Facilities AI agent · OSHA recordkeeping
EHS Incident Recordkeeping AI Agent
Stage every reported injury beside the criteria it was read against under 29 CFR 1904.7, run both § 1904.39 clocks, and hold the annual summary a company executive certifies.
- Typical delivery
- 4–6 weeks
- Deployment
- Your stack
- One certifier
- Two clocks
- After launch
- Agent Care
What this agent does
Assembles the case file, never the certification
In
- 01
An injury is reported, and § 1904.29(b)(3) allows seven calendar days to enter it.
- 02
A treatment is given, and § 1904.7(b)(5) closes the list of what counts as first aid.
Reason
- 03
A worker comes off routine duties, and § 1904.7(b)(4) makes that restricted work.
- 04
A death is learned of, and § 1904.39(a)(1) leaves eight hours to tell OSHA.
- 05
An amputation is learned of, and § 1904.39(a)(2) leaves twenty-four hours.
Decide
- 06
A case meets the closed list at § 1904.29(b)(7), and the name leaves the log.
- 07
A calendar year shuts, and § 1904.41(c) sets 2 March for the electronic filing.
Out
- 08
A summary goes up 1 February, and § 1904.32(b)(6) holds it there until 30 April.
- 09
Execute write actions only inside the approval boundaries agreed during implementation.
Product statement
The agent assembles the cases and runs the clocks. A company executive drawn from the § 1904.32(b)(4) list certifies the annual summary.
Example workflow
One case, report to certification
- 1Case evidence receivedIncident reports, treatment records, restriction notes or absence feeds
- 2Case context assembledThe injury, the establishment it happened at, the criteria it answers to and the day it was learned of
- 3Recordability evidence draftedThe case, the tests it was read against, the day counts and completeness
- 4Controls appliedWork-relatedness checks, first-aid checks, day-count 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 assembling, and the safety lane opens at the completeness gate.
Goes to the certifying executive to approve.
Adds a safety manager read first.
Safety review
The case is held with its criteria, its day counts and the establishment it sits at.
Certify · Append evidence · Send to safety review
Certified — by a company executive
- 6Log and case records updatedOnly where write access and records policy allow it
- 7Outcome evaluatedRecordability accuracy, clock coverage, reviewer corrections and what the read found
Corrections
Each safety correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required
8 items
- Certifying the annual summary under § 1904.32(b)(3).
- Deciding that a reported case is not recordable.
- Making the § 1904.39 report to OSHA.
- Choosing which executive may sign.
Automation boundary
Agent acts unaided
- ✓Assemble a case beside the § 1904.7 criteria used.
- ✓Run the seven-day entry clock from the day a report.
- ✓Track both § 1904.39 clocks from the hour the employer learns.
- ✓Hold the establishment roster that decides which forms are owed.
Nothing is certified or reported except by a named person, inside the agreed boundaries.
- Judging whether a case is work-related.
- Telling OSHA the log is complete.
- Setting the restriction a clinician recommends.
- Changes to the log, the summary or the roster.
Example output
One case, annotated
Our construction safety compliance copilot works safe work method statements for a duty-holder; this record is what one injury carried onto the log.
Log entry · single case
Illustrative example- Case
- Restricted work, § 1904.7(b)(4)
- Recorded as
- Read against the general recording criteria
- Test
- Restricted work
- Evidence of record
- Incident report, 3 August 2026
- Confidence
- Held uncertified
- Held for
- The certifying executive, by name
As received
Taken from the incident report and the treatment record — it reaches as far as those sources do.
What the record holds
- Incident report
- Treatment record
- Restriction note
Why no certification here
Whether a case is recordable is a § 1904.7 judgement, not a model output.
What the score decides
Below the configured threshold a case picks up a safety read before the executive sees it.
Action
CertifyAppend evidenceSend to safety reviewValue
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value lands
Value 01 – 04
Every case
From the site that reports it
Where the evidence is used
An injury log is not a safety programme: this page records what happened and holds the file, and it makes no claim about whether the hazard was ever controlled.
Recordable is a judgement
Recordability is settled against the general recording criteria of § 1904.7, and the agent supplies the rationale rather than the answer.
