No holding tank options?

[captain69]

Does anyone just use the head solely as a urinal, and pump directly overboard (or just pee off the side of the boat), and use a composting toilet for the solid waste, thereby never putting *anything* into the holding tank?
My understanding is that if ever boarded by USA for inspection, finding the head set to pump overboard will get you in big big trouble, but I wonder if inspectors would see reason when presented with the composting toilet.
There are too many unknowns for me to even really cover this topic, but I’m hoping someone else has some answers.
PS: a lot of people in Canada just pump it all directly overboard pretty much anywhere outside of the marina.

 

[dlochner]

I am sure there are people who don't comply with the no discharge law for various reasons. If a boat is boarded for any reason by the USCG, they will ask about discharge among other things and want to see that it is closed and sealed. Been there done that. How the CG responds to noncompliance is unknown, likely it will depend on circumstances, are there other violations and whether it is closed and not sealed or open.

Having both a marine toilet and desiccating toilet on a boat seems like a waste of valuable space. While peeing overboard has a long history, there are times at which that is certainly dangerous or uncouth.

 

[Calif. Ted]

No, you are confused, most boats have a type 3 (holding tank) sanitation system:
Federal law prohibits the discharge of untreated sewage from vessels into U.S. waters, including all inland waters, the Great Lakes, and coastal waters extending to three miles from shore. The discharge by such vessels of any treated or untreated sewage is prohibited in freshwater lakes, ponds, reservoirs, and rivers unnavigable by interstate vessel traffic. Some waters are designated as no-discharge zones (NDZs). In NDZs, it is illegal for vessels to discharge treated or untreated sewage.
Everything is explained at the link below by the EPA including methods to comply while in NDZ (no discharge zones) such as removing valve handles.
In fifty years I've been boarded by CG twice, neither time did they even look at the sanitation system, why would they? I'm in the Pacific Ocean.
https://www.epa.gov/sites/default/f...creational_boaters_guide_to_vessel_sewage.pdf

 

[dlochner]

In fifty years I've been boarded by CG twice, neither time did they even look at the sanitation system, why would they? I'm in the Pacific Ocean.

And when I was boarded I was on Lake Ontario.

Unfortunately, just because there is a law, it doesn't mean people actually follow it, especially when the chance of getting caught is low.

 

[smokey73]

@Calif. Ted Not sure why you say "you are confused." You are correct that most of the sailboats that those on this forum have are Type 3 devices, which means they are simply holding tanks, and do not provide for "treatment" per se, so any discharge from them is considered "untreated sewage" and governed as such. Therefore, when in those zones and areas where discharge of "untreated sewage" is prohibited (by location or by special NDZ regulations) those of us with simple holding tanks or direct discharge overboard pipes/valves must secure the ability to discharge by some physical means. Like you say, removing the valve handle is one. Other methods might include putting a lock on the handle so it can't be repositioned. The Coast Guard (and the local marine police or state Dept of Natural Resources for that matter), if they board your vessel, may want to see that you comply with this regulation and can issue a citation if you do not. I am not sure that the local police or DNR can board you "without cause" but that is a legal matter about "boarding" and not the subject here. Whether they ask to see the way you have prevented overboard discharge of untreated sewage is entirely up to them and I suspect highly dependent on the local organization.

It is my understanding that the USCG will accept a non-releasing zip tie that prevents operation as an acceptable method to secure the valve and meet the regulations.

 

[smokey73]

It is not just "my understanding" that a non-releasable zip tie is acceptable, it is right in the EPA Recreational Boating guide. Thanks for the reference @Calif. Ted

If your point is that the method of securing the valve or discharge path is ONLY REQUIRED in specially designated NDZ then I don't think that is the way the USCG applies the regulation at least where we live. In our neck of the woods, the securing method (remove handle, zip tie, etc) is required and enforced on any waterway where the discharge of "untreated" sewage is prohibited, not just the NDZs.

