poop. Not what I was looking for, but a worth while discussion. Anyway people seem to want to talk about it so I thought I would start a new thread here in the hopes of getting some staight poop on poop as it were.

Disclaimer: I am not a lawyer nor would I wish to be. However, the rules are the rules and need to stand on both sides. If however, you know you are right, and decide to stand up to the local authorities, you will probably find yourself holding a bucket of poop. Right or wrong, they can make your life miserable and it's always a question of "is the principle worth the repercussions". For me, at 19 yrs old the answer was yes..... Close to 6 decades later, not so much. The regs cited below apply to US waters (and their possesions) only. Most opinions as to requirements are based on the USCG guidlines as they have the final jurisdiction. "County Mounties enforcing, do so with the acceptance of the USCG and with the exception of "Houseboats" may not apply state regulations. (See Houseboat definition below). Be aware that contracts between boat owners and state or private marina facilities that may require approved Type III MSD do not violate the Title 33 Regulations.



Some Definitions...

MSD: Marine Sanitation Device. Equipment that prevents discharge of untreated sewage from vessels into the waters of the United States.(1)(2)

Sewage: Human body wastes and the wastes from toilets and other receptacles intended to receive or retain body wastes except that, with respect to commercial vessels on the Great Lakes, such term shall include graywater (1)

Graywater: Galley, bath, and shower water (1)

Houseboat: A vessel which, for a period of time determined by the State in which the vessel is located, is used primarily as a residence and is not used primarily as a means of transportation.(1) (Note: Federal Definition, not local)


FAQ

1. Do I have to have a toilet on my boat?

Short answer, No.... However as with anything their are some qualifications involved.
Did your boat come originally with a head? If no, sail on... If yes, you must either keep it in operational condition, or Vessel owners may elect to remove installed toilets and use instead portable toilets(2). For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable.(2)




2. What are the classes of MSD

Type I is a flow through discharge device that produces effluent having a fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating solids. This type of device is typically a physical/chemical based system that relies on maceration and chlorination. Type I MSDs are issued a Certificate of Approval.(2)

Type II is a flow through discharge device that produces effluent having a fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not greater than 150 milligrams per liter. This type of device is typically a biological or aerobic digestion based system.(2)

Type III is a device that prevents the overboard discharge of treated or untreated sewage or any waste derived from sewage. This type of device is typically a holding tank and may include other types of technology including incineration, recirculation, and composting.(2)


3. What are the acceptable means of "locking out" the overboard discharge in a no-discharge area?

Closing the seacock and removing the handle;
Padlocking the seacock in the closed position;
Using a non-releasable wire-tie to hold the seacock in the closed position;
Locking the door to the space enclosing the toilets with a padlock or door handle key lock.(4)


4. What about "Porta-Potties"?

Vessels having no installed toilet are not subject to the provisions of Section 312 of the Act. Portable toilets or porta-potties that use no installed water, power, etc., are not considered installed toilets and therefore not subject to the requirements in 33 CFR Part 159. However, regulations still exist to prohibit disposal of raw sewage within U.S. territorial waters, the Great Lakes, and navigable rivers. Use of portable toilets in combination with a direct discharge toilet is not permitted. Vessel owners may elect to remove installed toilets and use instead portable toilets. For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable. For inspected vessels using portable systems, use only devices manufactured of a durable material, such as molded plastic, aluminum, etc., to facilitate removal ashore, securely fastened to the vessel using straps, wooden framing, or similar materials, and maintained by the vessel operator following the manufacturers instructions as to waste disposal, chemical additives, etc.(2)

5. What about Composting Toilets?

USCG accepts Composting Toilets as a type III along with holdihg tanks, incineration and recirculation.(2) However, all composting toilets must be approved if installed after Jan 30, 1976.(1)(2)(4)(5) It could be argued that Composting Toilets are in fact, not an MSD but rather a Portable Toilet with a rather long cycle time.

6. Is "Greywater" included in the No-Discharge-Zone ?

IMHOP No.... (with the exception of commercial vessels)
No permit shall be required under this chapter by the Administrator (or a State, in the case of a permit program approved under subsection (b)) for the discharge of any graywater, bilge water, cooling water, weather deck runoff, oil water separator effluent, or effluent from properly functioning marine engines, or any other discharge that is incidental to the normal operation of a vessel, if the discharge is from a recreational vessel.(3)


Final Notes:

None of us wants to poop in our own front yard... Especially in a crowded anchorage. Swimming round the brown trout is no fun. And yet, we also do not need to be bound by mindless bureaucracy when a better path exists. Hence this thread. What works for you? How did you convince the local authorities you were legit? What questions do you have that haven't been addressed? And so on....

