While many issues in the Domino's case remain in dispute, nearly everyone agrees on one point: a significant number of Domino's drivers have been in accidents.

Kenneth R. Behrend, a Pittsburgh lawyer suing Domino's on behalf of a husband and wife whose car was hit by a Domino's truck in 1985, said he knew of at least 60 such accidents in which someone was seriously injured or died.

Joseph A. Kinney, the director of the safe workplace institute, has calculated Domino's employee death rate at 50 per 100,000. He said the rate is as high as in mining and higher than the 30 deaths per 100,000 workers in the construction industry. 20 Deaths Last Year Last year alone, Mr. Kinney said, 20 people died in accidents involving Domino's drivers, a figure Domino's confirms. The company has fought requests in lawsuits to disclose how many drivers have been killed in previous years.

But the two sides differ over what is causing the accidents. Domino's cites a broad range of reasons -from bad weather to falling asleep at the wheel - and says the 30-minute policy is not to blame.

Domino's says that the guarantee policy, which is two and a half years old, has helped the company, which is privately held and based in Ann Arbor, Mich., grow from a regional chain to one of the largest fast-food enterprises in the world, with more than 5,000 outlets and systemwide sales exceeding $2 billion annually. The chain's success has made Mr. Monaghan an extremely wealthy man, with a net worth estimated by Forbes magazine at $400 million.

The only chain larger than Domino's, Pizza Hut, with $3.2 billion in sales, offers a 30-minute guarantee in only a few markets, usually those in rural areas without much traffic. Godfather's Pizza Inc., another chain, has abandoned its 30-minute guarantee, contending that it was not safe. Negative Publicity Cited

Indeed, other large chains ''have shied away from the 30-minute rule,'' said Amy Lorton, editor of Pizza Today, the industry's trade journal. ''They don't want to get caught up in all the negative publicity.''