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HMRC internal manual

Hydrocarbon Oils Strategy

Registered Dealers in Controlled Oils (RDCO): duty of care: testing traders' controls

The following checks should be undertaken by examining RDCOs’ systems and records, management checks and controls (if any) and by interviewing both staff and management about their knowledge of their individual responsibilities for the sale, supply and delivery of controlled oil under the RDCO Scheme.

  • Are staff aware of their responsibility for ensuring that the business is seen to be exercising a duty of care?
  • What evidence is there that (any) training or guidance given to staff (including to delivery drivers) is being followed?
  • What evidence is there of any management checks or controls to ensure their staff are aware of, and performing the checks they should be carrying out before making a supply of rebated oil?
  • Are staff familiar with the relevant sections of Notice 192, in particular the requirements of Section 10.1 ‘Indicators of suspicious supplies’?
  • Are staff aware of the procedures they should follow when misuse is suspected and if so, do they routinely follow the procedures?
  • Are delivery drivers aware of the procedures they should follow to report any suspicious deliveries and do they routinely follow these procedures?
  • What action does the RDCO take if their drivers report a delivery was suspicious?
  • What efforts are RDCOs making to obtain missing information, such as VAT Registration Numbers (VRNs) or post codes?
  • Is this information available from another source, such as any credit checks made before delivering to a customer (which would be expected to include as a minimum, details of the customer’s name, address, telephone number and post code)?
  • How often do they accept orders in the absence of the required information?
  • Are staff familiar with the relevant sections of Notice 554 in particular sections 3 and sections 12?