One final reminder. If you are in a position where you are signing a rental agreement with anyone. State, City, Private, whatever... you are playing in their court. They are within their rights to tell you your boat has to be blue to rent there if they want. No use to bitch... Just move on.

Cap' Couillon


References:
(1) USC Title 33 › Chapter 26 › Subchapter III › § 1322
(2) USCG Systems Engineering Inspection Guidlines
(3) Title 33 › Chapter 26 › Subchapter IV › § 1342
(4) Title 33: Navigation and Navigable Waters PART 159—MARINE SANITATION DEVICES
(5) EPA Marine Sanitation Devices
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Old 26-10-2016, 05:51   #9
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Re: help marine toilet compliance

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Originally Posted by Mike OReilly View Post
If you’re cruising with one or two people you could go with a composting head. Means pulling the existing head, but no reason to go back once you’ve gone compost.

I agree, in my opinion this would be the smartest thing to do.


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Old 26-10-2016, 06:22   #10
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Re: help marine toilet compliance

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Originally Posted by peghall View Post
You said it's an older boat....which means the toilet has been sitting as long as the boat's been sitting. All the rubber parts in the pump have dried out and started to crumble. So unless the toilet is a $1000 all bronze "throne," you could replace it for less than it would cost you to get it into working order now...you can buy a new one for about $150. But if you do that, you'd have to add a holding tank and all the related plumbing too.

Sp the only smart thing to do is toss it, install an MSD portapotty (tidy self-contained toilet and tank)...and swap that out for a new toilet if/when you ever set sail for far off ports.
Mine came with an old Thetford with 5-6 gallon holding tank, hand pump, and Y valve. The boat had sat on the hard for 5 years before I bought it.

When I started using the boat and the thetford marine toilet, it would stink to high heaven.

After reading a few of PegHall's recommendations in other threads. I cut out the hand pump plus all junctions, joints, connections etc. and capped of the remaining hoses.

Before you could pump over the side with the hand pump if far enough offshore or get a pump out. Now you can do neither but it doesn't stink.

Maybe once a season I remove it and take it to the facility at Cobb's and dump it......I use Odorlos in the tank also

I'm a coastal cruiser and am many times anchored close enough to use land based facilities......

Thetford 2016 version

THE 24463 - Aquamate 875 Msd Marine Head by Thetford - Toilets & Accessories Plumbing - All Points Marine
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Old 26-10-2016, 07:21   #11
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Re: help marine toilet compliance

The only thing I believe may have changed is that composting heads have to be approved. I have a letter from the USCG about this same issue, asked specifically about composting heads, and he says differently:

After conducting research into the approval requirements for marine sanitation devices contained within CFR 33 159.12A, 159.53C and 159.7; Type III MSD's are not require to be Coast Guard approved. Which means that the composting toilet does not have to be approved either. I contacted FWCC concerning the legality of porta-potties as well, there is currently no regulation concerning their use in place of a traditional toilet. The only concerns for both the Coast Guard and the state of Florida is the discharge of its contents.

If you have any questions, please feel to contact me.

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Old 26-10-2016, 07:24   #12
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Re: help marine toilet compliance

The only thing I believe may have changed is that composting heads have to be approved. I have a letter from the USCG about this same issue, asked specifically about composting heads, and he says differently:

After conducting research into the approval requirements for marine sanitation devices contained within CFR 33 159.12A, 159.53C and 159.7; Type III MSD's are not require to be Coast Guard approved. Which means that the composting toilet does not have to be approved either. I contacted FWCC concerning the legality of porta-potties as well, there is currently no regulation concerning their use in place of a traditional toilet. The only concerns for both the Coast Guard and the state of Florida is the discharge of its contents.

If you have any questions, please feel to contact me.

v/r

DC2 Nicholas Martinez
Housing Petty Officer
USCG STA ISLAMORADA
183 PALERMO DR.
ISLAMORADA, FL 33036
W:305.664.8077
C:305.467.5796
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Old 26-10-2016, 07:46   #13
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Re: help marine toilet compliance

A Type III MSD is "a device that is designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage." Any device that meets that definition is considered automatically certified by the USCG. A composting toilet meets that definition, so is automatically a certified Type III MSD.
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Old 26-10-2016, 07:53   #14
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Re: help marine toilet compliance

I attempted to move the petcock valve on the through-hull discharge today, and it is firmly stuck closed. I guess that takes care of that, no thru hull discharge! If I want to pump out offshore, I will have to use some form of other pumping unit, and that is gonna kinda suck, I think... and smell to boot....I sure wish that through-hull valve worked...

What's preventing you from repairing/replacing the seacock/thru-hull?

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Old 26-10-2016, 08:30   #15
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Re: help marine toilet compliance

If there is no visible lock on your stuck valve you are asking for Marine Patrol problems. You can avoid any questions by installing a $5 lock. Seems like a no-brainer to me.
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