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D-2 Is No Longer Optional: A Master's Quick-Reference Table for BWM and SIRE

🕑 5 min read words Revision-general

From 8 September 2024, every vessel subject to the Ballast Water Management Convention must meet the D-2 performance standard through an approved Ballast Water Treatment System (BWTS). The D-1 exchange standard is no longer a standalone compliance option for any vessel capable of fitting a BWTS — this is worth stating plainly because older habits die hard on this point.

What SIRE and CDI Actually Check

SIRE (OCIMF's Ship Inspection Report programme, primarily for tankers) and CDI (for chemical tankers) both carry BWM questions as part of vetting. This isn't a formality — oil-major and chemical-major charterers factor BWM compliance status directly into pre-fixture approval decisions. A vessel with an unclear or lapsed BWM compliance position can lose fixture opportunities before a Master even knows it's been considered.

What's Changing Next

The Experience-Building Phase (EBP) concluded in 2025, and a Convention Review Plan is now underway that may revise D-2 thresholds, testing protocols (including DNA-based rapid sampling tools), and PSC guidance by 2026. Treat this as a live regulatory area, not a settled one — don't assume this year's compliance checklist will be identical next year.

A Practical Master's Checklist

Confirm your BWTS type-approval certificate is current and matches the installed system. Confirm ballast water record book entries are complete and consistent with actual operations, not retrospectively tidied. Know your D-2 compliance date and whether any extension or exemption applies to your specific vessel — and if SIRE/CDI vetting is coming up, have this documentation ready before the inspector asks, not after.

Test Your Knowledge

Think you've got this covered? Put it to the test in Crew Connect's free Knowledge Checker — try a quick MARPOL round and see how you score.

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