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Offline cap-couillon

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The Poop on Poop
« on: July 02, 2013, 12:04:30 PM »
The "Poop" on "Poop"

Started a thread looking for some info on Boot Key moorings and it devolved into poop. Not what I was looking for, but a worth while discussion. Anyway people seem to want to talk about it so I thought I would start a new thread here in the hopes of getting some straight poop on poop as it were.

Disclaimer: I am not a lawyer nor would I wish to be. However, the rules are the rules and need to stand on both sides. If however, you know you are right, and decide to stand up to the local authorities, you will probably find yourself holding a bucket of poop. Right or wrong, they can make your life miserable and it's always a question of "is the principle worth the repercussions". For me, at 19 yrs old the answer was yes..... Close to 6 decades later, not so much. The regs cited below apply to US waters (and their possessions) only. Most opinions as to requirements are based on the USCG guidelines as they have the final jurisdiction. "County Mounties enforcing, do so with the acceptance of the USCG and with the exception of "Houseboats" may not apply state regulations. (See Houseboat definition below). Be aware that contracts between boat owners and state or private marina facilities that may require approved Type III MSD do not violate the Title 33 Regulations.



Some Definitions...

MSD:      Marine Sanitation Device. Equipment that prevents discharge of untreated sewage from vessels into the waters of the United States.(1)(2)
      
Sewage:      Human body wastes and the wastes from toilets and other receptacles intended to receive or retain body wastes except that, with respect to commercial vessels on the Great Lakes, such term shall include graywater (1)

Graywater:
     Galley, bath, and shower water (1)

Houseboat:    A vessel which, for a period of time determined by the State in which the vessel is located, is used primarily as a residence and is not used primarily as a means of transportation.(1) (Note: Federal Definition, not local)


FAQ

1. Do I have to have a toilet on my boat?
 

Short answer, No....  However as with anything their are some qualifications involved.
Did your boat come originally with a head? If no, sail on... If yes, you must either keep it in operational condition, or Vessel owners may elect to remove installed toilets and use instead portable toilets(2).  For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable.(2)




2. What are the classes of MSD


Type I is a flow through discharge device that produces effluent having a fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating solids.  This type of device is typically a physical/chemical based system that relies on maceration and chlorination.  Type I MSDs are issued a Certificate of Approval.(2)

Type II is a flow through discharge device that produces effluent having a fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not greater than 150 milligrams per liter.  This type of device is typically a biological or aerobic digestion based system.(2)

Type III is a device that prevents the overboard discharge of treated or untreated sewage or any waste derived from sewage.  This type of device is typically a holding tank and may include other types of technology including incineration, re-circulation, and composting.(2)


3. What are the acceptable means of "locking out" the overboard discharge in a no-discharge area?

Closing the seacock and removing the handle;
Padlocking the seacock in the closed position;
Using a non-releasable wire-tie to hold the seacock in the closed position;
Locking the door to the space enclosing the toilets with a padlock or door handle key lock.(4)


4. What about "Porta-Potties"?

Vessels having no installed toilet are not subject to the provisions of Section 312 of the Act.  Portable toilets or porta-potties that use no installed water, power, etc., are not considered installed toilets and therefore not subject to the requirements in 33 CFR Part 159.  However, regulations still exist to prohibit disposal of raw sewage within U.S. territorial waters, the Great Lakes, and navigable rivers.  Use of portable toilets in combination with a direct discharge toilet is not permitted.  Vessel owners may elect to remove installed toilets and use instead portable toilets.  For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable.  For inspected vessels using portable systems, use only devices manufactured of a durable material, such as molded plastic, aluminum, etc., to facilitate removal ashore, securely fastened to the vessel using straps, wooden framing, or similar materials, and maintained by the vessel operator following the manufacturers instructions as to waste disposal, chemical additives, etc.(2)

5. What about Composting Toilets?

USCG accepts Composting Toilets as a type III along with holding  tanks, incineration and  re-circulation.(2) However, all composting toilets must be approved if installed after Jan 30, 1976.(1)(2)(4)(5) It could be argued that Composting Toilets are in fact, not an MSD but rather a Portable Toilet with a rather long cycle time.

