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Old 12-16-2013, 08:07 AM   #1
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macerator key switch and requirements

Our macerator from our holding tank goes to a dedicated through hull. In order to meet CG requirements will installing a keyed switch on the power for the macerator meet requirements. It will be lockable.
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Old 12-16-2013, 08:23 AM   #2
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I do not believe that there are USCG requirements to lock out sanitation through hulls. There are laws relating to where you may discharge of course. However, there may be local regs relating to securing our sanitation system. In RI, it is adequate to have the Y valves secured in the holding tank position (wire ties) and to remove or secure the holding tank discharge seacock. We simply leave the nut off of the seacock lever making it esay to install/remove as needed (for legal discharge outside 3 mile limit). This approach was deemed adequate for our RI inspection some years ago. There are certain no-discharge areas such as inland lakes where much more stringent requirements exist but I believe these again are local/state regulations. Also, unless your system is totally incapacitated by removing all through hull connections, this is an honor system. Your keyed approach is probably fine but if you chose to you could unlock your macerator, just as easily as I could re-attach my seacock lever!!!
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Old 12-16-2013, 09:10 AM   #3
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Thanks Chris,
I did not realize that. So my through hull is located in an area that is very difficult to get to. The zip ties would great or the seacock lever but it is a real pain to reach. Thus I thought the lock on the power to the macerator. I guess that would be up to the inspector how he would view this.... Any thoughts?
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Old 12-16-2013, 09:21 AM   #4
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Roger:
Certainly no expert but would have thought the approach should be fine unless you are in one of the really tightly restricted inland no-discharge zones. As previous, seems to me unless you totally incapacitate system, it is an honor system anyway, no matter how the system is temporarily secured.
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Old 12-16-2013, 10:12 AM   #5
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The EPA does have a rule that mandates that an overboard discharge valve be "incapacitated" in inshore waters. As others have noted, incapacitated is in the eye of the inspector. Usually it means that the handle has been removed or wired tied closed. I suspect that a key switch might work, but is sure easier to make usable than the other means. And it does nothing for the valve.

As others have noted, this is a silly honor system game. I can reinstall the handle on my thru hull valve in 10 seconds, or clip a wire tie in less.

There are some state waters, like Lake Champlain that do require positive controls, ie you cannot have a hose connected from your holding tank to the thru hull. It just takes a little longer to reconnect ;-).

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Old 12-16-2013, 10:37 AM   #6
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I learned key switch trick from Peggie Hall who literally wrote the book on marine sanitation systems. I plan to hook my macerator pump to a keyed switch just like you.

My toilet has no Y valve. I can't discharge directly overboard so the only way for me to put sewage in the water is to empty my tank with the pump.

If you have a Y valve that allows you to discharge directly overboard, you'll need to secure that as well.

Every boat owner with a head should read Peggies book.
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Old 12-16-2013, 05:30 PM   #7
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some new boats just have a key switch or a remote switch that isn't even keyed....they discharge through openings above the water that don't even have handles to secure...good enough for those boats...good enough for mine.
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Old 12-17-2013, 06:21 AM   #8
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Most of the new waste overboard deck fittings are built to hold a specific waste pump out fitting.

Install this ,,, NO overboard thru hull ,or waste switch lever , just the maceriator pump.


It is a matter of seconds to drop the proper fitting with a hose attached and pump away , offshore of course.

This will pass any test or inspection , and the discharge hose , rinsed overboard will be easy to store.

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Old 12-30-2013, 08:01 AM   #9
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My boat has an above water discharge for the holding tank and no seacock. When I got it, it had a pushbutton switch for the macerator. I replaced the button with a key switch and I keep the key hidden.

The "rules" don't specifically allow or disallow this method, but I have no seacock to wire shut so I'm just assuming that my solution will pass inspection.
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Old 12-30-2013, 08:07 AM   #10
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I think it passes just fine and the key isn't even required as long as the "overboard" button is not in the head.

More boats seem to be being made this way so I'm guessing manufacturers feel comfortable the pollution police are satisfied.

It doesn't take a rocket scientist to beat the system if they want to so why penalize all boaters with crawling in and out of the bilge regularly if they boat where overboard discharging is possible.

I could see in areas where the chance of overboard discharge is not possible without many days of steaming that they may want some physical disconnection and that's reasonable...but not the ICW.
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Old 12-30-2013, 09:51 AM   #11
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Hope you never lose the "hidden" key!!!
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Old 12-30-2013, 09:54 AM   #12
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Quote:
Originally Posted by Chrisjs View Post
Hope you never lose the "hidden" key!!!
My point is, I don't leave it in the switch. It's in a drawer with the key to my dockbox. I have a second key with my spare fuses. If I had to, I could jump the switch terminals with a cliplead. I've solved bigger problems while underway.
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Old 12-31-2013, 06:13 PM   #13
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Here's the list straight from the CFR's. Note "Include" doesn't limit to these choices:

Y valve lockouts

(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]
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Old 12-31-2013, 07:47 PM   #14
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Quote:
Originally Posted by Keith View Post
Here's the list straight from the CFR's. Note "Include" doesn't limit to these choices:

Y valve lockouts

(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]
That's not new news, we've been batting this back and forth for a long time. The problem is, a key switch on the macerator circuit isn't specifically approved so it's up to an individual LEO's whim as to writing a citation or not. We might win in court, but it would be a lot of hassle, especially if it happened out of state.
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Old 12-31-2013, 07:54 PM   #15
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supposedly a letter from the Commandant of the USCG stated there were alternatves to those listed in the CFRs...can't find the letter but if manufacturers have switched to key locks and main panel master switches for pumping overboard...they must feel pretty secure that it is OK.
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Old 12-31-2013, 08:03 PM   #16
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Quote:
Originally Posted by WesK View Post
I replaced the button with a key switch and I keep the key hidden.
The "rules" don't specifically allow or disallow this method, but I have no seacock to wire shut so I'm just assuming that my solution will pass inspection.
I did the same with my Microphor system. . . No holding tank or valve, other than the 5 gallon pump tank, so I installed a switch with a removable key to the overboard pump at the recommendation of the CGA.

Later when I was boarded and inspected, they said that was fine. As long as there was a positive method of stopping discharge from the system and ensures there is no inadvertent discharge from the vessel in prohibited areas.
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