I'd be interested to see if others have the same interpretation or have spoken to the Coast Guard or EPA on this. If you read the link that @Calif. Ted posted, you could interpret it as requiring the securing device ONLY WHEN IN AN NDZ and that no securing device is required in "U.S. waters, including all inland waters, the Great Lakes, and coastal waters extending to three miles from shore" unless they are specifically designated as NDZs. Darn lawyers can read things a hundred different ways.

 

[kloudie1]

Seems like if you are boarded and are pleasant and cooperative, they are more likely to treat you the same way.

 

[JamesG161]

On my boarding for Inspection, one officer went below alone and returned.

He told me all was good and thanked me.

The only thing he did not ask was where I kept the Regulations.

I had them under the Navigational Table.

Be Prepared....
Jim...

PS: You can dump anything it the Oceans 25 miles from shore.

 

[smokey73]

I'm answering my own questions (oops, is talking to myself on a forum considered a mental disorder)

If you have a Type 1 or Type 2 system that discharges "treated sewage" then you still have to secure (lock, remove handle, etc) when you are in an NDZ even if the sewage is treated. It seems to mean that those with Type 1 or 2 systems can discharge when NOT in an NDZ. It DOESN'T MEAN TYPE 3 holding tanks don't have to secure the discharge the device when ever they are in a waterway where the discharge of untreated sewage is prohibited, whether it a designated NDZ or not.

To put it in the positive "Whenever you are in water where you are not permitted to discharge untreated sewage you must secure the discharge path overboard by some physical means that is not easy to reposition like removing the handle, putting a lock on the valve, using a non-releasable zip tie, etc."

Of course we all know that someone can put the handle back on, unlock the valve, or remove the zip tie and pump then put the securing device back on but that takes "deliberate action" on the part of the person to violate the regulations and I think that is the position of the USCG.

 

[jssailem]

oops, is talking to myself on a forum considered a mental disorder

NO…
asking yourself a question and then providing the answer…Maybe.

 

[Claude L.-Auger]

FWC boarded me in Daytona, FL, years ago and inspected the sanitation system. As per the law options, I had chosen to remove the handle of the Y-valve. Officer then told me that while removing the handle was legal, its removal prevented them from seeing if the thru-hull was in the opened or closed position. I told him that it was indeed in the closed position and suggested for him to proceed to the simple test they do with what looked like food coloring. He put the test product in the head, pumped several times while a colleague was on the dock looking at the water in the area of the thru-hull. The water did not show any of the dye so they thanked me for being legal and went on there way. My boat in under Canadian registry and I was flying the Canadian Ensign, so I've always wondered as to why I was selected. I was at a fuel dock in a marina. Months later, I was boarded by a Sheriff while going up the Hudson river. He never checked the sanitation system but wanted to know where I was coming from and wanted to see my log-book. He told me they were checking for illegal drugs. There were a number of boats in the vicinity and when I politely asked him why they had selected me I was told it was because mine was the only one with a foreign ensign. I very politely asked him then if boats with the US Ensign were always deemed to be drug-free. He smiled and said I had a point but they had never thought of it. We chuckled together and they left after thanking me for the courtesy and patience.

 

[Davidasailor26]

You can dump anything it the Oceans 25 miles from shore.

Except plastic. That’s a no-go at any distance.

 

[captain69]

Yes. I've read "the rules" over and over again. It's clear that ALWAYS filling the blackwater tank with EVERY bodily waste product excreted is fine and dandy. I'm trying to figure out how to remain *legal* (and couth) while not ever putting anything into that shiny unused tank. Once it's tainted, that's it for life. It'll always have some kind of residue.

True that peeing openly in port is probably "uncouth" -- depends on your marina, I guess. (50 years ago we'd ALL stand on the dock facing different directions and let em rip, and no one ever gave a hoot!) Urine is usually sanitary, many will say STERILE, and may or may not be considered "raw sewage". I'm getting the idea that discharge is gonna have about as many "definitions" as there are people defining it.