6. Is "Greywater" included in the No-Discharge-Zone ?

IMHOP No.... (with the exception of commercial vessels)
No permit shall be required under this chapter by the Administrator (or a State, in the case of a permit program approved under subsection (b)) for the discharge of any graywater, bilge water, cooling water, weather deck runoff, oil water separator effluent, or effluent from properly functioning marine engines, or any other discharge that is incidental to the normal operation of a vessel, if the discharge is from a recreational vessel.(3)


Final Notes:


None of us wants to poop in our own front yard... Especially in a crowded anchorage. Swimming round the brown trout is no fun. And yet, we also do not need to be bound by mindless bureaucracy when a better path exists. Hence this thread. What works for you?  How did you convince the local authorities you were legit? What questions do you have that haven't been addressed? And so on....

One final reminder. If you are in a position where you are signing a rental agreement with anyone. State, City, Private, whatever... you are playing in their court. They are within their rights to tell you your boat has to be blue to rent there if they want. No use to female dog... Just move on.

Cap' Couillon


References:

(1) USC Title 33 ? Chapter 26 ? Subchapter III ? ? 1322
(2) USCG Systems Engineering Inspection Guidlines
(3) Title 33 ? Chapter 26 ? Subchapter IV ? ? 1342
(4) Title 33: Navigation and Navigable Waters PART 159?MARINE SANITATION DEVICES
(5) EPA Marine Sanitation Devices
Cap' Couillon

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Offline Fireboat52

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Re: The Poop on Poop
« Reply #1 on: July 04, 2013, 11:23:25 AM »
I agree with your assessment of the composting toilet system. As the manufacturer of the C-Head composting toilet and as a member of a family with a retired USCG station commander in it, let me make some added observations. Rather than confronting the LEOs, the best approach is to keep your head clean and in good repair, be polite and knowledgable about your head. If the officer who boards you is having a bad day, you are going to probably have a bad day too, no matter what.

Composting toilets are the solution to three big problems that boaters face; water conservation, head odor and urgency to discharge your holding tank. It is a shame that originally someone decided that a household type flushing toilet was a good solution for marine pleasure craft, probably one of the worst mismatches of all times. As a result, an infrastructure and regulatory system has grown up around it and become entrenched. As such we have become slaves to the pump out station and live in fear of the law.

Imagine a world where your toilet doesn't smell, has no hoses or valves or thru hull fittings and you simply pour the contents from one bucket into a 5 gallon bucket once a week for storage. A month later the bucket is full and you drop it off (when it is convenient) at a marina where you are getting fuel where it is picked up by the sanitation department. Imagine a world where you simply pour your urine overboard daily in areas that are not land locked or restricted due to no water movement. Law enforcement would be free to admit that they too just pee in the water when they have to. They could spend their time catching poachers and speeders instead. This is all in our power and ultimately up to us.

Just some thoughts.

Sandy Graves

Offline rorik

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Re: The Poop on Poop
« Reply #2 on: July 04, 2013, 04:05:02 PM »
Disclaimer:
I have a Lavac.

My thoughts on the composting heads...
 
As a liveaboard, if the marinas here in the PNW/Puget Sound caught you "pouring your urine overboard" you would most likely lose your moorage. Some of the marinas here won't even let you wash your boat with anything but water or water/vinegar.
The EPA last month(?) settled with King County and the City of Seattle for a hefty sum because the city and county have been dumping millions of gallons annually into Puget Sound.
Why would I contribute to that?

I'm all for keeping the waste on board, unless you're pretty much offshore, until you can get to a pump out station.

Where, on a 28 foot boat, am I supposed to keep a bucket full of poop? My holding tank has a cabinet built around it to hide it. How do I do that to a bucket I'm going to throw away once a month? Or even just continually use as a transfer tool?
In the vein of "Reduce, Re-Use, Recycle" why am I tossing a dozen or more buckets, or even plastic bags, a year into a landfill?
How much space on a 28 boat do I have  to allocate for the storage of a years worth of peat?
If it takes 1 brick of peat to start the process, and a case of 4 bricks is $20, at 1 brick per month, that's $60 a year.
If a Natures Head or Air Head costs $800 - $1000 and a C-Head costs $500, plus the $60 for peat, that's roughly $600 - $1100 for the first year. And $60 - $100 each year thereafter.

