Am I crazy to remove my holding tank

[David M]

In some places it is illegal not to have a holding tank. Many don't care what alternative you might have.

[Mike OReilly]

Originally Posted by David M

In some places it is illegal not to have a holding tank. Many don't care what alternative you might have.

I had not heard about the requirement to have all heads attached to a holding tank. That one is news to me. I thought it was adequate to have any direct discharge head disabled (thru-hull tied off).

A composting head is considered a Type III MSD. In other words, it is considered a holding tank set up.

[somanyboats]

we have put composting toilets in 3 of our boats. 2 of them we removed the holding tanks and all the hoses and filled in the thru-hulls.
On the other boat the tank seemed to be structural, we cut a hole in the top, cleaned it really well and added a watertight cover. it is now used as dry storage. Removing all the hoses and thru-hulls gains you a lot of storage.

[john61ct]

Originally Posted by Mike OReilly

I had not heard about the requirement to have all heads attached to a holding tank. That one is news to me. I thought it was adequate to have any direct discharge head disabled (thru-hull tied off).

A composting head is considered a Type III MSD. In other words, it is considered a holding tank set up.

No. Only a holding tank is a holding tank.

But no one said "requirement to have all heads attached to a holding tank".

Originally Posted by Capn Jimbo

any head that can discharge to the water MUST have a holding tank.

The composting head is not.

The other head must be.

Originally Posted by David M

In some places it is illegal not to have a holding tank. Many don't care what alternative you might have.

Of course if you avoid these places, no worries.

[Mike OReilly]

Originally Posted by john61ct

No. Only a holding tank is a holding tank.

Wrong.
https://www.dco.uscg.mil/Our-Organiz...gineering/msd/

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.

Originally Posted by john61ct

But no one said "requirement to have all heads attached to a holding tank". The composting head is not.

Capn Jimbo just wrote: "any head that can discharge to the water MUST have a holding tank and the Y valve must be directed to the holding tank…” I’ve not heard this before.

[john61ct]

Originally Posted by Mike OReilly

https://www.dco.uscg.mil/Our-Organiz...gineering/msd/

So then by that definition, your composter counts **as** a holding tank already.

What I mean is, since the composter can **not** discharge to the water, there is no need for a useless separate additional (mainstream-meaning liquid) holding tank for that head.

[Capn Jimbo]

Can we please stop the parsing and focus on the issue?

The issue is simple and unequivocal: the OP has a working head, with a single valved outlet overboard to the sea. This is absolutely, positively illegal and will cost you dearly if you are stopped and inspected by the USCG.

To be legal, this working head must be attached to a holding tank (new or existing), controlled by a Y-valve which must be positioned (and locked/immobilized) to the holding tank position in US waters. Period, stop, no exceptions. Please don't believe me - call the Coast Guard before they call on you.

I really hate to do this, but our resident nay saying parser needs to read and understand his own hastily miscited Google links.

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.

A proper reading distinguishes the "typical holding tank" from "other types of technology" (eg a composter). The basic intent is that whichever device you use, it must "prevent the overboard discharge". Both holding tanks and the other devices (incinerators, composters, etc) achieve this.

A composter is not, not NOT a holding tank. Give it a rest...

And please - understand and follow the regulations. Your existing head valved only to overboard - is ILLEGAL.

[Don C L]

I agree you are not crazy, but you may want to hang on to all the stuff if you have storage space, and keep the thru-hulls there and capped, if you think you may want to sell one of these days... some prospective buyers may not see the beauty of the Nature's Head initially.

[Mike OReilly]

Originally Posted by john61ct

So then by that definition, your composter counts **as** a holding tank already.

That’s what I wrote when you said “no.” I had to correct you, so people don’t get misinformed.

Originally Posted by Capn Jimbo

The issue is simple and unequivocal: the OP has a working head, with a single valved outlet overboard to the sea. This is absolutely, positively illegal and will cost you dearly if you are stopped and inspected by the USCG.

To be legal, this working head must be attached to a holding tank (new or existing), controlled by a Y-valve which must be positioned (and locked/immobilized) to the holding tank position in US waters. Period, stop, no exceptions. Please don't believe me - call the Coast Guard before they call on you.

I really hate to do this, but our resident nay saying parser needs to read and understand his own hastily miscited Google links.

A proper reading distinguishes the "typical holding tank" from "other types of technology" (eg a composter). The basic intent is that whichever device you use, it must "prevent the overboard discharge". Both holding tanks and the other devices (incinerators, composters, etc) achieve this.

A composter is not, not NOT a holding tank. Give it a rest...

