Jeff wrote:
I've often wondered it this setup requires a "lock" on the pumpout to
comply with 33CFR159.

It doesn't...Only valves and/or seacocks connected to overboard
discharge thru-hulls must be secured:

33CFR159 sayeth:


(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.

No mention of the pumpout line at all.

However, inland may be another story. The Great Lakes and all non-navigable
inland lakes are “no discharge” waters. They’re also a loooong way
from the ocean. Since there's no possible way to legally use a
y-valve or macerator to dump a tank, many states have made it illegal
for vessels operating on these waters even to have one or both
installed. When in doubt, check with your local authorities.


Most descriptions of the reg refer to "preventing
accidental discharge" or securing a "direct discharge" line.

There are no adjectives in the wording of the CFR (which I copy/pasted
directly from it above)...just "discharge."

If the holding tank is considered part of the MSD Type
III system, then it would seem its pumping system would be included.

Any means of pumping sewage overboard IS included. The CFR defines
"discharge" as: "includes, but is not limited to, any spilling, leaking,
pouring, pumping, emitting, emptying, or dumping." The deck pumpout
fitting would automatically be "secure" as long as no hose going over
the side is connnected to it.


--
Peggie
----------
Peggie Hall
Specializing in marine sanitation since 1987
Author "Get Rid of Boat Odors - A Guide To Marine Sanitation Systems and
Other Sources of Aggravation and Odor"
http://shop.sailboatowners.com/books...ku=90&cat=1304

Sorry Peggie, what I meant was the onboard pump that was shown in the
picture, not the deck pumpout fitting. I had assumed that my setup,
and Roger's, was legal because because it didn't come directly from
the head, but a closer reading of the CFR shows, as you say, that any
line that could be used to discharge overboard, is included and must
be secured.

Peggie Hall wrote:
Jeff wrote:
I've often wondered it this setup requires a "lock" on the pumpout to
comply with 33CFR159.

It doesn't...Only valves and/or seacocks connected to overboard
discharge thru-hulls must be secured:

33CFR159 sayeth:


(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.

No mention of the pumpout line at all.

However, inland may be another story. The Great Lakes and all
non-navigable
inland lakes are “no discharge” waters. They’re also a loooong way
from the ocean. Since there's no possible way to legally use a
y-valve or macerator to dump a tank, many states have made it illegal
for vessels operating on these waters even to have one or both
installed. When in doubt, check with your local authorities.


Most descriptions of the reg refer to "preventing
accidental discharge" or securing a "direct discharge" line.

There are no adjectives in the wording of the CFR (which I copy/pasted
directly from it above)...just "discharge."

If the holding tank is considered part of the MSD Type
III system, then it would seem its pumping system would be included.

Any means of pumping sewage overboard IS included. The CFR defines
"discharge" as: "includes, but is not limited to, any spilling, leaking,
pouring, pumping, emitting, emptying, or dumping." The deck pumpout
fitting would automatically be "secure" as long as no hose going over
the side is connnected to it.

Jeff wrote:
Sorry Peggie, what I meant was the onboard pump that was shown in the
picture, not the deck pumpout fitting. I had assumed that my setup, and
Roger's, was legal because because it didn't come directly from the
head, but a closer reading of the CFR shows, as you say, that any line
that could be used to discharge overboard, is included and must be secured.

It's legal. Since there is no y-valve, wire tying the seacock handle and
removing it, or removing the handle from the pump, or both, secures the
system.

Peggie



Peggie Hall wrote:
Jeff wrote:
I've often wondered it this setup requires a "lock" on the pumpout to
comply with 33CFR159.

It doesn't...Only valves and/or seacocks connected to overboard
discharge thru-hulls must be secured:

33CFR159 sayeth:


(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.

No mention of the pumpout line at all.

However, inland may be another story. The Great Lakes and all
non-navigable
inland lakes are “no discharge” waters. They’re also a loooong way
from the ocean. Since there's no possible way to legally use a
y-valve or macerator to dump a tank, many states have made it illegal
for vessels operating on these waters even to have one or both
installed. When in doubt, check with your local authorities.


Most descriptions of the reg refer to "preventing
accidental discharge" or securing a "direct discharge" line.

There are no adjectives in the wording of the CFR (which I copy/pasted
directly from it above)...just "discharge."

If the holding tank is considered part of the MSD Type
III system, then it would seem its pumping system would be included.

Any means of pumping sewage overboard IS included. The CFR defines
"discharge" as: "includes, but is not limited to, any spilling,
leaking, pouring, pumping, emitting, emptying, or dumping." The deck
pumpout fitting would automatically be "secure" as long as no hose
going over the side is connnected to it.




--
Peggie
----------
Peggie Hall
Specializing in marine sanitation since 1987
Author "Get Rid of Boat Odors - A Guide To Marine Sanitation Systems and
Other Sources of Aggravation and Odor"
http://shop.sailboatowners.com/books...ku=90&cat=1304