The Lavac has no moving parts, other than the bilge pump. It uses roughly a pint of raw water to flush the bowl. The Lavac is $500, plus a holding tank and some hose. A rebuild kit for the pump and seals for the seat are $60. There are no annual costs. Maintenance consists of pouring a little vinegar in the bowl once a month.

Personally, a composting head seems like a lot of extra annual expense, extra effort and a loss of storage space, to potentially get rid of a smell and make life "easier". Nor does it seem to offer any greater solution to the pollution issues.

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Offline s/v Faith

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Re: The Poop on Poop
« Reply #3 on: July 04, 2013, 04:32:35 PM »
Real life numbers on composters.

I just returned from 6 months in the Virgin Islands, TCI, and Bahamas.

I was aboard every day.  I had at least 1 crew with me, and as many as 6 other people.  We all used one composting Air Head.

I cleaned it out 5 times, but one of those times was only because I used the wrong compost.  The CocoTEK bricks are $8 each on Amazon, I bought a case online and pAid less then $5.  So six months, should have been $20 but even if you count 5 clean outs at $8 each we are talking $40 or $80 a year.  Likely expense for a crew of 2?  About half that.

Not even as much s half a dozen cheap pup outs of a regular holding tank.
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Offline s/v Faith

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Re: The Poop on Poop
« Reply #4 on: July 04, 2013, 04:37:10 PM »
No idea why anyone would throw away a bucket to empty a head?  No composter I know of does not reuse the containment vessel.

I only bagged the waste one time, the rest of the times I found suitable places ashore to dump it.  The product is really pretty dry and not at all offensive compared to what comes out of a porti potty or a holding tank.

The solid waste can go a very very long time under light use without being dumped.  I find it really dries out and the solids break apart into the compost over time.
Satisfaction is wanting what you already have.

Offline s/v Faith

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Re: The Poop on Poop
« Reply #5 on: July 04, 2013, 04:38:57 PM »
I do not produce any more urine then a dolphin, shark, or manatee....  I really don't see that as much of an issue...
Satisfaction is wanting what you already have.

Offline CharlieJ

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Re: The Poop on Poop
« Reply #6 on: July 04, 2013, 04:49:07 PM »
Nor do I.

Here on the gulf coast, and all around Florida and up the east coast, plus all through the Bahamas, urine routinely just gets dumped overboard.

And I have zero problems with that.
Charlie J
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Offline ralay

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Re: The Poop on Poop
« Reply #7 on: July 05, 2013, 11:46:13 AM »
Why not just use free/cheap sawdust instead of coir/peat?  We have some land friends with a saw dust-filled composting toilet.  Seemed just as inoffensive as ours.

Also, if you spend a lot of time in a crowded marina and are concerned about your pee, why not just carrying your pee jug up to the bathrooms/port-o-potty dump?  Ours has handles and a screw cap so it can safely go for a dinghy ride/a walk up the dock.  It fills up slower when we're close to land anyways as we're usually out and about rather than sitting on the boat.  They sell spares to increase one's capacity, though they seem expensive for what they are.

Either way, the simplest, most economical thing to do is usually to work with what you already have.  We went with the Airhead that came with the boat.  If the boat had come with a Lavac, we'd be going with that. 

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Offline rorik

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Re: The Poop on Poop
« Reply #8 on: July 05, 2013, 12:25:08 PM »
Re-reading my post ...... didn't mean to sound so harsh....
I've been focusing on cutting any and all costs I can lately, especially monthly or annual costs.
And I have enough trouble remembering what day it is, so remembering to carry a bottle to the marina facilities and to buy peat, etc is just more than I want/need to do....
Call me I'm cheap and lazy if you must.
 ;D

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Offline Fireboat52

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Re: The Poop on Poop
« Reply #9 on: July 05, 2013, 08:33:27 PM »
With a C-Head you do store the waste in a 5 gallon disposable bucket that costs around $5 including the lid. The bucket and the medium don't take up any more space than a holding tank. You can easily wait until you are off shore to dump it out if you don't want to add the plastic to the landfill.