And please - understand and follow the regulations. Your existing head valved only to overboard - is ILLEGAL.

It is you that is inserting unfounded, oddly parsed, interpretation here. No one, ever, EVER, has made the claim you are here. And I have never, EVER, heard this claim made that a head must be attached to a holding tank. Please post the regulation so we can all read it.

A composer IS a Type III MSD. The typical commercial composters used by most boats includes a holding tank. So, show your counter-facts, or in your imminent words: “give it a rest.”

[Don C L]

From the USCG site:

Approved MSDs: There are three different types of MSDs that can be certified by the U.S. Coast Guard to meet the requirements in 33 CFR Part 159, each having its own design, certification, and discharge criteria. For more information see 33 CFR 159.53.

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.
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.
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.

and:

No discharge zone.
While operating a vessel in an EPA designated no discharge zone, flow-through devices are only permitted if adequately secured to prevent discharges of all treated and untreated sewage. For example, closing the seacock and padlocking, using a non-releasable wire tie, or removing the seacock handle are considered to be sufficient in most cases. For short voyages, locking the door to the head with a padlock or a door handle key lock is another acceptable method. For vessels that routinely operate in no discharge zones a Type III MSD is recommended. For more information see 33 CFR 159.7 and 40 CFR Part 140.

and:

Portable toilets.
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.


Y valve. Type III MSDs having a through hull Y valve must only be opened when the vessel is offshore, beyond the limit of U.S. territorial waters. At all other times, the valve must be positively secured in a way that presents a physical barrier to valve use and prevents all discharges. Adequate means include the use of padlock, non-releasable wire-tie, or removal of the valve handle. For more information see 33 CFR 159.7.

https://www.govinfo.gov/content/pkg/...2-sec159-7.pdf

https://ecfr.io/Title-40/pt40.25.140

I have not yet found anything there that states a composting toilet must be attached to a holding tank.

Given the regulations cited above, I believe a toilet with no holding tank must be rendered inoperable (seacock wired or padlocked shut) while in no-discharge zones, but I do not see yet where it is forbidden to have one on board. Since the composting toilet has no provision for discharge overboard one would gather that it is in compliance without a need for holding tank of course.

[john61ct]

Wow so much misunderstanding going on.

**No one** is saying a composter needs a holding tank, even federal bureaucrats are not that stupid.

Originally Posted by sailingunity

I still have a second head that pumps overboard.

This head is the illegal one, the only one that **does** require a holding tank,

in those jurisdictions that require one.

[john61ct]

Originally Posted by Mike OReilly

A composer IS a Type III MSD.

Yes, and as such does not require a holding **tank**, as in for holding (mostly) liquid effluent, stuff that can be **pumped out**. Words do have meanings.

Originally Posted by Mike OReilly

Wrong.

https://www.dco.uscg.mil/Our-Organiz...gineering/msd/

Nothing there says a composter requires a holding tank.

The just include the composters in the same category of other types that **do**.
_____
> The typical commercial composters used by most boats includes a holding tank.

Wut? Never seen or heard of that. Sure it has the container you poop into, but that holds solid materials only, this is not a "tank" of any sort.

A composting toilet does not have, nor does it require a holding tank.

[Mike OReilly]

Thanks for posting the full regs Don. I suggest everyone read them. No need to parse, or interpret. It’s all very clear.

Originally Posted by john61ct

Yes, and as such does not require a holding **tank**, as in for holding (mostly) liquid effluent, stuff that can be **pumped out**. Words do have meanings.

> The typical commercial composters used by most boats includes a holding tank.

Wut? Never seen or heard of that. Sure it has the container you poop into, but that holds solid materials only, this is not a "tank" of any sort.

A composting toilet does not have, nor does it require a holding tank.

Show me where you’re getting this definition of “holding tank.” Where does it say a holding tank contains "(mostly) liquid effluent.” Where?

If you knew anything about composters you would know they contain two holding tanks; one for urine and one for feces. They are two separate tanks that hold the material — you know, “holding tanks.”

[Don C L]

I believe the regulations are trying to distinguish "holding tanks" from porta-potty and composting systems, the key being that all three adequately prevent discharge in no discharge zones.

[mitiempo]

Originally Posted by Capn Jimbo

To be legal, this working head must be attached to a holding tank (new or existing), controlled by a Y-valve which must be positioned (and locked/immobilized) to the holding tank position in US waters. Period, stop, no exceptions. Please don't believe me - call the Coast Guard before they call on you.

A Y-valve is not necessary, assuming a holding tank is present. The only issue is the tank outlet seacock needs to be able to be locked closed.