POLLUTION PREVENTION EQUIPMENT
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 Marine Sanitation Device (MSD)

No person may operate any vessel equipped with installed toilet facilities unless it is equipped with an operable MSD.  “Porta-potties” are not considered as installed toilet facilities.  If the vessel has a type I or II MSD and does not have an adequate stock of chemicals on board, these MSDs are not considered

operable.  

Properly operating Type I and II MSDs are devices that produce an effluent and solids that do not exceed regulatory limitations.  A Type III MSD is designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage.  

Most Type I and II MSD’s require the use of chlorine tables to function properly.  Contact between petroleum products and chlorine tablets may cause fires and explosions.  Chlorine tables must be properly stored IAW manufacturer instructions and the Material Safety Data Sheet.  

Some Type III MSDs use incineration to prevent the discharge of untreated sewage; however, most are configured with a “Y” valve to retain untreated sewage in a holding tank on board the vessel while operating on the Navigable Waters of the United States. If the vessel’s route does not routinely take it into coastal waters beyond the Navigable Waters of the United States where untreated sewage can be legally discharged, the installation of a “Y” valve-equipped Type III MSD is inappropriate; these vessels must be equipped with an alternate means of discharging untreated sewage from the holding tank to a shore-based sewage treatment facility.  

When operating a vessel in a no discharge zone where the discharge of treated or untreated sewage is prohibited by the EPA under 40 CFR 140.3 or 140.4, each Type I, II and III MSD must be secured in a manner which prevents discharge of treated and/or untreated sewage. For Type I and II MSDs, acceptable methods of securing the device include 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; or locking the door to the space enclosing the toilets with a padlock or door handle key lock.  For a Type III MSD, acceptable methods of securing the device include closing each valve leading to an overboard discharge and removing the handle; padlocking each valve leading to an overboard discharge in the closed position; or using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.  

Items to check:

  • MSD installed is appropriate for length of vessel and operating area:
    • Vessel 65 ft or less in length:
      • Type I
      • Type II
      • Type III
    • Vessel over 65 ft in length:
      • Type II
      • Type III
    • If Type I or II is installed:
      • Adequate supply of chemicals on board IAW manufacturer
      • Proper certification label and operating placard that contains:
        • Operating instructions
        • Safety precautions
        • Warnings pertinent to the device.
        • Lettering one-eighth of an inch or larger
      • If the vessel operates in a no discharge zone(s) there is a means to secure the device in a manner which prevents discharge of treated or untreated sewage.
    • If Type III with “Y” valve is installed, it properly secured  

Regulatory Cites:

33 CFR Part 159 Marine Sanitation Devices
33 CFR 159.7 Requirements for vessel operators
33 CFR 159.59 Placard
33 CFR 159.65 Chemical level indicator
40 CFR Part 140 Marine Sanitation Device Standard
40 CFR 140.3 Standard
40 CFR 140.4 Complete prohibition  

Additional Guidance:

Marine Safety Manual Volume II

 Oil Pollution Prevention

Towing vessels must have the capacity to retain on board all oily mixtures and be equipped to discharge those oily mixtures to a reception facility.  Oceangoing vessels, as an alternative, may be equipped with an approved oily-water separating equipment for processing oily mixtures from bilges and discharges into the sea according to 33 CFR 151.10.  Vessels may retain oily mixtures onboard in the  bilges; however; no person may intentionally drain oil or hazardous materials from any source into the bilge - see 33 CFR 155.770.

Vessels 300 GRT or more constructed after June 30, 1974 must have a fixed container or enclosed deck area under or around each fuel oil, bulk lubricating oil tank vent, overflow, and fill pipe with capacities as follows:

  • At least one-half barrel for a vessel a less than 1600 GRT
  • At least one barrel for a vessel 1600 GRT or more

A vessel of 100 GRT or more constructed before July 1, 1974 and a vessel of 100 or more but less than 300 GRT constructed after June 30, 1974 must meet the above requirements or, during oil transfer operations, equip each fuel oil, bulk lubricating oil tank vent, overflow, and fill pipe with a portable container of at least a 5 U.S. gallon capacity or, if the vessel has a fill fitting for which containment is impractical, use an automatic back pressure shut-off nozzle. 33 CFR 155.320.

