From Fear to Foresight: Transforming Safety Culture

Hilary Framke: Happy Friday to our listeners. I’m Hilary Framke, your host. I’m here for another episode of the Elevate EHS podcast. Thank you so much for listening in. I’ve got Rogelio Cuellar here with me.

Rogelio Cuellar: Hey, Hilary.

Hilary Framke: How are you, Rogelio?

Rogelio Cuellar: Great as usual. Friday is great as well.

Hilary Framke: It’s a fantastic time to sit and just talk about thought leadership on EHS, isn’t it?

Rogelio Cuellar: It’s always a great time, but Friday is better, for sure.

Hilary Framke: Fantastic. Let’s get into it. In our prep call, I got to learn a lot about Rogelio. One of the things that stood out to me that he said, was early in his life, he was a Boy Scout. So Rogelio, tell our listeners a little bit about how your early experiences as a Boy Scout led you to EHS.

What lessons do you still carry from the Boy Scout organization that you still reference in your career today?

Rogelio Cuellar: Thank you, Hilary. I believe that was the actual trigger for my career because just going outside, outdoors with a lot of kids, a lot of people just camping or swimming or doing any sort of outdoor activities led me to identify that we need to have a decent level of protection to our people. We’re always exposed to hazards in the forest, in the lake, in the river. So we love to go outside for activities so the need to protect our team members, our Boy Scouts probably was the trigger for my interest on this EHS universe. If I need to select a couple of takeaways from my early years in scouting, I should say that what I learned the most is the service mindset to help others.

It’s the mindset of scouting. And the second one is respect and care of others. I believe this is totally connected to the service mindset as well. I believe that all the values and these two specific items modify my personal and professional profile. So now to your question.

So what I’m still using from my scouting life today in my EHS career, probably, protect the people. This is my personal mantra as a safety professional, protect the people. Second one, because all these values that we embed, learn and live is do always the right thing. So protect the people, do always the right thing.

And this is not from scouting. This is the universe law, but treat others in the same way that you want to be treated. And when you’re a safety professionals, this statement has a different meaning because you’re thinking, imagine that your son is going to be using that machine. So how you want your son to be protected by operating that machine, operating that process.

So it’s a different meaning of the same statement, but it’s the same. So how you want to be treated, how you want your son, your daughter, your family member be treated from the organization perspective, from the protection perspective. I think that’s a key and probably the most fun one is enjoy the journey.

So as a scout, you always go outside, go for camping. But the journey, singing songs, joking with friends, just walking long, long distances to arrive to the right spot, is part of the fun. So for safety, it’s the same. Enjoy the journey. Safety is an endless journey. There’s always something else to do. So let’s enjoy it.

Hilary Framke: I just think that’s so great. It’s such a refreshing viewpoint on EHS. Okay, let’s shift gears a little bit. So obviously, Rogelio you bring a diverse cultural background. You’re not from the US originally. Tell us a little bit about your experiences in that. I just find that this diverse viewpoint starting in a different country and then moving up into regional management, global management gives you such a unique perspective on EHS. So tell our listeners some more about that.

Rogelio Cuellar: Yeah, thank you, Hilary. So I arrived to the United States like six years ago, 2018. However, I’m from Mexico. Probably a couple of years before to move from Mexico to US I was really lucky to have the opportunity to travel worldwide to understand different type of cultures besides the Latin cultures and the US based cultures. I was able to understand Asian cultures and European culture regarding safety. So I believe that was the most enriching experience in my career, because now to your point, I was able to identify similarities and differences and work accordingly to creating the standards and stuff. So in my experience, I’m just talking about US And Mexico, one of the technically speaking, regulatory aspects are very similar. So EPA or environmental regulations in Mexico, OSHA or safety regulation in Mexico aren’t really aligned. There’s a couple of regulations that are more robust in US. Some others in Mexico. But those are very aligned.

However, one of the most relevant and important differences are regarding the record keeping standards. So the way that OSHA standards are defined for record keeping is totally different than Mexico and other countries outside of the US. It’s totally different. So the way to record accidents is, as I mentioned, totally different.

And this can be frustrating for the US. based employees, because when you start to compare same global, regional or world companies, the rates and numbers from US operations versus Mexico or other locations, you see a huge difference, like three, four, five times the amount of cases.

And for the US based people, it’s frustrating. Hey, we’re making our biggest efforts. We’re implementing all the controls. We’re following the standards. And we still see have five times the amount of cases than other countries. So going deeper, we need to understand that regulatory is the trigger for these differences.

