Diarise a recurring obligation the day it lands, file the evidence under it as the evidence arrives, and hand the whole register to the named owner or operator who certifies it.
An obligation lands from a rule such as 40 CFR 68.79, and it enters the register with an owner.
02
A deadline recurs whether anybody is watching or not, so the clock runs off the rule, not the diary.
Reason
03
A five-year revalidation falls due under 68.67(f), and the evidence is checked before the date.
04
A change forces a revised hazard analysis, and 68.190(b)(5) sets six months from that change.
05
An incident occurs, and 68.81 starts a clock on beginning the investigation, not on finishing it.
Decide
06
An owner leaves, and each obligation filed under that name shows as unheld until somebody takes it.
07
An emergency contact changes, and 68.195(b) opens a one-month window nobody else is watching.
Out
08
An obligation lapses, and the lapse is written up as a finding rather than quietly closed out.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
Tracking, evidencing and clock-keeping belong to the agent. The certification belongs to a named owner or operator, who makes the reasonable inquiry and signs.
Example workflow
One obligation, rule to certification
AgentHuman
1Obligation identifiedRegulatory text, permit conditions, corporate standards or an existing compliance register
2Clock set from the ruleThe interval, the trigger that starts it, the next date it falls due and the owner who holds it
3Evidence assembledThe audits, revalidations, investigations and change records filed against the obligation
4Controls appliedRegister checks, evidence-age checks, owner checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is tracking, and the owner lane opens at the completeness gate.
5DecisionSplits at the completeness gate
Evidence complete
Goes to the named owner or operator.
Anything missing
Adds a process safety lead read first.
Owner review
The obligation is held with its evidence, its gaps and the date it next falls due.
Certify · Add evidence · Send to safety review
Certified — by the owner or operator▼
6Compliance records updatedOnly where write access and records policy allow it
7Outcome evaluatedClock accuracy, evidence currency, owner corrections and what review found
Corrections
Each owner correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying that a submission is true and complete.
Deciding that an obligation applies to this company.
Conducting the reasonable inquiry behind a signature.
Declaring a compliance audit adequate.
Automation boundaryAgent acts unaided
✓Set the clock from the rule that creates the duty.
✓File the evidence under the obligation it answers.
✓Show which obligations are unheld, unevidenced or overdue today.
✓Raise the next date due, and name the owner who must answer it.
Nothing is certified except by a named owner or operator, inside the agreed boundaries.
Judging whether a hazard analysis needs revising.
Accepting a declined recommendation as justified.
Telling a regulator what a record means.
Changes to the register, the clocks or the owners.
Example output
One obligation, annotated
This serves an operations team whose owner or operator has to certify under 40 CFR 68.185; below is one obligation exactly as the agent leaves it.
Obligation record · single dutyIllustrative example
Obligation
Recorded as
Interval
Evidence of record
Confidence
Held for
Compliance audit, covered process
Due, evidence incomplete
Three-year cycle
Audit report, 6 May 2026
Held uncertified
The named owner or operator
As receivedAssembled from the audit report and the change records on file, and it asserts nothing beyond them.
What the record holdsAudit reportRevalidation recordChange record
Why no certification hereCertifying after inquiry is a judgement the owner or operator makes.
ActionCertifyAdd evidenceSend to safety review
What the score decidesBelow the configured threshold the obligation gets a safety-lead read before the owner.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every obligationFrom the rule that creates it
03Evidence
Where the register sits
Horizon scanning watches instruments and the stage each has reached; this tracks the obligations you already have, the evidence filed against each and the clocks that recur.
01Approved path
The clock runs without you
A recurring duty comes round again and nothing in the stack says so, because the deadline lives in 40 CFR 68.190 and not in your calendar.
02Human review
What was checked, and not found
Checked in the current text: the 2024 accident prevention rule is in force and codified, not stayed and not vacated, its challenge sits in abeyance and the rollback is proposed only, so the 68.10 date in May 2027 stands.
04Build an evidence trail
The obligation, the evidence filed against it and the owner who holds it stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Regulatory sourceseCFR · Federal Register Permit conditions and corporate standards
Process safety recordsHazard analyses · revalidations Management-of-change and incident records
An obligation-level evidence figure can read clean while event-driven six-month clocks carry most of the corrections. Nestack reports the correction rate by obligation type, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Event-driven six-month clocks
11.8%
3.7×
Review
Newly registered obligations
8.4%
2.6×
Review
Obligations with shared owners
5.3%
1.7×
Watch
Established annual obligations
2.1%
0.7×
Normal
Bar: correction-rate lift vs. established-obligation baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a lapsed clock costs
The cycle shuts when the missed recurring deadline is a regression case. That suite is what the next obligation review is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on event-driven six-month clocks.
02Diagnose
The three-year audit that was four years old because the owner had left is worked backwards until one cause is left standing.
03Improve
Number the change; the obligations that drove it are filed beneath it.
04Verify
Nothing ships while one obligation case remains red.
05Learn
The case is kept, and the calendar rules are amended in that same commit.
Learn → DetectThe return edge. The next obligation review runs against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, obligation tracking, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Obligation-register and automation-boundary work.
02Regulatory, permit and internal sources.
03Rule-to-obligation and clock-derivation mapping.
04Obligation and evidence ingestion.
05Clock, evidence and owner binding.
06Completeness scoring and review routing.
07Owner certification workflow.
08EHS-system integration.
09Obligation and evidence cases.
10Guardrails and attestation controls.
11Obligation-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne register, one siteProductionProduction compliance workflowAdvancedMultiple sites / regimes
Introduced at Pilot
Obligation tracking to your register✓✓✓
Named owner certification✓✓✓
Obligation-register baseline✓✓✓
Introduced at Production
Reporting by obligation—✓✓
Owner review workflow in your systems—✓✓
Approved write-back—✓✓
Obligation-source integration—✓✓
Introduced at Advanced
Multi-regime obligation sets——✓
Cross-site evidence packs——✓
Large obligation registers——✓
Multi-regime calendar controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, register size, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your live obligations and the rule each one comes from→Obligation capture and clock derivationWeek 1
02Representative audits, revalidations and change records→Evidence binding, clock logic and the register baselineWeek 2
03Your compliance calendar and the owners it names→Obligation mapping, clock derivation and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Regulatory, permit and record-store assessment, then integration setupWeek 2
05Registers you would not want inspected→Deadline cases and failure-mode testingWeek 4
06What no obligation register may certify→Completeness scoring, review routing, guardrails and release controlsWeek 3
07A named owner or operator who certifies→Release to the named owner, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Each band is as wide as its phase costs, so week five carries a pair rather than an empty column.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Obligation discovery, clock derivation and the automation boundaryW2Source integration and the obligation-register baselineW3Evidence binding, completeness logic and release controlsW4Evaluation suite, deadline cases and failure-mode testingW5EHS-system integration, pilot obligations and targeted correctionsW6One audit cycle run under the accountable owner, then Agent Care handover
Reading the bandEach bar covers only the weeks its own work is named for, and week five is shared by design.
At the end of W6When the evidence record validates, Agent Care assumes the agent.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Operations AI agent
Build a compliance obligation agent around the clocks that recur without anybody starting them.
Show us one recurring obligation and the evidence filed against it since it last came round. The owner or operator signs, on knowledge, information, and belief formed after reasonable inquiry, and the agent keeps the register that inquiry is run against.
