The Postal Service is required by 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses, to use the following to record occupational injuries and illnesses:
- OSHA Form 300, Log of Work-Related Injuries and Illnesses;
- OSHA Form 300A, Summary of Work-Related Injuries and Illnesses; and
- OSHA Form 301, Injury and Illness Incident Report; or
- Equivalent forms.
The Postal Service uses an accident reporting process — the Employee Health and Safety system (EHS) — to fulfill these requirements. The PS Form 1769/301, Accident Report, generated by EHS is equivalent to the OSHA Form 301.
The manager or supervisor of the employee or operation involved must:
- Report all accidents and occupational injuries and illnesses in the Employee Health and Safety (EHS) within 24 hours of the date of the accident, the diagnosis of injury or illness, or the notification of the manager of the situation.
- Provide a copy of PS Form 1769/301, Accident Report, generated from EHS, to the employee involved upon written request.
Completion of the report in EHS is required by Postal Service policy if an accident occurs and by the OSH Act if an occupational injury or illness that is recordable by OSHA definition occurs, regardless of tort claim action or the requirements of the Federal Employees’ Compensation Act.
In accordance with OSHA Part 1904, OSHA Form 301 must be completed for each recordable injury or illness. The PS Form 1769/301, Accident Report, must be maintained along with the OSHA 300 Log for 5 years.
An accident report must be entered into EHS by the supervisor when any one of the following occurs:
- Injury or illness of a Postal Service employee. The appropriate OSHA recordable indicator and Postal Service reportable status are automatically identified in the EHS system, which uses OSHA recordkeeping guidelines to determine OSHA recordability, and follows guidelines for Postal Service requirements.
- Death of a Postal Service employee on Postal Service premises or on the job. U.S. Department of Labor Form CA-5, Claim for Compensation by Widow, Widower, and/or Children, or CA-6, Official Superior’s Report of Employee’s Death, is generated from EHS and submitted to the Office of Workers’ Compensation Programs (OWCP).
- Injury or fatality to a non-Postal Service person on Postal Service premises. Unless a contractor is involved, this is not an OSHA-recordable event (see OSHA Parts 1904.25, 1904.39-41, and 1904.43-44).
- Motor vehicle accident that results in death, injury, or property damage, regardless of cost, who was injured (if anyone), or what property was damaged.
- Damage to Postal Service property or to property of customers or the general public, regardless of whether an injury was involved.
- Fire damage to Postal Service property.
The manager or supervisor of the employee or operation reports all accidents and occupational injuries and illnesses in EHS within 24 hours.
Managers and supervisors of the employee or operation are responsible for quickly and accurately investigating all accidents and occupational injuries and illnesses to determine root causes, and they are responsible for completing the accident report in EHS.
Review is conducted as follows:
- The supervisor’s immediate manager must review each PS Form 1769/301, Accident Report, for accuracy and its application (including OSHA recording status), and follow up to ensure that action is taken to prevent similar occurrences.
- The installation head (or designee) must review the report to see if positive action has been taken or is planned.
- Servicing safety personnel must ensure that accident causes are identified, that the action taken is appropriate, and complete the necessary actions in the back end of EHS.
Correct erroneously recorded data by submitting a new, correct version of the accident report into EHS.
The District Safety must be contacted if corrections to an accident report are necessary.
In accordance with 29 CFR 1904, each facility must maintain an OSHA 300 log by calendar year that lists all OSHA–recordable occupational injuries and illnesses. All such injuries and illnesses must be recorded and maintained in the Employee Health and Safety (EHS) system for inclusion on the automated OSHA 300 log.
Print a copy of the OSHA Form 300A from EHS, and post it for the period of February 1 through April 30 each year in a conspicuous place at every establishment where employees work or report to work.
OSHA Form 301 must be filled out for each OSHA-recordable, work-related illness or injury within 7 days of notification (see 821.122). PS Form 1769/301, generated by EHS, is equivalent to OSHA Form 301.
Retain OSHA Forms 300, 300A, and PS Form 1769/301 for 5 years after the end of the calendar year. These forms are all available for 5 years in the EHS system.
Managers and supervisors are responsible for investigating all accidents promptly, determining their causes, and reporting them accurately in accordance with OSHA and Postal Service regulations. Management should consult with safety personnel when accident causes cannot be readily determined.
To have first-hand knowledge of every accident that occurs in their operation, supervisors must make thorough investigations that include at least the following:
- Interview employees to determine:
- What caused the accident,
- Why it happened, and
- What the employees and supervisor think could have been done to prevent it.
- Promptly inspect the accident site to determine what conditions (such as equipment and work practices) contributed to the accident.
- Interview witnesses and coworkers.
- Examine the most recent PS Form 1783, On-the-Job Safety Review/Analysis, for the task involved to determine if changes are required. Update as needed and review with all affected employees. If a PS Form 1783 is not on file, determine if one is necessary. If so, prepare one. See the Safety Resources page on Blue for assistance in completing a PS Form 1783.
Accident analysis is vital for identifying the hazardous conditions, contributing factors, and root causes of accidents.
Installation heads/managers must use the results of accident analyses to address the causes of accidents, develop specific actions (countermeasures), and enter them into an accident reduction plan (ARP) (see 812.31). The ARP serves as management’s primary tool for reducing OSHA injury and illness (OSHA II) and motor vehicle accident (MVA) rates.
The process of conducting an accident analysis includes, but is not limited to, investigating the following key factors:
- Specific tasks being performed at the time of the accident or injury.
- Operations, equipment, tools, and machinery involved.
- Specific event that resulted in the accident or injury.
- Nature and severity of the injury.
- Part(s) of the body involved.
- Incidence and nature of the following:
- Faulty equipment or design.
- Unsafe condition(s).
- Unsafe acts or practices.
- Violation of rules, procedures, or instructions.
- Inadequate training or lack of safety rules or procedures.
Accident records, including the left side of the OSHA log and summary, contain information about individuals. Therefore, they must be handled and disclosed in accordance with the Privacy Act and implementing instructions.
An individual’s accident records and related correspondence are maintained by the Postal Service as the privacy system entitled Postal Service 120.035, Personnel Records — Employee Accident Records.
