Am I crazy to remove my holding tank

[mitiempo]

Originally Posted by sailingunity

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......

Not really. They know you will use the head if on the boat for any length of time. Not flushing is a very temporary solution. Therefore any flush type marine head needs a holding tank.

[Don C L]

Originally Posted by 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.

Yes, that's what I'd do or get two composters. (Do you need 2?) As I read it, if you are in a no discharge zone, you must have a working MSD and it must not be able to discharge. If you have 2, my read on it is that as long as you have one MSD that complies, the other must have the seacock locked or wired shut. If you want to move the composter aft then you'll have 2 heads in compliance and no need to lock the seacock. But that is just my take on it after reading it through a few times. But, after being checked twice I was told that you have to have a holding tank, a porta potty or a composter (they simplified it for me.)

[Don C L]

By the way, Defender has one of these all-in-one toilets which I have not seen in action but I thought was interesting. 9.5 gallons is not bad when you consider that you don't need to waste a lot of water in the flushing. It might fit. Might be an option to consider.
https://www.defender.com/product.jsp...4286&id=105225

[mlydon]

Could someone who has stated that all heads must run to a holding tank please post the actual rule that says so? My understanding is that all heads “must be secured against accidental discharge” overboard. And yes, “every vessel blah blah, must have a type x device”.

That doesn’t mean that EVERY head must run to a holding tank. Just that you aren’t putting sewage overboard, and have the means to either treat it or store it, to my eye.

One head used in regulated waters, hooked up to a holding tank, the other direct out for use on passages, should be perfectly legal

Am I wrong?



Thanks,

Matt

[Don C L]

Originally Posted by mlydon

Could someone who has stated that all heads must run to a holding tank please post the actual rule that says so? My understanding is that all heads “must be secured against accidental discharge” overboard...period stop

Thanks,

Matt

Well... the #2 has to go somewhere... even if there is no specific rule, I'd guess it's pretty well implied (for heads that are not self-contained) for anyone operating a boat in a no discharge zone, no? I mean you can't lock the seacock and then claim you've been able to hold it for the last few weeks or so...

[BigNut]

Originally Posted by mlydon

Could someone who has stated that all heads must run to a holding tank please post the actual rule that says so? My understanding is that all heads “must be secured against accidental discharge” overboard. And yes, “every vessel blah blah, must have a type x device”.

That doesn’t mean that EVERY head must run to a holding tank. Just that you aren’t putting sewage overboard, and have the means to either treat it or store it, to my eye.

One head used in regulated waters, hooked up to a holding tank, the other direct out for use on passages, should be perfectly legal

Am I wrong?

Thanks,

Matt

In order to discharge within three miles, sewage must be treated using a U.S. Coast Guard-approved Type I or Type II MSD. Alternatively, sewage may be stored onboard in a holding tank (Type III MSD).

If the head is OPERABLE, it needs to use an MSD which cannot discharge. The only MSD that cannot reasonably discharge is Type III.

So, if you have a vessel with installed toilets, you can lock away all of them (make them inop) except one. Can’t see any issue there, on a regular cruising vessel.

From the links to the EPA I provided above.

[BigNut]

And the rest of that quote:

Treated and untreated sewage discharges are prohibited in:
Freshwater lakes, reservoirs and other freshwater impoundments whole inlets or outlets are such as to prevent the ingress or egress by vessel traffic.
Rivers not capable of navigation by interstate vessel traffic.
No-discharge zones (NDZs) (as applicable).
In these areas, sewage effluent generally must be retained onboard in a holding tank (Type III MSD). Operators of vessels equipped with flow-through MSDs (Type I or Type II) must secure the device to prevent overboard discharge.

[Paul L]

Originally Posted by 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

May be considered is certainly true. It is my undetstanding tbey have to be certified by USCG for them to actually be marine type iii for a US registeted boat.

[Capn Jimbo]

Originally Posted by mitiempo

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.

Keep in mind the OP has a head single valved overboard. You are right if he disconnects and blocks that through hull, but then the head must be connected to a holding tank (in his case perhaps his existing tank). The tank must be more than "present", it must be connected to the head if he intends to use it. Since the boat is already plumbed for overboard, and he has to connect to a tank anyway (and he has one possibly already installed), I'm not sure why he'd want to give up the overboard option just to save a Y-valve.

To the Master Debator: I do not answer to you. Since you seem to have all the answers, YOU cite the regs which support your unsupported beliefs. I completely disagree, I know the regs. I choose not to engage. The OP now knows his options and risks, and can call the Coast Guard. Please breathe, mate...

[Capn Jimbo]

Maritime Sanitation > Vital Info > The Law

"Marine Sanitation Devices

The Federal Clean Water Act requires that all boats with an installed head have one of three types of Coast Guard approved marine sanitation devices (MSD's) attached to the toilet. Failure to comply can result in a $2,000 fine.

Type I and II MSD's are flow-through systems that treat the sewage using chemical, electrical and/or incineration methods before discharging the waste overboard; i.e., Lectra-San or Microphor. A macerator pump is not an MSD.

Type III MSD's are holding tanks that store sewage on the boat. The waste is not treated in a Type III device, even if odor-reducing chemicals are added. It is illegal to discharge or empty the contents of your boat's holding tank in U.S. territorial water ( within a three-mile limit).

Some boats are equipped with a "Y" -valve that allows for the direct discharge of raw sewage. This valve can only be used outside the three-mile limit. Coast Guard regulations require that the "Y"-valve must be secured in the closed position (by padlock, non-resealable tie, removal of handle or other physical barrier) when the boat is within three miles of shore. Boaters can be fined for non-compliance.