Besides the reduction in odor, savings in water usage and simplicity with respect to maintenance, a more important point as to why composting toilets are more "green" is that you cannot simply dump one overboard very inconspicuously or without incriminating yourself as you can with a holding tank. The simple truth is that holding tanks (regardless of which head you have) are easy to evacuate in the middle of the night or while underway and it is routinely done by many boaters for many different reasons. Some do it just to spite the law, some for emergencies and some just for convenience sake. If every boat had a composting toilet the reduction in water pollution from pleasure craft would be gigantic. For one thing, there is no urgency to empty the system as there is with a holding tank. When the holding tank is full you can either stop using the toilet or empty the tank by whatever means necessary. Those are your choices.

Sandy
« Last Edit: July 06, 2013, 04:50:19 AM by Fireboat52 »

Offline s/v Faith

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Re: The Poop on Poop
« Reply #10 on: July 05, 2013, 09:01:31 PM »
Sandy,

  I do not recall welcoming you to the forum.  Let me fax that now.  ;D

Glad you are here.
Satisfaction is wanting what you already have.

Offline Fireboat52

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Re: The Poop on Poop
« Reply #11 on: July 06, 2013, 04:53:09 AM »
Thanks! I hope I can be helpful and add good information to the conversation.

Offline Fireboat52

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Re: The Poop on Poop
« Reply #12 on: July 06, 2013, 09:53:14 AM »
I would like to address this paragraph in the original post

"USCG accepts Composting Toilets as a type III along with holding  tanks, incineration and  re-circulation.(2) However, all composting toilets must be approved if installed after Jan 30, 1976.(1)(2)(4)(5) It could be argued that Composting Toilets are in fact, not an MSD but rather a Portable Toilet with a rather long cycle time."

If you look at the laws written about marine toilets, it is apparent that they were written in haste in the need to get something on the books and probably not by admiralty lawyers or persons with intimate knowledge of marine sanitation. With respect to "porta potties" or more correctly "portable toilets" you can find statements that say that a portable toilet is automatically classified as MSD III and others that  state that the portable toilet is not classified at all but is still legal.  Portable toilets are generally considered to be toilets that are designed so that the waste can be hand carried ashore for disposal using all or part of the toilet to that end. If the toilet meets that criteria and has a label with the statement "This product is designed and manufactured as a portable toilet", that pretty much seals the deal.

Couple that with the fact that every LEO has his or her own idea of what is legal and what isn't and you can understand the dilemma we boaters face. The question is, are you more likely to get on the wrong side of the law with a holding tank or a portable system. I can imagine that if you save the officer the indignity of getting down on his hands and knees to inspect your stinky hoses, you probably get a "plus" check mark. If you emphasize that the waste is carried ashore for disposal, you probably get another one. If your head (and boat) is clean and doesn't smell or look complicated . . . well you get the drift. Piss them off, and I guarantee you that they will find something wrong.

Another portion of the USCG law is this little caveat.

"For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable."

Shouldn't all "non-compliant" toilets be removed or made inoperable regardless of whether you have a portable toilet on board or not? This statement makes no sense and why it is made is something of a mystery. Presumably they thought someone would use the portable toilet as an excuse to be compliant and then dump the contents into the non-compliant toilet to get rid of the waste? Even so, with a composting toilet, this is not possible since organic matter expands in water and would clog up the system in very short order. Plus imagine the act of trying to do that. My guess is that this is neither understood by the ordinary Coastie or other LEO and probably not enforced, but then again, I may be missing something.

Bottom line here is that if your MSD system is compliant then you can have a portable toilet on board as well. This is important for larger boats or catamarans with a head in each hull.

Any thoughts?

Sandy
« Last Edit: July 06, 2013, 01:13:31 PM by Fireboat52 »

Offline CharlieJ

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Re: The Poop on Poop
« Reply #13 on: July 06, 2013, 11:30:25 AM »


Another portion of the USCG law is this little caveat.

"For vessels having a portable toilet, all non-compliant fixed toilets should be removed unless impractical or unsafe in which case such devices should be rendered permanently inoperable."

Shouldn't all "non-compliant" toilets be removed or made inoperable regardless of whether you have a portable toilet on board or not? This statement makes no sense and why it is made is something of a mystery. Presumably they thought someone would use the portable toilet as an excuse to be compliant and then dump the contents into the "non-compliant" toilet to get rid of the waste? Even so, with a composting toilet, this is not possible since organic matter expands in water and would clog up the system in very short order. Plus imagine the act of trying to do that. My guess is that this is neither understood by the ordinary Coastie or other LEO and probably not enforced, but then again, I may be missing something.