Towing vessels over 300 GRT are required to have Certificates of Financial Responsibility (COFR) - see 33 CFR 138.10. The Coast Guard no longer issues COFRs. If the vessel owner and operator are not the same, the operator must ensure that the original or copy of the demise charter-party is maintained on board the vessel and made available upon request. The demise charter-party may be substituted by a written document on the owner’s letterhead, signed by the vessel owner, which specifically identifies the vessel operator named on the COFR – see 33 CFR 138.100.

Items to check:

  • Records contain required info:
    • Name of each person currently designated as a person in charge of transfer operations.
    • Date and result of the most recent test and inspection of each item tested or inspected required by 33 CFR 156.170
    • Hose information required by 33 CFR 154.500(e) and (g) unless that information is marked on the hose
  • Hoses in oil service properly marked:
    • Maximum allowable working pressure
    • Date of manufacture (may be recorded in the hose records)
    • Date of the latest test required by 33 CFR 156.170 (may be recorded in the hose records)
  • Spill containment system at hose connections, vents and fills
  • If vessel is 26 feet or greater in length, Oil pollution placard posted
  • If vessel is equal to or greater than100 GRT has either:
    • An approved oily-water separating equipment for the processing of oily mixtures from bilges or fuel oil tank ballast; or,
    • Pumping, piping and discharge equipment that:
      • At least one pump installed to discharge oily mixtures through a fixed piping system to a reception facility
      • At least one piping system outlet that is accessible from the weather deck
      • Shore connection(s) at each outlet that is compatible with reception facilities in the ship's area of operation
      • A stop valve for each outlet
      • For oceangoing vessels only:
        • If the vessel goes on international voyages, outlet(s) have a shore connection that meets the specifications in §155.430, or the ship has at least one adapter that meets the specifications in §155.430 and fits the required outlet(s)
        • A means on the weather deck near the discharge outlet to stop each pump that is used to discharge oily mixtures
  • For vessels with a capacity of 250 barrels (10,500 gallons):
    • Declaration of Inspection(s) properly completed and retained for at least 1 month from date of signature as required by 33 CFR 156.150
    • Oil transfer procedures:
      • Available for inspection
      • Legibly printed in a language or languages understood by personnel engaged in transfer operations
      • Permanently posted or available at a place where the procedures can be easily seen and used by members of the crew when engaged in transfer operations.
      • Contents complete:
        • A list of each product transferred to or from the vessel
        • A description of each transfer system on the vessel:
          • A line diagram of the vessel's transfer piping, including the location of each valve, pump, control device, vent, and overflow
          • The location of the shutoff valve or other isolation device that separates any bilge or ballast system from the transfer system
          • A description of and procedures for emptying the discharge containment
        • Number of persons required to be on duty during transfer operations
        • Duties of each officer, person in charge, tankerman, deckhand, and any other person required transfer operations
        • Procedures and duty assignments for tending the vessel's moorings during the transfer operations;
        • Procedures for operating the emergency shutdown and communications means
        • Procedures for topping off tanks;
        • Procedures for ensuring that all valves used during the transfer operations are closed upon completion of transfer
        • Procedures for reporting discharges into the water  

Regulatory Cites:

33 CFR 138.10 Scope (COFR)
33 CFR 138.100 Non-owning operator's responsibility for identification
33 CFR 151.10 Control of oil discharges
33 CFR 154.500 Records
33 CFR 155.320 Fuel oil and bulk lubricating oil discharge containment
33 CFR 155.410 Pumping, piping and discharge requirements for non-oceangoing ships of 100 gross tons and above
33 CFR 155.420 Pumping, piping and discharge requirements for oceangoing ships of 100 gross tons and above but less than 400 gross tons
33 CFR 155.450 Placard
33 CFR 155.720 Transfer procedures
33 CFR 155.740 Availability of transfer procedures
33 CFR 155.750 Contents of transfer procedures
33 CFR 155.770 Draining into bilges
33 CFR 155.800 Transfer hose
33 CFR 156.150 Declaration of inspection
33 CFR 156.170 Equipment tests and inspections  

Additional Guidance:

Marine Safety Manual Volume II