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Old 12-04-2019, 11:48   #1
txg
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Florida without a holding tank

Our liveaboard vessel has no holding tank (it never had one), and we want to sail over to Ft. Lauderdale in about a week (currently on Isla Mujeres).



I now found out it is forbidden to pump blackwater overboard in US coastal waters and i totally accept that, but i don't want to install a complete holding tank system for a single US visit that will probably be shorter than two weeks. And there is no way to buy the required parts here anyways.



What is the easiest solution for us to comply with US laws?



-It is probably not sufficient to simply close the seacock. Is it acceptable to put a lock on the seacock and simply use marina facilities?


-If not, is it okay to lock the seacock and use an additional portapotti? If so, is it acceptable to buy this portapotti after entering the US? Probably hard to get here.



-If all of this is not sufficient, is it acceptable to route the toilet outlet to an old jerrycan that has no other connection? Obviously this is not a very beautiful solution, but it won't be used anyways, this is only to comply with the local laws.



Any other ideas or hints? Please no discussion about installing a proper holding tank system with y-valve, pump-out connection and vent line.
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Old 12-04-2019, 12:04   #2
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Re: Florida without a holding tank

I believe if the seacock is locked up you are ok.
The cheap porta potti is a good solution. I have never been looked at in Florida and was there a few months on two separate occasions.
In most circumstances you could enter and then buy what you need I would think. Or just lock or zip tie the seacock closed until you do. Last I heard zip ties were acceptable as a lock, but it's hard to keep up with.
I dont think there is a restriction on the type of holding tank, so yes any tank you could plumb in to should work.
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Old 12-04-2019, 12:19   #3
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Re: Florida without a holding tank

I believe Cheechacko is correct. Lock the head in such a way that it cannot flush overboard and cannot be too easily unlocked like hanging the keys next to a padlock. Nylon cable ties I've read are acceptable.

Some locales in Florida are known to check heads and, since marine plumbing and be hard to trace, check the head by putting a dye tablet in the toilet, flushing and checking to see if color shows up in the water next to the boat. In your case since you have no holding tank you need to completely disable the head or disable access so no flushing could happen at all.

Then buy a portapote.

Note: If you get caught out of compliance the fine can be up to US$1,000.00
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Old 12-04-2019, 12:25   #4
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Re: Florida without a holding tank

Another alternative is to install a flex holding tank. Not good for long term, but OK for short term use.
Locking the seacock should get you through any inspections.
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Old 12-04-2019, 12:30   #5
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Re: Florida without a holding tank

The USCG Commandant's office issued a letter of clarification on this 20+ years ago. The head must simply be "secured" against illegal discharge. That is usually down by physically locking the thru-hull (or the Y-valve when there's a holding tank split) and that can be done with zip ties, a padlock is not required. In theory you can also "secure" the head by simply locking the door to the head compartment and securing the key, i.e. in the ship's safe or the captain's shoe. Or all of the above.

All you need is to demonstrate that the head cannot be discharged overboard without conspicuous change or actions.

No big deal, you can go to any restaurant or deli in Florida on trash pick-up day and get a slightly used five gallon plastic bucket, with lid, for free. They get coleslaw, potato salad, all sorts of food in those buckets and routinely throw them out. Grab one and some plastic bags, and you've got a suitable marine head. (And yes, camping and hunting suppliers actually sell snap-on toilet seats for them!) Just in case you need one, cheap and easy.
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Old 12-04-2019, 12:35   #6
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Re: Florida without a holding tank

There is no restriction on the type of any sanitation equipment, only on what you're allowed to do with human body waste. I agree that a portapotty is the best solution here. If you only plan to use it for a week or two, an inexpensive camping portapotty is all you need. If you'll have access to land transportation, you can find those in the camping section at any Walmart.

Doesn't even have to be "installed" beyond making sure it can stay upright wherever you put it. If you plan to stay at the dock, you should be able to empty the tank into any toilet on land. If that happens to be in a marina, use the bathrooms there for any "serious" business. If you do any sailing in open water beyond the "3 mile limit" (at least 3 miles offshore from the nearest point of land), you can legally pour it over the side.

'Twould also be advisable to "secure" the seacock on the overboard discharge thru-hull. Yes, a plastic zip-tie is acceptable.

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Old 12-04-2019, 12:43   #7
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Re: Florida without a holding tank

The rules are pretty clear in Florida:

“If you have a recreational vessel with installed toilet facilities, it must have an operable, USCG–certified marine sanitation device (MSD) on board.

All vessels 26 feet or more in length that have an enclosed cabin with sleeping facilities, must be equipped with a toilet if on Florida state waters.”

Any valve allowing direct discharge must be “secured”.
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Old 12-04-2019, 12:58   #8
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Re: Florida without a holding tank

WAG (Waste Alleviation and Gel) bags can be a very short term solution (and handy for emergencies too). They can be laid in the head, if it is dry, for use. Assuming the commercial product is not available, any HD bags (double) and absorbent will do for a day.


Not pretty, just a possibility. We keep a few on board just for "what if."
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Old 12-04-2019, 13:12   #9
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Re: Florida without a holding tank

The wag bags are convenient, assuming you have a local source of them or are within reach of the delivery drones(G). But you can also pick up a roll of 8-gallon trash bags for $2.50 in wallyworld, and a huge jug of *clumping* kitty litter for $6.50, and for under ten bucks...you've got 50 commode liners, aka wag bags, that can also be used when shoreside water and power go down. (The four-gallon trash bags seem to be the smallest, but they won't fit a commode or bucket, just a little too small.)
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Old 12-04-2019, 13:29   #10
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Re: Florida without a holding tank

Thanks for all the helpful replies so far, looks like all this is not as complicated as i feared.