Lost time incidents are managed totally different around the globe. The prescription medication, for example, is totally different in the rest of the world and US. So in my career experience, two different ways to do this. One was, if this is a US company work company, but based in US, we try to standardize the criteria for the rest of the organization.

However, we understand that for other countries, this is still a regulatory aspect. So for example, in Mexico, so when we needed to move to OSHA standards, Mexico locations, they needed to create two reports. One, the internal company standard, and they need to keep reporting the official regulatory ones. So it’s complicated for the organization, for those organizations outside of the US manage double reports. So the other way to manage these, which is probably not ideal, but it is based on what you have, just follow your standards and understanding differences. So our internal company standards are the same. So we follow those. But understanding the difference for record keeping standard should remain in place and you need to eat it and just live with that. So that’s the thing, right?

Hilary Framke: This is such an interesting topic, Rogelio. The first time, obviously, once you go into regional management that has more than one country of origin, you start to have these conversations, and you look at your metrics as a regional manager, you’re reporting up to your director, and you’re going, Oh, boy, these aren’t the same, though. We don’t have the same standards. I like your former statement, right? The one about actually taking a look at the regional differences and setting a standard for how you’re going to report things internally to the business versus regulatory to your country of origin, right?

And and I think those can be two different things. We absolutely need to always record in the way that the country of origin requires us, right? That absolutely 100 percent has to happen. But just because it’s a recordable in the same injury type region to region does vary.

And it is really important that we evaluate it and we look at the severity of the injury. So what we always did is we took a look at what is the severity of the injury? What were the actual investigative factors? What were they prescribed for treatment? Was the treatment directly linked to the injury of note?

The doctor make a diagnosis. And connect that treatment, to the injury of note. And then if there is restricted time or lost time assigned, again, does that seem to make sense based on the severity of injury? So almost to put together, in previous employers I was at, we had this little board of people, right?

Directors and the different business units. Who would get together and evaluate, ones that were on the bubble. If we were unsure if we should record it or not, and they would present the case with all the details to this board. And this board would make a decision, based on historical incidents from that region.

How would we treat it? And that’s a good practice to have, to hold yourself accountable. I do think that there’s, because of the significant differences between the regions, it can get very competitive between the regions. Especially in the US because the recording criteria is so specific. They feel like we’re always eating recordables, but they never have to. And it seems like I have a lot, but I don’t, that sort of thing.

Rogelio Cuellar: Yeah, I agree with you. This is the right thing to do. However, it’s not a simple task because you trying to modify all what they know since the beginning of their careers outside of the US. And for them, it’s double task. They need to comply with the internal standards and also the regulatory standards. And this could be complicated because, for example, in a couple of countries in Europe they don’t have the recordable concept.

They have first aids or with more than 30 days lost time or less than 30 days lost time. In Asia, for example, those times start to come after three days, for example, of time off. So it’s a huge management of change process that will require knowing the culture, knowing the people outside of the United States to understand what’s the trigger for those people to manage the change. Adopting both the standards for those countries, right?

Hilary Framke: Exactly. And, speaking of Europe, and some of the differences with the health systems and how they look at treatment we always used to joke around with our European colleagues that, employees get two weeks off for a stubbed toe. I stubbed my toe at work and now I have two weeks off work if I go to the doctor, so it’s those situations where I think it is important to have a standard, for the reason that one, our investigation, our resources, our work and incident management, it can give us an inaccurate picture when we’re counting so many days over an injury that isn’t severe.

That isn’t something that we should, is a SIF or a PSIF that we should be focusing our attention on. So if we can find a way to create an internal process that gives us this barrier of after this, then, it is recorded and those are the ones we take a look at. It helps us to make sure that we’re chasing the right things.

Rogelio Cuellar: I agree. I totally agree with you.

Hilary Framke: What about the differences, Rogelio, in risk management? Tell me about that application.

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Hilary Framke: Rogelio, if you could pick one EHS program that you feel is the key to success in the field, what would it be and why?

Rogelio Cuellar: There’s no questions. I believe that risk management is not just risk assessment. Risk management is the only way to reach zero.

So we have multiple programs, multiple standards, controls. But I am a believer that risk management is the only way to achieve zero incidents. And when I talk about risk management, there’s some steps or a cycle I call the risk assessment cycle, risk management cycle, which includes the hazard identification, the risk evaluation, the implementation of control measures, the verification of the effectiveness of those control measures, and then reevaluation of the risk to verify the risk reduction.

