Environment and Legislation

BoatWide make custom made holding tanks (septic tanks) for waste and grey water to fit almost any available space.  Caring for the environment and compliance with legislation.

Spain

There is increasing pressure on boat owners in Spain to fit grey water tanks. Particularly in conservation areas. 

Sant Carles de la Rapita Marina in the Ebro delta are introducing compulsory grey water tanks in the new marina for all boats. This was an agreement that MDL had to agree to in order to operate the new Marina at sant Carles.

Whilst there is no overall Spanish law which makes the fitting of Grey water tanks obligatory, it could be that local conservation laws will be able to impose these requirements.  It is possible that the Spanish authorities could interpret sections of the black water tank law, such as “you will not pollute” in such a way as to create the imposition.

Laws in Spain introduced in 2004 make it compulsory for Spanish flagged vessels to fit holding tanks.  For many boats, particularly older ones that are not designed to accommodate holding tanks, this will pose some problems.

Boats that are under the Recreational Craft Directive, i.e. those younger than 1998,  were supposed to be built to take holding tanks.  In some cases it has been shown that perhaps not enough attention was given to the size of tank needed by the crew and therefore a problem remains in fitting a suitable size tank.

The Spanish legislation, ORDEN FOM/1144/2003, 28 April makes a number of statements as follows.

Under Chapter 5 “Prevention of Sewage” It states the following
 

In port waters, protected zones, Rivers, Bays, etc. It is not permitted to discharge sewage, even with treatment.

Up to 3 miles from shore. It is permitted to discharge with treatment, however there must be no solids and no discoloration of the water.

Treatment is not accurately defined but to create the compliance with "no solids" it would definately involve some form of maceration.  However as the zone 3 miles to 12 miles talks about "crumbled and disinfected", what "treatment" means in the 3 mile zone we can hardly guess.  We can only guess at it meaning heavily chemically treated, which flies in the face of the whole anti-pollution idea in the first place. 

The phrase "no discoloration of the water" is equally not defined.  It could be thought that this would involve some form of chemical treatment but not a coloured chemical, leaving the boat owner to ponder colourless chemicals such as bleach.  We are not suggesting the use of bleach (this would be a disaster for the environment)

We are seeking to get this one answered but are not receiving much of a response from the authorities.  We think that they dont really know themselves.

We recommend not discharging anything in the 3 mile zone as it is difficult to advise on what compliance would actually be.

From 3 miles to 12 miles. It is permitted if crumbled and disinfected.  Also, for discharging, the speed of the vessel must be more than 4 knots. 

We suggest of the type of maceration brought about by an electric macerator, not interpreted as "some form of maceration caused by pumping the toilet into the tank and then hand pumping the tank overboard"

Disinfected, we have a problem with this one. We suggest a small amount of "disinfectant" such as the toilet chemical products for portable toilets.  Whilst this is coloured, there is not a clause regarding the coloration in the 3 to 12 miles zone.  We do not like the idea of any chemical in the discharge, however, if challenged you should be able to prove that you have the means to crumble and disinfect for discharge in this zone.

We can confirm that a well functioning macerator discharging whilst the boat is moving at more than 4 knots produces a quickly dispersed light brown cloud which, in our opinion, if free from chemicals would be perfect for the environment.

More that 12 miles.  It is permitted in any condition.  Also, for discharging, the speed of the vessel must be more than 4 knots.
 


Whilst the compulsory fitting of tanks relates to only Spanish flagged vessels the legislation also states that there shall be no pollution from any boat (regardless of flag).  This means that if you do not have a holding tank then you cannot use your toilet (until you are 12 miles offshore).

In terms of the Spanish regulation applied to the Spanish flagged vessels it states 4 litres per person per day for two days, the number of persons being the person capacity of the vessel (i.e. the number of berths).  The regulation also states that the installation should be to the EU standard ISO 8099 which means having a hatch fitting on the tank amongst other things.  The regulation also incorporates a deck pump out fitting.  Note that the Spanish Ministry diagram also shows a hull discharge facility in addition to the deck pump-out. 

At present. April 2009.  There are very few pump-out facilities in Spain, making a farce of the legislation and the boat MOT which demands a pump-out fitting.  Also, due to the EU ISO 8099 specification not accurately defining the pump out deck fitting, there are many pumps that dont fit with many deck fittings.  It is a lottery if your deck fitting fits with the pump out of the marina you just pulled into.  It may well fit perfectly in the next marina along the coast.

If you are not a Spanish flagged vessel you must remember that you must not pollute, therefore fit a tank.  The Spanish legislation demands 4 litres per berth per day.  Our advice is to go for the biggest tank you can get into the boat.  The reason for this is that pump-outs cost money, marina offices close during the siesta, deck fittings dont fit, and going at least 3 miles offshore might not be convenient. Also, a full tank and full crew dont go together well.

Have the tank manufactured with a dip tube and screw fitting hose-tail connection ready for a deck pump out but in place of the hose-tail have a screw on blanking cap.  Do not necessarily install the deck fitting and pipes until you are ready.  You can even choose to have a hatch fitted at a later time because (at present, as a UK registered vessel) you dont have to comply with the fullness of the ISO specification.  There are retrofit hatches available. You simply empty the tank, give it a good flush through, cut the hole in the tank the right diameter, fit the hatch.

 

Greece and Turkey

Whilst there are no stated requirements. It seems that foreign boats are targeted and penalised for any type of discharge.  Note especially that sink water, shower water discharge in a port will surely bring the officials onboard

 

 France and Italy

We only have information on the French canals, where it is stated that there will be no discharge from boats.

 

Croatia

We have no information.  However, it is clear.  If you are caught discharging, there is probably some law that will allow the authorities to tke action against you

 

Note that generally in a foreign country there is probably some law that you dont know about that can be applied that will allow the authorities to take action against you.   In the mediterranean it is better to face the issue and fit a holding tank of sufficient capacity to suit your cruising needs.