Am I crazy to remove my holding tank

[Mike OReilly]

Originally Posted by 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.

My reading of the regs you posted make a point of differentiating "Approved MSDs” from "Portable toilets.” People (me included) seem to be interpreting how a composter qualifies as a Type III. To me, it seems obvious that it fits here b/c it has a holding tank (two, in fact), but I grant this is my interpretation. I suppose composters could simply be a separate category unto themselves. Regardless, the salient point is that composters are legal, and are Type III MSDs.

As to whether all heads must be attached to holding tanks, I am still waiting to see the reg that states that. From the post here it seems clear that securing the outflow thru-hull is sufficient:

“...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.”

[gaucho]

What size holding tanks did some of you have? Jeez. When you list all the stuff you now put where your holding tank was, Im thinking ... this people generated A LOT of waste. Haha.

[CapnBazza]

Originally Posted by sailingunity

I have about a 25 gallon holding tank on my boat, but to eliminate our reliance on pumpouts I replaced the head that was connected to it with a composting head. I still have a second head that pumps overboard. I'm thinking about removing the holding tank to increase my storage - it is not that old, installed in 2007. The composting head makes us legal, technically, and I would be quite happy to never have to visit a pump out station again. I'm just wondering if anyone has any opinions on why we might want to keep it?

I did keep the old head that was in there, and if we leave the US for an extended time I might reinstall it in overboard mode.

Probably no crazier than I am because I’m about to put one in. Regulations in Australia require it. (Forget your composting heads, I’m no sh*t stirrer!)

[Brewgyver]

Originally Posted by Mike OReilly

My reading of the regs you posted make a point of differentiating "Approved MSDs” from "Portable toilets.” People (me included) seem to be interpreting how a composter qualifies as a Type III. To me, it seems obvious that it fits here b/c it has a holding tank (two, in fact), but I grant this is my interpretation. I suppose composters could simply be a separate category unto themselves. Regardless, the salient point is that composters are legal, and are Type III MSDs.

Yes, composting toilets are Type III devices, but no, they are not holding tanks. That's why the CG regs spell out that Type III "may include other technologies." Those other technologies, including composting, ARE Type IIIs, they are NOT holding tanks.

As to whether all heads must be attached to holding tanks, I am still waiting to see the reg that states that.

I haven't found it yet, but I've seen it. I've also seen two youtube videos in which the sailors installed new holding tanks, because they had pulled them out while outside the U.S., but did the smart thing and contacted USCG to ask the question, and were told unequivocally that if they had a flush toilet it HAD to be connected to a holding tank, and if not they would face the penalties when caught. Notice I didn't say if. There was even one popular YouTube couple who removed their holding tank to gain usable space, and replaced it with what they hoped would be deemed a holding tank, made from about two feet of 4" PVC pipe.

From the post here it seems clear that securing the outflow thru-hull is sufficient:

“...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.”

The last paragraph that you quoted pertains to Type I and Type II sewage treatment devices, like the Electro Scan.

[BigNut]

I must say I find this whole issue simple to parse. All the relevant laws are available at: www.epa.gov.

There are 3 types of waters (at least for this purpose and for Americans, I am not one):

1. Greater than 3nm offshore
2. Less than 3nm offshore
3. Less than 3 nm offshore AND otherwise limited, as in, eg a No Discharge Zone.

There are 3 kinds of MSDs.
If you wish to enter waters closer than 3nm, you MUST have an MSD.
If you enter waters that are otherwise limited, you MUST have AT LEAST a Type III AND follow the rules regarding securing the outflow from a Type I or II.

See picture.
Perhaps I have missed something?

[BigNut]

Can I use a composting toilet onboard my vessel?

Composting toilets may be considered a Type III marine sanitation device by the U.S. Coast Guard.

From the epa website

https://www.epa.gov/vessels-marinas-...ions#graywater

[BigNut]

How does a vessel operator comply with an NDZ?

