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Old 23-10-2020, 08:25   #1
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toilet - what has to be secured for coastal sailing

I'm unsure of the requirements for securing the head and holding tank for bay and close coastal sailing on the US East Coast.

The diverter valve is zip tied so toilet flow goes to the holding tank.
There are seacocks for toilet discharge and holding tank discharge.
Those don't have any provision for locking.

Questions:

1. Is a zip tie adequate to secure the diverter valve or is a padlock required?

2. Do the toilet and holding tank seacocks need to be closed?

3. Do those seacocks need to be secured and what's required?

Thank you
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Old 23-10-2020, 09:06   #2
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Re: toilet - what has to be secured for coastal sailing

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Originally Posted by vpbarkley View Post
I'm unsure of the requirements for securing the head and holding tank for bay and close coastal sailing on the US East Coast.

The diverter valve is zip tied so toilet flow goes to the holding tank.
There are seacocks for toilet discharge and holding tank discharge.
Those don't have any provision for locking.

Questions:

1. Is a zip tie adequate to secure the diverter valve or is a padlock required?

2. Do the toilet and holding tank seacocks need to be closed?

3. Do those seacocks need to be secured and what's required?

Thank you
I assume you have a diverter which goes to a seacock and through hull for direct discharge or the holding tank.

You then have a connection from holding tank to macerator to another seacock and through hull.

For Coastal Cruising, simply diverting the Y valve to the holding tank and closing both the direct discharge seacock and macerator seacock should be sufficient.

Inland waterways and some coastal places, such as Rhode Island want you to fully secure the discharge system. To fully secure, you can either remove the seacock handles (once closed), or zip tie the handles closed (if possible).
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Old 23-10-2020, 09:31   #3
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Re: toilet - what has to be secured for coastal sailing

Mine had no easy way to lock, either. I passed a bit of 1/16" steel cable through a hole in the cabinet structure behind the Y-valve, then crimped a loop on it. I use a serialized tamper-seal tag (about $14 per hundred) around the valve handle, to that loop, so the valve handle can't turn. The tag number & GPS location get written in the log whenever one's installed or snipped off, so it's easy to prove to the Coast Guard that the valve has indeed been locked the whole time we were in no-discharge waters, and wasn't just ziptied up when we saw their boat approaching.

Since you have two ways to discharge (we have just 1), I'd do this on both discharge seacocks instead of on the Y-valve, or on the Y-valve and on the holding tank dump seacock. That should make the Coasties happy.
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Old 31-10-2020, 05:54   #4
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Re: toilet - what has to be secured for coastal sailing

@MarshMat thats the same way we do it on tugs. If its good for us it should be good for you.
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Old 31-10-2020, 06:31   #5
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Re: toilet - what has to be secured for coastal sailing

Quote:
Originally Posted by vpbarkley View Post
1. Is a zip tie adequate to secure the diverter valve or is a padlock required?

2. Do the toilet and holding tank seacocks need to be closed?

3. Do those seacocks need to be secured and what's required?
1. Yes. A zip tie is specifically spelled out in the regulations as an option.

2. No. The system has to be "locked" out of service such that overboard discharge can't occur without some effort. Securing the seacocks with a zip tie is one option. It's convenient and since it's right there in the regulation as an example, there would be no discussion.

However, any method of effectively locking out the system works. I have a key switch to run the macerator, and the key is hidden or in the master's possession.

3. No. See above.

Also, these are federal regulations. While states can and do add additional requirements for their sole-state, inland waters, they do not apply to vessels transiting federally "navigable" waterways (essentially, anything an ocean-going vessel can navigate, plus waterways which straddle state boundaries.)

There is a grey area where states can require their own state-registered vessels to comply with additional standards while in that state (see: NY and VT on Lake Champlain) but that technically doesn't apply to vessels transiting those waters. Not all LEs understand this, however.
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Old 31-10-2020, 07:18   #6
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Re: toilet - what has to be secured for coastal sailing

Remember the three mile limit. It's marked on the NOAA charts.
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Old 31-10-2020, 09:21   #7
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toilet - what has to be secured for coastal sailing

The USA answer to securing the head is here:

https://www.law.cornell.edu/cfr/text/33/159.7

A holding tank is a type III msd. The requirements include removing the handle, or padlocking, or using a non- releasable zip tie.
This is on each valve leading to an overboard discharge.
The previous section for type I and II msds refers to seacocks. This section does not.
My interpretation is that the wye valve leading from the head, or tank, or both, to the seacocks must be secured.
Some seacocks do double duty as a discharge for black and gray water and cannot practically be left closed.
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Old 31-10-2020, 11:10   #8
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Re: toilet - what has to be secured for coastal sailing

The solution that sounds most convenient to me is to zip tie the Y valve and add a key switch to the macerator pump. Those two steps lock out any possible discharge.

On our boat the seacocks for the toilet and holding tanks are difficult to get to. They are located within a settee and quite a reach down.

Thank you all for your answers.
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