Accident and Incident Reporting SOP

Purpose

Establish the consistent procedure for documenting, reporting, investigating, and following up on workplace accidents and incidents. The SOP exists for three reasons: (1) federal and state law require specific reporting for certain incidents; (2) accurate documentation protects the business in workers' comp and litigation; (3) investigation of each event prevents recurrence.

Scope

Applies to all employees, contractors performing work on behalf of the company, and any incident on a job site or in company facilities involving:

• Employee injury or illness (regardless of severity)
• Property damage to customer, third-party, or company property
• Vehicle accidents involving company vehicles or employees on company business
• Near-miss events (close calls that could have resulted in injury or damage)
• Safety-related complaints from employees or customers

Customer-side incidents not involving company employees or operations are handled under separate customer service procedures.

Roles and responsibilities

Categories and reporting requirements

Category 1: Catastrophic or fatal injury

OSHA-mandated reporting:

• Fatality: report to OSHA within 8 hours (29 CFR §1904.39).
• In-patient hospitalization, amputation, or loss of an eye: report to OSHA within 24 hours.
• Report by phone (1-800-321-OSHA) or online OSHA reporting form.

For DOT-regulated incidents involving commercial vehicles:

• Specific reporting per 49 CFR Part 390 / 392.
• Post-accident drug and alcohol testing per 49 CFR Part 382 within prescribed windows.

State workers' comp boards usually require notification within 72 hours for serious injuries.

Category 2: Recordable injury or illness

OSHA Recordkeeping requirements (29 CFR Part 1904):

• Document on OSHA Form 300 (Log of Work-Related Injuries and Illnesses).
• Complete OSHA Form 301 (Injury and Illness Incident Report) within 7 days.
• Post OSHA Form 300A summary annually (February 1 - April 30).
• Submit Form 300A electronically annually for covered employers.

Recordable means:

• Days away from work.
• Restricted work or job transfer.
• Medical treatment beyond first aid.
• Loss of consciousness.
• Significant injury or illness diagnosed by a physician.

First-aid-only incidents (small cuts, sprains treated by RICE, etc.) generally don't require OSHA recording but should be documented internally.

Category 3: Vehicle accident

Procedure:

1. Ensure scene safety; call 911 for injuries.
2. Notify police; obtain police report.
3. Photograph the scene, vehicles, damage.
4. Exchange information with other parties (per state law).
5. Notify the company immediately.
6. File with insurance carrier within carrier-required window (typically 24-72 hours).
7. Internal accident investigation form completed.

A vehicle accident with bodily injury may also be a recordable injury and require OSHA reporting.

Category 4: Property damage to customer

Procedure:

1. Technician notifies dispatch / service manager immediately.
2. Photograph damage thoroughly.
3. Honest acknowledgment to customer; commitment to remediation.
4. Internal incident report completed.
5. Notify general liability carrier if damage above the policy notification threshold.
6. Owner reviews and approves remediation plan.

See Customer Trust After Mistake reference for the customer-relationship component.

Category 5: Near-miss

Events where injury or damage did not occur but could have. Examples:

• A tool dropped from a ladder; no one below.
• An electrical short discovered before energizing.
• A pedestrian who walked into a work zone but stepped back.
• A vehicle accident narrowly avoided.

Near-misses are not legally required to be reported but are the most valuable data for prevention. A company that documents near-misses well rarely has serious accidents.

Category 6: Safety complaint

An employee or customer raises a safety concern. Procedure:

1. Document the complaint with date, person, specific concern.
2. Investigate within 48 hours.
3. Document findings.
4. Implement corrective action if warranted.
5. Communicate back to the person who raised the concern.

Retaliation against an employee who raises a safety concern is prohibited under OSHA Section 11(c) and exposes the company to significant penalties.

Procedure

Step 1: Immediate response

For an injury accident:

• Render first aid; call 911 if serious.
• Secure the scene; prevent additional injuries.
• Move equipment that's creating hazard (only if safe to do so).
• Don't move accident victims unless their position creates additional risk.
• Notify supervisor / service manager.

For a property damage event:

• Stop work that could create additional damage.
• Document the scene before disturbing anything.
• Notify supervisor / service manager.

For a vehicle accident:

• Move to safety if possible.
• Call 911 for injuries.
• Wait for police if required by state.
• Notify supervisor / dispatch.

Step 2: Documentation at the scene

While at the scene:

• Photographs from multiple angles.
• Video where useful.
• Witness names and contact information.
• Time, weather, lighting conditions.
• Equipment involved.
• Conditions that contributed (lighting, weather, fatigue, etc.).

The standard accident report form should capture all of this. A form filled in days later from memory is worth a fraction of one filled in at the scene.

Step 3: Notification chain

Within 1 hour:

• Affected employee → supervisor.
• Supervisor → service manager.
• Service manager → owner.

Within 24 hours:

• Owner → insurance carrier (if applicable).
• Owner → counsel (if litigation potential).
• Service manager → workers' comp carrier (if injured employee).

Within OSHA deadlines:

• Fatality: 8 hours.
• Hospitalization, amputation, eye loss: 24 hours.

Step 4: Investigation

References

• 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses.
• 29 CFR §1904.39 - Reporting fatalities and hospitalizations to OSHA.
• 29 CFR §1904.33 - Records retention.
• OSHA Section 11(c) anti-retaliation, 29 USC §660(c).
• 49 CFR Part 382 - DOT post-accident testing.
• 49 CFR Part 390 - Federal motor carrier reporting.
• State workers' compensation reporting requirements (varies).
• OSHA Publication 3169 - Recordkeeping in the Construction Industry.
• Manuall internal: Drug and Alcohol Testing Program, Handling Emergencies After Hours, Documenting Service for Insurance.