The requirements for vessel operators are described in 33 CFR 159.7(b)-(c) (PDF) (2 pp, 190 K). The regulations allow for four methods of securing a Type I or II marine sanitation device (MSD) while in an NDZ, including:
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; or
Locking the door to the space enclosing the toilets with a padlock or door handle key lock.
For Type III devices, the following options are available:
Closing valves leading to overboard discharge and removing the handle;
Padlocking any valves leading to overboard discharge in the closed position; or
Holding overboard discharge valves closed using a non-releasable wire-tie.

https://www.epa.gov/vessels-marinas-...rge-zones-ndzs

[Mike OReilly]

Originally Posted by Brewgyver

Yes, composting toilets are Type III devices, but no, they are not holding tanks. That's why the CG regs spell out that Type III "may include other technologies." Those other technologies, including composting, ARE Type IIIs, they are NOT holding tanks.

So, I went to the actual legislation (TITLE 33—Navigation and Navigable Waters, CHAPTER I—COAST GUARD, DEPARTMENT OF HOMELAND SECURITY, SUBCHAPTER O—POLLUTION, PART 159—MARINE SANITATION DEVICES159.3).

There is NO definition of holding tank. I suppose it is self-evident: it is a tank that holds stuff, in this case, human effluent; just like a typical composter. Perhaps there is an interpretation of the definition in legal precedent. I’d appreciate seeing it. Otherwise, we are all just imposing our own interpretation.

It is all a moot point. The salient point is that it is a Type III MSD. BTW, there is a definition of Type III MSD:

Type III marine sanitation device means a device that is designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage.

You are correct, the quote I referenced refers to Type I and II MSDs. Type I is the typical macerator/chlorinated treatment. Type II is the on board treatment like Electrosan. I assume the OP’s direct discharge head is a Type I, but in that I may be in error.

[BigNut]

Originally Posted by Mike OReilly

There is NO definition of holding tank.

I think you can make the point that the definition of a Type III applies equally to a composter/dehydrator, and you quoted it perfectly. There is no PERFORMANCE standard. Nada is nada!

[Paul L]

Originally Posted by BigNut

I think you can make the point that the definition of a Type III applies equally to a composter/dehydrator, and you quoted it perfectly. There is no PERFORMANCE standard. Nada is nada!

To be accepted by tbe USCG as marine sanitation device for a US base vessel I'm prettt sure it hax to have a Type Certificate of Approval.
https://www.dco.uscg.mil/Our-Organiz...msd/#equipment

[coopec43]

Well after reading all that I am a bit confused. Am I correct in concluding:

• You cannot discharge direct into the ocean even from deck level in the dark of the night?
• It is legal to use the toilet but once the toilet bowl is full you have to go 3 km offshore to discharge it?

[atlroofman]

Originally Posted by Capn Jimbo

The law and regs here in the US are simple: any head that can discharge to the water MUST have a holding tank and the Y valve must be directed to the holding tank, and must be securely locked (not just directed to the tank) in that position. You must also have a flue or vent over the installed head. The existence of a composter, porti-potty, or 5 gallon bucket does not relieve you (pun intended) of these regs.

Do yourself a favor and call the Coast Guard.

Yes sir he's got it.
The man is right, got to have a tank here.

[BigNut]

Originally Posted by Paul L

To be accepted by tbe USCG as marine sanitation device for a US base vessel I'm prettt sure it hax to have a Type Certificate of Approval.

The quote in post 36 is directly from the EPA website.

[sailingunity]

Wow this has turned into quite the discussion. I appreciate the advice, however I don't see how having a holding tank with a closed seacock vs a direct overboard with closed seacock makes any difference. The toilet won't flush with the seacock closed. Anyway, it seems like something that is open to interpretation, that is, I could call one coast guard station and they might say no holding tank is fine, while the next would say I need one. It's not possible to install a holding tank on my 2nd head, the boat was built in 1974 and there just isn't the space back there for it. Perhaps the thing to do is move the composting head aft, and the one that is currently pumping overboard forward to where it can connect to the holding tank.

[john61ct]

Why couldn't you flush into a locked-outlet holding tank?

That is what they are for. . .