What was checked, and not found
An eCFR banner reporting a 2026 amendment to part 1904 could not be matched to any Federal Register document, the standing of § 1904.12 was left unresolved, the text of directive CPL 02-00-172 was not read, no State Plan variation under § 1904.37 was surveyed, and no injury-rate or recordkeeping-cost figure was confirmed from a primary source.
Build an evidence trail
The injury, the test it was read against and the executive who certified stay on the log.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Incident and report sources
- Report forms
- hotline
- Supervisor incident reports
Occupational health
- Clinic records
- case notes
- Treatment and restriction records
People and establishments
- HR system
- roster feed
- Hours and headcount records
Agent
EHS incident recordkeeping
- Reads the cases
- Assembles the log
- Holds for the executive
Case and records systems
- EHS platform
- ticketing
- Log, summary and retention records
Observability & evaluation
- OpenTelemetry
- Langfuse
- Supported monitoring/evaluation sources
Integration availability depends on the client's existing systems and API access.
Agent controls
Six locks between the model and the executive
Six locks turned in order, the last one stiffest. Whatever opens them all is drawn in the map below.
L6 · Outermost — last line of defence
Inward → L1 · closest to the model
- L1 – L2
- Test whether a case may stand
- L3
- Puts the certification in a person's hands
- L4 – L5
- Keep the injury and the test behind it
- L6
- Holds the summary uncertified when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the log entry that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the summary an inspector reads
- E1Final-output evaluationDid the entry record what the case actually was?
- E2Step-level evaluationDid the agent read the right case, the right criteria and the live roster?
- E3Tool evaluationDid it read and write the correct case record and the correct log?
- E4Confidence calibrationDo low-confidence cases actually attract more safety corrections?
- E5Slice evaluationHow does performance change across specific establishment types?
- E6Business outcomeHow many cases needed a correction before the executive certified?
Floor — the log the employer answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each fixed at the stage where it first surfaces.
Agent lifecycle
Direction of processing →
01 · Retrieval
1 mode
- KR-03
Stale roster read
The headcount read is not the one now on site.
Stage gathers
The cases, the tests, the dates and the roster
02 · Reasoning
2 modes
- KR-04
Recordability called early
A case is logged before the criteria are met.
- KR-06
First aid read as treatment
Care on the closed list is worked as recordable.
Stage proposes
The cases, their tests and completeness
03 · Tool / write
2 modes
- KR-02
Thin case passed forward
A case moves on without the safety read.
- KR-05
Bound to the wrong establishment
An injury is filed against the wrong site.
Stage writes
Only where write access and approval policy allow it
04 · Output
1 mode
- KR-01
Certified, evidence unrecorded
The record shows a certification but not what supported it.
Stage returns
The summary an executive certifies and OSHA reads
05 · Change / Version
1 mode
- KR-07
Silent clock regression
A configuration change moves the clock, not the case.
Stage tracks
Model, prompt, recording rules and log fields
- Sev-1 · a fatality report past eight hours
- Sev-2 · wrong evidence reaches the log
- Sev-3 · source degrades, case held uncertified
Affected slices
Warehouse sites absorb the corrections
An establishment-level recordability figure can read clean while warehouse and distribution sites carry most of the rework. Nestack reports the correction rate by establishment type, not only in total.
Slice performance — reported separately, not only in aggregate
Illustrative example| Slice | Failure rate | Lift | Lift vs. threshold | Status |
|---|---|---|---|---|
| Warehouse and distribution sites | 7.5% | 3.6× | Review | |
| Manufacturing establishments | 5.4% | 2.6× | Review | |
| Field and service establishments | 3.3% | 1.6× | Watch | |
| Office establishments | 1.8% | 0.9× | Normal |
Bar: correction-rate lift vs. office establishment baseline · scale 0–4.0× · tick marks the 2.0× review threshold
2 of 4 slices over threshold
Evidence-linked improvement
What a missed case costs
A cycle shuts when the late fatality report is a regression case. That suite is what the next case logged is measured against.
Improvement cycle · five stages
Switchback — the path turns at Improve and returns at Learn
- 01
Detect
Correction rate rises on warehouse and distribution sites.
- 02
Diagnose
The strain that was first aid on Friday and restricted duty on Monday is read back until one cause remains.
- 03
Improve
The change ships numbered, and the cases that forced it ride with it.