This is not rocket science. I’m not reinventing the wheel. This is the step zero or the basic task for safety professionals. However, what I learn from my career is that the very first step on this risk management process, which is a hazard recognition. Most of the safety professionals take it as granted.

So we deploy tools to the floor and say, hey let’s identify hazards. And eventually we have an incident say, hey, during the investigation. Oh, we didn’t recognize that hazard. That was not evaluating the risk assessment process. In my experience that was basically every single case that we investigate. At the same discuss somehow the same discussion about, hey hazard not identify or we didn’t notice about that.

So I believe that the key element for all these risk management process is having the proper hazard recognition or hazard identification process. Most of the times we just have a blank template, hey, let’s go there and identify what could go wrong. That’s the basic principle of the hazard identification.

And most of the times we don’t have the right level of forecasting skills to identify what can go wrong. Some of those are very simple to identify. But not all of them, so that’s why I believe that we have the proper process implemented, including the hazard identification, we can succeed and we can deliver the zero.

Hilary Framke: Rogelio, before you go on to the next step in the life cycle, because I want to walk through each of these because I feel they’re very value added for our listeners. The hazard identification piece. I could not agree more. This is something that has always set me apart. When I came into a new organization, And started out walking the floor, finding the things, being a little mini inspector. And people were always shocked at all the things that I would find. We’ve had safety consultants through, we have EHS people through no one has ever said anything about that. There’s a lot of this. And I think it’s not done enough. And we’re not using the forecasting element and the creativity element of seeing things before they occur, like really thinking outside of the box, our technical skills that are lost on our EHS professionals. I have a couple tips, I’m sure you do as well. One of the tips that I always teach my team about, have you ever heard of the movie Final Destination?

Rogelio Cuellar: Oh, yeah.

Hilary Framke: Okay, stick with me. I know it’s a little weird.

Rogelio Cuellar: It is not. I know where you’re going. Go ahead.

Hilary Framke: For those listeners who don’t know the movie franchise, look up the synopsis and you’ll see where I’m going here as I explain it.

But in the movie, they find a way. They get a premonition, they find out they’re going to die, they get a premonition, they cheat death, right? And then death comes after them for the rest of the movie, but in very unique ways. All these really odd things, the broom falls over, it hits the door, hits the knife.

Rogelio Cuellar: The candle, yeah.

Hilary Framke: It’s like a very odd acts of God situations, right? For all the pieces to come together to eventually cause a fatality, right? So I think of this, honestly, when I go out into a floor doesn’t matter what environment it is. If it’s the office, if it’s manufacturing, if it’s distribution, construction, et cetera.

I step back in one like corner of the room, and I take a big picture look, and I think of it like Final Destination. What are all of the strange, dangerous, conditions, and then the odd like act of God circumstances that could go after each other domino effect, to result in a serious incident? And that’s how I work through my hazard identification. I was recently doing a tour in a metal fabrication facility where they had the chemical dispensing right out in a section of the plant, and then behind right adjacent to the chemical dispensing section, they had all of these very large totes of metal scrap all stacked very high. And lots of forklift traffic through this production facility. And what I had said was, all I can see is an employee dispensing off the chemical and a forklift operator grabbing a tote, accidentally pushing a tote and crushing the person between the chemical dispenser, and the tote itself, because it was so high, the forklift operator couldn’t see anyone at the dispensing station.

The president was actually on the tour. I give him a lot of credit for that. He was like, whoa, never considered that as a risk. But line of sight is so imperative when you have forklift operation. And especially if it’s a workstation like this, where people are going to stand and there’s no way to recognize them.

So I’m like, yeah, we’ve got to correct that. We’ve got to find a way to get visibility or relocate this. But that’s exactly how I think is I use Final Destination to say, okay, person here, forklift here, don’t have line of sight, push it. Of course, they’re not supposed to push it, but they can, and it’s very easy to do.

And this is what businesses need from EHS people. They need them to see the future, all the different scenarios. To identify those dangerous conditions and risk factors that could lead to a loss.

Rogelio Cuellar: Yeah, I’m always using Murphy’s law, so if something can go wrong, will go wrong.

Hilary Framke: Yes.

Rogelio Cuellar: Your approach is easier to understand with Final Destination franchise, but yes, absolutely. And something that I believe is really common and triggering this type of issues is that we traditionally as a safety professionals, we try, because we’re not experts in every single portion of the productive process.

So we need to create multidisciplinary teams in the org to perform this risk assessment. Because we don’t understand every single steps for every single workstation in every single area in each facility. So we need operational stakeholders, all the people involved in the process to understand the process, materials, et cetera, et cetera.