If you use a portable toilet, remember it is illegal to dump it overboard. Use shore side facilities to empty it. SPECIAL NOTE: Waste treated by Type I and II MSD's is unhealthy for marine waters because (1) chemical treatmentt often sanitizes only the outer surfaces of waste clumps, (2) chemicals routinely used in MSD's are harmful to sea life and water quality (chlorine, formaldehyde, formaline, phenol derivatives, ammonia compounds), (3) poorly maintained MSD's may not treat effluent to the prescribed standards, and (4) even treated sewage contributes nutrients and lowers dissolved oxygen levels in water, lowering water quality for marine life."

"I never heard of that" is not an argument. If the glove don't fit, you must acquit, lol. Carry on..


*********
Also:https://www.boatus.org/study-guide/environment/waste/

[Mike OReilly]

Originally Posted by Paul L

May be considered is certainly true. It is my undetstanding tbey have to be certified by USCG for them to actually be marine type iii for a US registeted boat.

Here’s the certification requirement for Type III MSDs:

§159.12a Certification of certain Type III devices.
(a) The purpose of this section is to provide regulations for certification of certain Type III devices.
(b) Any Type III device is considered certified under this section if:
(1) It is used solely for the storage of sewage and flushwater at ambient air pressure and temperature; and
(2) It is in compliance with § 159.53(c).
(c) Any device certified under this section need not comply with the other regulations in this part except as re- quired in paragraphs (b)(2) and (d) of this section and may not be labeled under § 159.16.
(d) Each device certified under this section which is installed aboard an in- spected vessel must comply with § 159.97.

Sec. 159 says

(c) Be designed to prevent the over- board discharge of treated or untreated sewage or any waste derived from sew- age (Type III).

So technically, they have to be “certified.” But there is no list of certified Type III MSDs. There is just these requirements.

For more clarity, from the EPA site on MSDs:

https://www.epa.gov/vessels-marinas-...n-devices-msds

Type III: No performance standard; must "be designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage." 33 CFR 159.53(c) (PDF)(2 pp, 163 K)).

Jimbo, thanks for pointing out what many of us have said, the valve must be “secured in a closed position.” No where do any regs I have read says a head must be connected to holding tank. It must not discharge in NDZ areas, but I’ve found no reg that states what you say. You may be right. If so, just cite the reg reference. That’s what the rest of us are doing.

[Capn Jimbo]

Sec. 159 says...

So technically, they have to be “certified.” But there is no list of certified Type III MSDs. There is just these requirements.

No list? Just a technicality, not really certified or documented? Really?

"Certify Your Device

Texas has a program to certify your marine sanitation device.

If you operate a boat on Clear Lake which is 26-feet or longer and have permanent sleeping quarters on board, your boat must have a marine sanitation device and be certified. If your boat is less than 26-feet but has a marine sanitation device, it also must be certified. To apply for your decal, please complete TCEQ-0117. Owners will receive a decal which must be displayed on the hull of their boat after submitting their application.

The Texas Parks and Wildlife Department is now enforcing the Texas Clean Water Act on Lake Texoma and is inspecting boats for compliance. In the interest of public health, they have ruled that by December 31st 2010 all of the vessels in the Clear Lake/Galveston Bay area must have their marine sanitation device certified."

Clean Vessel Act
Wildlife & Sport Fish Restoration Program"

Looks like Texas is making a list and checking it twice. You even need a "certified" decal. Carry on...

[Sailmonkey]

Originally Posted by Capn Jimbo

No list? Just a technicality, not really certified or documented? Really?









Looks like Texas is making a list and checking it twice. You even need a "certified" decal. Carry on...

Do you even know what you’re spouting off about?

The Texas marine sanitation “certification” is a form that’s completed (check a box that says you’re compliant) and send a check to the general fund. It’s not a certification of anything!!!

I’ve competed this form and sent my money off under protest. If it was specifically earmarked to build free to use, easily accessible pump out stations, I’d be all in.....its not.

[Capn Jimbo]

Originally Posted by Mike OReilly

Jimbo, thanks for pointing out what many of us have said, the valve must be “secured in a closed position.” No where do any regs I have read says a head must be connected to holding tank. It must not discharge in NDZ areas, but I’ve found no reg that states what you say. You may be right. If so, just cite the reg reference. That’s what the rest of us are doing.

"Many of us... rest of us... we"? That's funny. I'm not biting. "I've never heard... I'm not aware... I haven't read..." are not arguments. And misrepresenting what was or was not said seems simply argumentative for no good cause.

The case has been made and the OP's head to overboard is not in compliance, case closed, there's nothing more to say, at least by me. By the way there's a great saying - when you're being run of town by a crowd, your best move is to get in front and pretend you're leading the parade, lol...

Don't drop yer baton...

[Mike OReilly]

Originally Posted by Sailmonkey

Do you even know what you’re spouting off about?

The Texas marine sanitation “certification” is a form that’s completed (check a box that says you’re compliant) and send a check to the general fund. It’s not a certification of anything!!!

I’ve competed this form and sent my money off under protest. If it was specifically earmarked to build free to use, easily accessible pump out stations, I’d be all in.....its not.

Thanks SM.

And here’s Jimbo’s “list.” It is exactly as SM says:
https://irp-cdn.multiscreensite.com/...tification.pdf

Instead of getting huffy Jimbo, just cite the legal or regulatory reference. You keep stating something which, by all research and evidence, appears to be untrue. An apt saying comes to mind: “Shyte, or get off the pot.”