Welcome to our new monthly feature created for small and medium-sized fuel oil distributors across the UK and Ireland.
In this new series we will focus, each month, on a single, business‑critical topic to enable you to assess current practice, understand industry developments, and make informed decisions to improve operational efficiency, profitability, and resilience.
From optimising depot operations and managing cash flow to navigating regulation and seizing new growth opportunities, our goal is to do the research for you, present the facts clearly, and give you practical, data-led actions you can implement immediately.
While larger companies may have in-house HR teams, fleet managers, compliance officers and analysts, many fuel oil distributors (FODs) operate without these. Delivering Insight is your virtual support team – a growing knowledge base that builds into a valuable reference library, helping you make informed decisions that safeguard your business for today and strengthen it for the future.
Dangerous Goods Security Audit isn’t just a compliance exercise – it’s a vital safeguard for your business, your customers, and the wider community. For SME fuel distributors in particular, getting it right the first time saves time, money, and the stress of repeat inspections.
Drawing on years of hands-on operational experience in the fuel distribution sector, Viki shares her tried-and-tested advice for preparing effectively and making the most of your audit.
Why this matters for fuel oil distributors
If you transport High Consequence Dangerous Goods (HCDG), you are legally required to undergo a DfT Dangerous Goods Security Audit every two years. These audits ensure that your recruitment processes, training programmes, security measures, and operational procedures meet the standards set out under ADR.
Failing to prepare can lead to:
- Costly remedial actions
- Reputational damage
- Increased regulatory scrutiny
- In extreme cases, restrictions on operations
SME Focus: Unlike large operators with dedicated compliance teams, smaller distributors must often manage preparation alongside daily operations – making a clear, practical plan essential.
What the audit covers
The inspection is split into four core sections:
- Recruitment and Training
- Security Programme
- Physical Security and Equipment
- Access Control and Passes
Each section has its own set of evidence requirements.
Common audit triggers
Not all dangerous goods are high consequence. HCDG actually refers to a very specific category defined in the ADR regulations and only some products, in certain volumes, meet the criteria.
They are high consequence because, in the wrong hands, they could be misused causing high consequence destruction.
You will need an audit if you transport:
- Petrol: Any load over 3,000 litres
- Kerosene, diesel, heavy fuel oils: Any volume
If in doubt, check with your DGSA. Even a one-off high consequence delivery triggers the requirement.
The DfT will often make the initial contact, having spotted your tankers on the road sporting orange ADR plates, or even your company website and adverts showcasing that you transport dangerous goods.
You will usually get an email from them asking if that includes any high consequence dangerous goods, and if you are, then good news – they’ll need to book an ADR Security Inspection in with you soon. And if you’re not, go back to them and confirm so that they can take you “off their list”.
How to prepare: Step-by-step
1. Recruitment and Training
Be ready to evidence of completion and documentation of on-the-job training and assessments as well as formal qualifications.
This will include:
- ADR driver training certificates
- Evidence of Dangerous Goods Awareness training for all relevant non-driving staff – such as salespeople, routers/planners and your transport team.
- Toolbox talks, driver handbooks, induction programmes
- Security-specific training, including the DfT “Lockdown” video (which can be requested from landsecurity@dft.gsi.gov.uk) and refresher modules (e.g. FORS Counter-Terrorism, ACT e-learning)
For recruitment you will need to evidence the way you control who you are employing or subcontracting:
- Document your vetting process: advertising, background checks, licence checks, references
- Include subcontractor vetting and audits including pre-employment DBS and licence checks as well as references taken.
Viki’s Tip: Inspectors focus heavily on recruitment and vetting – it’s often the weakest area.
2. Security Programme
This is about evidencing your security procedures and planning:
- Maintain a written ADR Security Plan (mandatory for HCDG)
- Keep it safely stored and regularly tested
- Use drills – tabletop or live – to test your plan with staff and contractors
Vikis’s Tip: Templates are available on GOV.UK; customise them to your operation.
