Holding Tank Lock Out

[Gordon J]

Not necessarily true

No one "accidentally" pumps out their holding tank. The idea is to make it a purposeful act so that when you get caught there is no argument about the ticket you get. Of course those who purposely pump out will still bitch and argue about the ticket.

I have accidentally hit the wrong circuit breaker. The three that control my heads are grouped together: One for each vacuum pump and one for overboard discharge. Fortunately, for me, my thruhull has a switch that disables the circuit should the valve be closed. Keeps one from inverting duck bills.

I can tell you that I have mistakenly hit all three, only to realize sometime later what had occurred.

Gordon

 

[amapola]

We have a similar system. When we were boarded, the USCG told us the key must be kept separate from the switch.

 

[thataway]

My understanding is that in some of the Inland waters, such as Lake Champlain, the house must be capped as well as the thru hull, and separated. I have never had an issue with inspections in Florida, with a closed thru hull, or keyed macerator pump.

 

[Alaskan Sea-Duction]

All I have to do is turn the key to the “off” position and remove the key to be in compliance when in a NDZ.

When not in a NDZ I turn the key to “automatic” and the holding tank stays empty, plus I do not have any 3 mile requirement as the system can only discharge treated waste.

Kevin touched on this and it appears most of you skipped right over it.

33 CFR 159 states (I highlighted):

§ 159.7 Requirements for vessel operators.
(a) No person may operate any vessel equipped with installed toilet facilities unless it is equipped with:

(1) An operable Type II or III device that has a label on it under § 159.16 or that is certified under § 159.12 or § 159.12a; or

(2) An operable Type I device that has a label on it under § 159.16 or that is certified under § 159.12, if the vessel is 19.7 meters (65 feet) or less in length.

(b) When operating a vessel on a body of water where the discharge of treated or untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3 or 140.4, the operator must secure each Type I or Type II device in a manner which prevents discharge of treated or untreated sewage. Acceptable methods of securing the device include -

(1) Closing the seacock and removing the handle;

(2) Padlocking the seacock in the closed position;

(3) Using a non-releasable wire-tie to hold the seacock in the closed position; or

(4) Locking the door to the space enclosing the toilets with a padlock or door handle key lock.

(c) When operating a vessel on a body of water where the discharge of untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3, the operator must secure each Type III device in a manner which prevents discharge of sewage. Acceptable methods of securing the device include -

(1) Closing each valve leading to an overboard discharge and removing the handle;

(2) Padlocking each valve leading to an overboard discharge in the closed position; or

(3) Using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.

[CGH 95-028, 62 FR 51194, Sept. 30, 1997]

Take a look on page 35 in red.

https://www.uscgboating.org/images/420.PDF

BOTTOM-LINE: No lockout is required unless you are in a EPA designated "No Discharge Zone."

Again: NO LOCK OUT REQUIRED!

 

[dhays]

Kevin touched on this and it appears most of you skipped right over it.



33 CFR 159 states (I highlighted):



§ 159.7 Requirements for vessel operators.

(a) No person may operate any vessel equipped with installed toilet facilities unless it is equipped with:



(1) An operable Type II or III device that has a label on it under § 159.16 or that is certified under § 159.12 or § 159.12a; or



(2) An operable Type I device that has a label on it under § 159.16 or that is certified under § 159.12, if the vessel is 19.7 meters (65 feet) or less in length.



(b) When operating a vessel on a body of water where the discharge of treated or untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3 or 140.4, the operator must secure each Type I or Type II device in a manner which prevents discharge of treated or untreated sewage. Acceptable methods of securing the device include -



(1) Closing the seacock and removing the handle;



(2) Padlocking the seacock in the closed position;



(3) Using a non-releasable wire-tie to hold the seacock in the closed position; or



(4) Locking the door to the space enclosing the toilets with a padlock or door handle key lock.



(c) When operating a vessel on a body of water where the discharge of untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3, the operator must secure each Type III device in a manner which prevents discharge of sewage. Acceptable methods of securing the device include -



(1) Closing each valve leading to an overboard discharge and removing the handle;



(2) Padlocking each valve leading to an overboard discharge in the closed position; or



(3) Using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.



[CGH 95-028, 62 FR 51194, Sept. 30, 1997]

Thanks for posting this ASD.

What I find interesting is that for me (like most of us), I have a Type III MSD. As such CFR 33 159.7(b) doesn’t apply to me. However, I am subject to CFR 33 159.7(c).

I find it interesting that the “Acceptable methods” that are listed are different for Type I and II vs Type III. My system has two valves between the holding tank and the outside of the hull. One is a valve between the holding tank and macerator, and the other is a through hull. As I reading the examples. I would need to either lock, secure, or remove the handles of both those valves.

Unfortunately, without taking a saw to some under the counter shelving in the head, I can’t remove the handle in the thruhull and the valve is not one that has a hole for securing with a padlock. So, I’m hoping that any interested parties will consider my system “secured” with just one of the valves disabled in the closed position as well as the breaker secured in the off position.

 

[Alaskan Sea-Duction]

Thanks for posting this ASD.

What I find interesting is that for me (like most of us), I have a Type III MSD. As such CFR 33 159.7(b) doesn’t apply to me. However, I am subject to CFR 33 159.7(c).

I find it interesting that the “Acceptable methods” that are listed are different for Type I and II vs Type III. My system has two valves between the holding tank and the outside of the hull. One is a valve between the holding tank and macerator, and the other is a through hull. As I reading the examples. I would need to either lock, secure, or remove the handles of both those valves.