The short of it is that I'd like to leave the "normal head" set to pump directly overboard and ONLY pee into it--so obviating the "uncouth" aspect of open displays in port, at anchor, etc. Meanwhile always pooping into the composting "desiccating" toilet which would only have to be emptied every now and then, and emptying being unbeholden to pump-out stations. (Disposing of compost waste is a simple bag and trash operation.)

FWIW, the *ASA school boat* where I took some classes had the head set to pump overboard IN THE MARINA, but there was a NO POOPING ON BOARD rule. ¯\_(ツ)_/¯

 

[dlochner]

Yes. I've read "the rules" over and over again. It's clear that ALWAYS filling the blackwater tank with EVERY bodily waste product excreted is fine and dandy. I'm trying to figure out how to remain *legal* (and couth) while not ever putting anything into that shiny unused tank. Once it's tainted, that's it for life. It'll always have some kind of residue.

True that peeing openly in port is probably "uncouth" -- depends on your marina, I guess. (50 years ago we'd ALL stand on the dock facing different directions and let em rip, and no one ever gave a hoot!) Urine is usually sanitary, many will say STERILE, and may or may not be considered "raw sewage". I'm getting the idea that discharge is gonna have about as many "definitions" as there are people defining it.

The short of it is that I'd like to leave the "normal head" set to pump directly overboard and ONLY pee into it--so obviating the "uncouth" aspect of open displays in port, at anchor, etc. Meanwhile always pooping into the composting "desiccating" toilet which would only have to be emptied every now and then, and emptying being unbeholden to pump-out stations. (Disposing of compost waste is a simple bag and trash operation.)

FWIW, the *ASA school boat* where I took some classes had the head set to pump overboard IN THE MARINA, but there was a NO POOPING ON BOARD rule. ¯\_(ツ)_/¯

I don't think anyone here is going to give you permission to violate the law. If they did, I'm quite sure the forum administration would have a private conversation with that poster.

 

[JamesG161]

Except plastic. That’s a no-go at any distance.

This is a complete list of not allowed dumping.
Learn about Ocean Dumping | US EPA

Jim...

PS: Who monitors dumping?

 

[smokey73]

I think if you look carefully it is the TYPE of sanitation device (yes a holding tank is a TYPE 3 Sanitation Device even though it does not treat or sanitize the waste) NOT THE CONTENTS of the tank that is the operative word. It is the TYPE of sanitation device that determines when and where you can discharge and requirements for preventing discharge, not what has been previously put into, or not put into the tank. In theory then, a brand new tank, once installed and the boat is in the water is governed by the discharge rules by the TYPE of device it is even if it has never had anything put into it. It does not say a TYPE X sanitation system that has only had (fill in the blank) can be treated differently. I think you'd be hard pressed to "prove" that the tank, which is not easily visible nor easily sampled, has NEVER in its lifetime been used. Besides, I am sure you'd "p%$$ off" the enforcement officer if you tried to use that one.

I am not a lawyer, but I did stay in a Holiday Inn last night

 

[captain69]

OK. So no one here, who is brave enough to write about it, will admit to ever having peed in the ocean.


Anyway, I did learn that simply having a lock on the head is sufficient to satisfy the LAW!

 

[smokey73]

A qualification about what has been put into the tank is that if you put oil or some other prohibited item (like radioactive waste) you can't pump it overboard no matter where you are. I guess you could clean the tank after you accidently put oil into your waste tank, just like you can clean a bilge after you contaminate it but those types of discussion are out of the normal discussion of discharging "waste" from a Type 1, 2 or 3 sanitation device.

 

[dlochner]

OK. So no one here, who is brave enough to write about it, will admit to ever having peed in the ocean.


Anyway, I did learn that simply having a lock on the head is sufficient to satisfy the LAW!

When I cross the 3 mile limit, the Y valve gets switched to overboard discharge and stays that way until I cross back.

 

[smokey73]

OK. So no one here, who is brave enough to write about it, will admit to ever having peed in the ocean.


Anyway, I did learn that simply having a lock on the head is sufficient to satisfy the LAW!

Of course I've peed in the ocean. However if you mean a lock on the head you mean a lock on the door I don't think that suffices to meet the regulation but it may.