I didn't find a good solution for zip-tieing the seacock shut yet, but instead i found a good solution to block the pump handle with some spare steel wire and some crimps that we had on board anyways. See attached picture. This should be at least as good as a zip-tie on the seacock. For emergencies, we will simply put a standard trashbag in the toilet bowl itself.
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Old 13-04-2019, 10:16   #11
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Re: Florida without a holding tank

Quote:
Originally Posted by S/V Illusion View Post
The rules are pretty clear in Florida:

“If you have a recreational vessel with installed toilet facilities, it must have an operable, USCG–certified marine sanitation device (MSD) on board.

All vessels 26 feet or more in length that have an enclosed cabin with sleeping facilities, must be equipped with a toilet if on Florida state waters.”

Any valve allowing direct discharge must be “secured”.
The Federal Clean Water Act would allow the use of porta potties for boats which do not have an installed toilet, in lieu of a certified marine sanitation device.

The State of Florida has its own sanitation laws which also must be complied with.

If you have a recreational vessel with installed toilet facilities, it must have an operable, USCG–certified marine sanitation device (MSD) on board.

I would recommend securing the head or the installed toilet, e.g., seal the Y value shut and / or clamp the toilet seat cover so that the bowl is not accessible, or lock the door to the head. You might be able to fit the porta pottie in your shower stall, depending on the configuration. Be sure to securely stabilize the porta potty, when the tip over they can make a horrendous mess.

Florida:
All vessels 26 feet or more in length that have an enclosed cabin with sleeping facilities, must be equipped with a toilet if on Florida state waters.
On a vessel other than a houseboat, the toilet may be portable or a permanently installed toilet properly attached to an MSD.

Type III MSD
Consists of holding tanks or portable toilets. Type III MSDs have the least effect on the environment since the waste is to be discharged on shore into a local sewage treatment facility.

*There may be a Y valve that directs untreated waste material for discharge or directs waste material for treatment prior to discharge. The Y valve must be secured to direct waste to the MSD at all times within Florida waters (three miles or the edge of the Gulf Stream, whichever is greater, off the Atlantic coast or nine miles off the Gulf of Mexico coast).

Which crafts are required by Florida Statute 327.53 to have a working toilet on board when in state waters?
Any vessel 26 feet or longer with an enclosed cabin and berthing facilities.
Any houseboat, defined as a vessel used primarily as a residence and not moved for 21 out of 30 days in a county of this state.
Any floating structure with enclosed living space with berthing facilities or work space with public access.

What are the coastal boundaries for waters in Florida?
Coastal boundary limits are nine nautical miles on the Gulf and three miles on the Atlantic Ocean.

What are marine sanitation devices?
A marine sanitation device (MSD) is any equipment for installation on board a vessel, other than a toilet, which is designed to receive, retain, treat or discharge sewage and any process to treat such sewage (Florida Statute 327.53).
MSD TYPE 1: Flow-through device that treats sewage by chemical or thermal means
MSD TYPE 2: Device that treats the sewage by biological means and uses bacteria
MSD TYPE 3: Holds the sewage. Prevents direct overboard discharge or sewage

How do you tell if an MSD is U.S. Coast Guard approved?
For Type I or Type II a label is affixed to the device or there is a letter or document on board for Type 1 or 2 MSD; Type 3 does not require a label.

What are the guidelines for Y-valves?
Under federal law, if a boat has a Y-valve allowing direct overboard discharge of untreated waste, it must be closed while operating in all inland and coastal waters. It is suggested you use a non-releasable wire tie or lock, or remove the valve handle to secure the device. When you are more than three miles offshore in the ocean, the Y-valve may be open allowing direct discharge overboard.
A Y-valve may also be found on boats having both a Type I or II MSD and a holding tank. This gives the boater an option to discharge treated waste overboard or to contain it for pumpout later.

What is a No Discharge Zone?
A No Discharge Zone is approved by the U.S. Environmental Protection Agency, which prohibits boats from discharging treated or untreated sewage into water bodies. In these waters, a Y-valve has to be closed. Currently, there are three No Discharge Zones in Florida: Destin Harbor, the Florida Keys Marine Sanctuary and the city of Key West.

Are marine sanitation devices subject to inspection?
Yes. When the owner or operator is aboard, an officer may board a vessel with consent or if there is probable cause or knowledge to believe that a violation has occurred or is occurring. An officer may also board a vessel if the operator refuses or is unable to display the safety or marine sanitation equipment.

What are the fines for non-compliance?
$50 infraction for compliance issues
$250 civil penalty for discharge of raw sewage

Portable toilets are Legal on any boat.* They does not fall under USCG regulations of MSDs.
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Old 13-04-2019, 11:37   #12
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Re: Florida without a holding tank

I had a locked seacock and had a porta potty onboard. Had no problems.
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Old 13-04-2019, 12:32   #13
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Re: Florida without a holding tank

just put a plastic bag in the existing head and dump it out once on shore.
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Old 13-04-2019, 14:04   #14
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Re: Florida without a holding tank

Had a portapoty for 22yrs and still have it. No hoses no pumps. When it needs emptying i bring it up on deck , the marina pumps it out. Best $100.00 I ever spent.
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Old 13-04-2019, 14:19   #15
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Re: Florida without a holding tank

The reason I first looked into WAG bags was for winter sailing on small boats, when everything would freeze. Carrying a porta-head on an icy dock is dangerous. But not a Florida issue.


Now we still carry them in the summer. It's just easier, although they are almost never used.
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