Make drills dramatic but realistic – and make sure everyone knows it is a drill before they mobilise!
3. Physical Security and Equipment
With depot, tanker and in-cab technology advancing all the time, this is where most distributors get to ‘show off’. Inspectors want to see robust site as well as vehicle security – not just on site but also on their journey to/from and during deliveries.
Measures could include:
- Locked, combination key safe
- Site-wide, monitored CCTV
- Tank alarms
- Fob-controlled gates
- Intruder alarms
- Vehicle immobilisers, cameras and trackers
5. Access Control and Passes
This can be summed up in one question – what do you have in place to stop someone just wandering off the street into your depot?
- Prevent unauthorised entry with fob access or codes
- Keep visitor sign-in processes tight
Viki’s Tip: Don’t let inspectors walk in unchallenged – the audit starts the moment they arrive and there’s nothing more embarrassing than leaving your gates open allowing them to walk in unchallenged!
Emerging focus: Cyber and data security
Cyber resilience is now a key part of your security profile:
- Discuss defences with your IT provider
- Add cyber awareness training for drivers and depot staff
Viki’s Tip: Download the Protect UK app and check the website – it’s a great resource! Following recent cyber-attacks within the UK supply chain you will see a focus on cyber and data security – a common vulnerability for businesses.
SME-specific considerations
For smaller FODs:
- Prioritise low-cost, high-impact measures (clear signage, robust locks, training)
- Share resources with other distributors for specialist training
- Partner with compliance consultants if you don’t have in-house expertise
Worked example: Recruitment checks
Cost of a DBS check: In the region of £43 per driver
Potential cost of non-compliance: Thousands in fines, reputational damage, and possible licence restrictions.
Recommended actions
- Confirm if you are transporting HCDG and require an audit
- Audit your recruitment, training, and vetting procedures
- Review and update your ADR Security Plan
- Check physical security measures and fix gaps
- Add or update cyber security training
Security Audit Checklist
Recruitment and training
- Driver ADR qualifications up to date
Non-driving staff trained in Dangerous Goods Awareness
Recruitment/vetting procedures documented
Security Programme
- Written ADR Security Plan in place
- Regular drills conducted and recorded
Physical Security
- CCTV and monitoring in place
- Tank alarms and immobilisers fitted
Access Control
- Fob-controlled entry or access codes
- Visitor sign-in procedure enforced
Cyber Security
- Cyber awareness training delivered
- IT defences reviewed with provider
Final thought from Viki:
These audits aren’t designed to trip you up. Inspectors are a valuable source of guidance, and preparation turns the audit into a constructive, confidence-building experience.
The products we transport have the potential to cause devastation in the wrong hands. It is your responsibility to make sure suitable controls are in place to try and prevent that happening. Even though I work in this area, I have to remind myself not to become complacent about the risks associated with fuel – easily done when it becomes your day-to-day.
The audits are there to check controls are in place, and give advice where they are not, to help improve safety for everyone.
Rather than regarding them as an unwanted intrusion, take them as your opportunity to further improve your business and make the most of your time with the inspectors.
Viki has over 15 years’ experience in fuel distribution and high-hazard industries.
Having held operational roles with several major fuel distributors, Viki’s hands-on insight into the sector’s unique safety and compliance challenges enables her to turn complex regulations into pragmatic, effective safety protocols for fuel distributors.
Viki is a qualified Dangerous Goods Safety Adviser, holds a NEBOSH diploma, and is a trained lead auditor across quality, environmental, and health and safety standards. Through her businesses, she helps distributors stay safe, compliant, and resilient – offering practical tools, expert advice, and trusted accreditation support.
Viki launched Hazkit Ltd in 2023 to meet a need for pre-qualified clothing, equipment and expert support tailored to high-risk sectors like fuel distribution.
Since then, Hazkit has grown quickly, adding two specialist divisions: N90 Consultants, offering health, safety, and environmental advice, and Help With ISO, which supports companies with ISO certification and compliance.
Image credit: Hazkit Ltd