Bottom line here is that if your MSD system is "compliant" then you can have a portable toilet on board as well. This is important for larger boats or catamarans with a head in each hull.

Any thoughts?

Sandy

Sandy - I suspect this was written to cover vessels with several heads aboard. Many large sail boats, and a great many large power boats have two complete heads,, a few even have three.

Only thing that would make sense to me. Most of us barely  find room for ONE head aboard.
Charlie J
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Offline cap-couillon

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Re: The Poop on Poop
« Reply #14 on: July 06, 2013, 02:33:04 PM »
As the "OP"  it has been interesting to watch to discussion on this thread.   

A couple of observations......

1.  Sandy's observation in the second post in this thread is really the bottom line.
Quote
Rather than confronting the LEOs, the best approach is to keep your head clean and in good repair, be polite and knowledgable about your head. If the officer who boards you is having a bad day, you are going to probably have a bad day too, no matter what.

2. On the other hand.... If you get into the situation of another quote from Sandy
Quote
every LEO has his or her own idea of what is legal and what isn't
If you look at the laws written about marine toilets
there are really only two sections of Federal law that apply...  The EPA "Clean Water Act which defines what you can and can't do, And the USCG regs which defines how you can/must meet the CWA requirements.

The states have no jurisdiction over MSDs other than being able to request a "No discharge zone" Local jurisdictions do however have the ability to enforce requirements under CFR 33 and as Sandy says, "every LEO has his or her own idea of what is legal and what isn't". If you do decide to stand up against a "bully" your best bet is to politely take you citation and make your battle in the courts. Might keep him from finding a number of other "violations".  (Are all your flares up to date?)

Myself, my biggest problem is every time I go to piss in the sink, it's full of dirty dishes
Cap' Couillon

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Offline CharlieJ

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Re: The Poop on Poop
« Reply #15 on: July 06, 2013, 02:57:14 PM »


Myself, my biggest problem is every time I go to piss in the sink, it's full of dirty dishes

 ;D ;D

Don't drink out of the red cup

 ;D ;D ;D

Friends told me that onboard their boat- it was the Pee can!

On Tehani, it's a red coffee can, lives in the cockpit, and both of us used it.
Charlie J
Sailing on S/V Tehani
Meridian 25

On Matagorda Bay
On the Redneck Riviera

Offline Godot

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Re: The Poop on Poop
« Reply #16 on: July 07, 2013, 05:14:40 PM »
FWIW, I just spent my first week aboard with my Nature's Head (I tore out the previous setup after an unfortunate and messy incident late last year).

So far, it is working very well. Two aboard all week, daily use, and the solids side doesn't look appreciably more full than when we started. It did smell a little odd the first couple days; but now that is no longer an issue. If you have a girlfriend like mine, the liquid side fills up remarkably fast. Not a huge deal, though, so long as you are cognizant of how full it is. I have the spare bottle. actually, the only time the smell is offensive is when removing the liquids bottle. Pee stinks.

Interestingly, in my case the toilet has worked just fine on both tacks. This was a big concern of mine. Of course, the Bayfield sails far more upright than my previous Seafarer.
Adam
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Offline Porter Wayfare

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Re: The Poop on Poop
« Reply #17 on: July 07, 2013, 05:43:35 PM »
I'm having a slow day.  I mean, I'm slow today.  What is an LEO.  Legally Entitled (to be) Obnoxious?
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Offline Godot

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Re: The Poop on Poop
« Reply #18 on: July 07, 2013, 05:48:11 PM »
I'm having a slow day.  I mean, I'm slow today.  What is an LEO.  Legally Entitled (to be) Obnoxious?

Sometimes I think you are right. More generally LEO stands for Law Enforcement Officer.
Adam
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Offline Porter Wayfare

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Re: The Poop on Poop
« Reply #19 on: July 07, 2013, 05:50:54 PM »
Duh.
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I can't watch the sea for a long time or what's happening on land doesn't interest me anymore.  -Monica Vitti