- 04
Verify
Nothing releases while one touched case entry is still red.
- 05
Learn
It is retained for good, and the recording rules are amended in that same commit.
Learn → Detect
The return edge. The next log is measured 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, case assembly, evaluation, integration, then production validation and handover.
Workstream
Week 1Week 2Week 3Week 4Week 5Week 6
- 01Recordability-criteria and automation-boundary work.Week 1
- 02Incident, treatment and roster sources.Week 1, Week 2
- 03Case-to-criteria and clock-coverage rule mapping.Week 1, Week 2
- 04Case and treatment ingestion.Week 2
- 05Case, criteria and record binding.Week 2, Week 3
- 06Completeness scoring and review routing.Week 3
- 07Executive certification workflow.Week 3, Week 4
- 08Occupational-health system integration.Week 5
- 09Recordability and clock cases.Week 4, Week 5
- 10Guardrails and executive controls.Week 4
- 11Case-trail instrumentation.Week 5, Week 6
- 12Deployment, documentation and Agent Care handover.Week 6
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel
Final 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 tier | PilotOne establishment, one year | ProductionProduction recordkeeping workflow | AdvancedMultiple sites / entities |
|---|---|---|---|
| Introduced at Pilot | |||
| Case assembly to your criteria | ✓ | ✓ | ✓ |
| Certifying executive release | ✓ | ✓ | ✓ |
| Establishment-roster baseline | ✓ | ✓ | ✓ |
| Introduced at Production | |||
| Reporting by establishment | — | ✓ | ✓ |
| Certification workflow in your systems | — | ✓ | ✓ |
| Approved write-back | — | ✓ | ✓ |
| Occupational-health integration | — | ✓ | ✓ |
| Introduced at Advanced | |||
| Multi-site rosters | — | — | ✓ |
| Cross-year evidence packs | — | — | ✓ |
| Large case loads | — | — | ✓ |
| Multi-clock notification controls | — | — | ✓ |
| Build price | From $5,000 | From $8,000 | Custom quote |
- Final build price
- Confirmed after discovery based on integrations, workflow complexity, case volume, approval controls and deployment requirements.
- Separate from build
- Build 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 bring
We build with it
01Your establishments and the roster behind each one
→Establishment mapping and case capture
Week 102Representative incident, treatment and restriction records
→Record binding, criteria logic and the log baseline
Week 203Your reporting procedure under § 1904.35(b)(1)(i)
→Criteria mapping, clock binding and the automation boundary
Week 104Access to relevant APIs, feeds or exports
→Incident, health and roster-source assessment, then integration setup
Week 205Logs you would not want certified
→Recordability cases and failure testing
Week 406What no injury log may establish
→Completeness scoring, review routing, guardrails and release controls
Week 307A company executive who satisfies § 1904.32(b)(4)
→Certification workflow, then pilot and production validation
Weeks 5–6
Nothing else is required
Deployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Each width is the time a phase honestly takes and not a layout choice, so week five holds a pair.
Phase
W1
W2
W3
W4
W5
W6
- DiscoveryW1
- BuildW2 – W3
- EvaluateW4 – W5
- Pilot & LaunchW5 – W6
Week focus
W1EHS workflow discovery, criteria mapping and the automation boundary
W2Source integration and the recordability baseline
W3Case assembly, clock logic and release controls
W4Evaluation suite, recordability cases and failure-mode testing
W5Health-record integration, pilot cases and targeted corrections
W6One recordkeeping year run under the certifying executive, then Agent Care handover
- Reading the band
- Each bar covers only the weeks its own work is named for. The fifth carries a pair because the work does.
- At the end of W6
- Validation closes on live logs, and Agent Care picks up the watch.
- Duration
- Six-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Facilities AI agent
Build a recordkeeping agent around the case that changes character between Friday and Monday.
Show us one case and the criteria it was read against. Only § 1904.32(b)(4) says who may certify: an owner, an officer of the corporation, the highest-ranking official at that establishment, or that official's immediate supervisor.
- Typical delivery
- 4–6 weeks
- Deployment
- Your establishments
- One certifier
- Two clocks
- After launch
- Agent Care available
Nestack Agents · OSHA recordkeeping
AGT-AF-09 · Agent Care available after launch