Unfortunately, without taking a saw to some under the counter shelving in the head, I can’t remove the handle in the thruhull and the valve is not one that has a hole for securing with a padlock. So, I’m hoping that any interested parties will consider my system “secured” with just one of the valves disabled in the closed position as well as the breaker secured in the off position.

True, but ONLY if you are in a NDZ...otherwise no lockout required.

 

[dhays]

True, but ONLY if you are in a NDZ...otherwise no lockout required.

Yeah, but unless I cross the border into Canada, I’m always in an NDZ now. :-(. Even without an NDZ, with a type III MSD I’m still required to “secure” my system to prevent discharge. That doesn’t mean a key, but I have to secure the valves.

 

[menzies]

Anyone know of any NDZs in the US inside the three mile line? Coastal or inland?

 

[OldDan1943]

Hey Menzies, Hey Dave,

I love that lockout. Who makes it?

Cheers!
-Greg

West Marine, BOW, DH Hull

 

[OldDan1943]

All this talk about lock outs, wire ties, keyed switches, removing the overboard valve handle.... Sort of make a guy wonder how the EPA controls the fish poop.

 

[menzies]

All this talk about lock outs, wire ties, keyed switches, removing the overboard valve handle.... Sort of make a guy wonder how the EPA controls the fish poop.

While clearly written in jest, I always love this argument about a lot of the environmental issues.

Why cut emissions when other countries won't? Why recycle plastics since third world countries do twice as much as us? Do you really think planting trees in towns us going to help when large areas of the Amazon jungle is being destroyed?

These things are not mutually exclusive. Just because others don' t do the good, or do the bad worse, is not reason for an individual or a family or a country to not do it if they can.

It gets to the argument, should we go for the transformational rather than incremental? Why not do the latter while looking for the former?

 

[Pcpete]

When the State of Washington petitioned the EPA to make, basically, everything easy of Port Angeles a NDZ for any Vessel, I called the appropriate office in Olympia and was able to talk to the person charged with writing the enforcement implementation. The discomfort level in her voice was very obvious. I explained that as a boater with a complete, compliant MSD system, I was curious about enforcement regarding vessels without any system. My example was a 16-20 foot open runabout with two or three males enjoying a day of salmon fishing. There would be the obligatory beverages and at some point a bladder would demand relief. I supposed there was no preplanning for such an event, so one way or another, the waste was going over the side. I pointed out that there are literally thousands of these boats and large concentrations occur at well known fishing grounds.
I then asked what the enforcement plan was regarding that situation. After several very uncomfortable moments from the Olympia end of the conversation, her advice was “if you see a violation, report it”. I thanked her, ended the call, and just shook my head. Make a rule, get big press about making those boaters take care of their sewage and have no viable additional enforcement.

 

[dhays]

Pcpete, all the NDZ expansion did was to extend existing NDZ regulations to WA waters of the Salish Sea. The only change it made for WA boaters was to prohibit the discharge of treated sewage. This didn’t change the regulations affecting those small boats at all.

It prohibits large vessels from discharging their treated waste in Puget Sound and I’m happy for that. However the prohibition for small recreational boats with treatment systems really did nothing to improve water quality in my opinion.

On the bright side, it did come with some additional funding for pump-out facilities around the Sound which actually helps us quite a bit. For decades it was almost impossible to find working pump-out facilities. That doesn’t seem to be the case anymore.

 

[Alaskan Sea-Duction]

Yeah, but unless I cross the border into Canada, I’m always in an NDZ now. :-(. Even without an NDZ, with a type III MSD I’m still required to “secure” my system to prevent discharge. That doesn’t mean a key, but I have to secure the valves.

True. All of Puget Sound (U.S. Waters) is now a NDZ. If you want to be compliant, then cross the boarder pull the valve and dump, then return to the U.S. as your poop flows back into Washington. Seems to work for the cities of Seattle, Tacoma and Bellingham.

When the State of Washington petitioned the EPA to make, basically, everything easy of Port Angeles a NDZ for any Vessel, I called the appropriate office in Olympia and was able to talk to the person charged with writing the enforcement implementation. The discomfort level in her voice was very obvious. I explained that as a boater with a complete, compliant MSD system, I was curious about enforcement regarding vessels without any system. My example was a 16-20 foot open runabout with two or three males enjoying a day of salmon fishing. There would be the obligatory beverages and at some point a bladder would demand relief. I supposed there was no preplanning for such an event, so one way or another, the waste was going over the side. I pointed out that there are literally thousands of these boats and large concentrations occur at well known fishing grounds.
I then asked what the enforcement plan was regarding that situation. After several very uncomfortable moments from the Olympia end of the conversation, her advice was “if you see a violation, report it”. I thanked her, ended the call, and just shook my head. Make a rule, get big press about making those boaters take care of their sewage and have no viable additional enforcement.

I did the same thing except I approached them at the Seattle boat show. Their response? "Why are you worried about it? It doesn't affect you and your boat. You are required to pump or dump beyond the 3nm mark." When I asked about Seattle and Tacoma I was told that is a "different" law.

The problem I have with the law is just about everyone from the Highway patrol to the dog catcher now has a right to board your vessel to ensure compliance.

 

[HenryD]

Before we went into Lake Champlain and Canada, I installed an "air gap" in my macertator plumbing with two unions. Easy to install when I know I will be 3+ miles off shore...the rest of the time, the gap is in place.