However, we as safety professionals, we always think that risk assessment is not a tool for us. It’s a safety tool for the organization. So we are always trying to push the leaders or the operations team members to own the process and to fill the form and to actually run the risk assessment.

And we’re always around supporting, giving ideas and stuff. So I believe that’s one of the key mistakes that we just drop the form without the proper level of skills or knowledge. As safety professionals, we should have this Final Destination mindset, but if we don’t teach that, if we don’t create that expectation in our stakeholders, we cannot expect the same result from the process.

So I believe this is one of the initial mistakes that we take as safety professionals trying to create ownership from this process in our stakeholders.

Hilary Framke: Yeah, too much offloading. I Would love to hear any ideas that you have for our listeners about verification of controls. How are you going back in this risk management cycle and verifying control is effective?

Rogelio Cuellar: Sure. This is not perfect math and for sure, whatever is defined for me may not work for everyone, but what I find useful is when you implement the control, you follow the hierarchy of controls trying to go from elimination to PPE, this is the regular theory. However the key element after the implementation of controls is verifying those controls are effective.

And this means that controls remain in place because it’s really common when you place a sign or implement a new guard or new control. If that was not properly managed or was not effective enough you can come back after two weeks and that will be missed because somebody disturbed somebody activities or nobody cares about maintaining those.

So there’s several elements regarding the verification of effectiveness first. Those controls should remain in place. And second those should be effective enough to prevent the recurrency of the issue that we had at the beginning. We can talk about the incidents in this case, risk assessment.

Those controls should actually mitigate, we need to validate the mitigation or the reduction of the risk by implementing those controls. So what works for me right now is having a 90 days period or verification. So 90 days period helps me to identify if those controls actually remain in place, because for the first week nobody will touch it, but after a couple of months, the people get used to those.

So you can verify those actually are still in place are still effective and probably just talking about, I know that the question was regarding risk assessment, but talking about the incidents. If you have a repetition of incidents, that’s the key trigger that you are not implementing effective controls, right?

But moving back to risk assessment. So that’s why after the verification of the effectiveness, you need to go back and actually verify the risk reduction. And it’s complicated for risk assessment because everything is in theory. The difference between incident investigation Is because that is a reactive stuff.

So the incident already happened. So you can verify that whatever fail can be controlled for risk assessment is just forecasting the future, the Final Destination type of stuff. So you need to think what can go wrong and after you implement those controls. Are those actually remove what I saw at the beginning or not?

It’s not a simple task because everything is in your mind. Everything is just forecasting future stuff. So there is no perfect math to validate moving from severity of five to severity of one. You know what I mean? So it’s just everything based on the criteria skills and expertise of the people performing the tasks.

Basically my suggestion is give a period of time, two, three months and verify if those controls remain in place. And if those actually mitigate the risk that you identify at the beginning.

Hilary Framke: Do you know something that I always found, I feel we don’t do enough of, is in the hazard observation, all the proactive events, reporting that you have, whether that’s whatever you call it, good observations, hazard observations, right?

Near misses, that whole side of things. So before an injury has occurred. Trending that against risk types. So how many of these could have been cuts? Actually classifying the cause category, and then looking at controls and then pushing that against the risk assessment scoring that we’ve built in that category, right?

But here’s the problem. I’m shocked at how many businesses don’t do a risk profile analysis. This was something that I learned from a previous mentor that again, just. Of course you have to do, risk assessment at the task level, at the department level, job level, however you have it, but what businesses are missing is the almost a higher level, the bucket. So overall, what is our risk in hazardous waste? Overall what is our risk in air emissions in comparison to the world’s right? Other industries, et cetera. Is this the biggest thing we should be thinking about? If yes, why?

Should be based on having very extensive permitting, having lots of losses, having very hazardous emissions. And if those emissions don’t exist, and you don’t have high class air permits, and you don’t have emission overages, why is it, scored so high? So actually connecting the profile analysis then to your proactive data to say, okay if let’s say 60 percent of our near misses were related to control of hazard energy lockout tagout issues, jams, et cetera.

How do we have control of hazard energy scored as an overall risk profile for our business? How do we think we are if we’re seeing a lot of what I like to say, overflow, in the proactive program, likely our controls are not sufficient, as we have set today and those should align.

If they don’t, you need to up the scoring, the risk potential in your risk profile analysis and put some investment into bolstering your controls or go after different types.

Rogelio Cuellar: It makes sense. Yeah. Recently in my previous company, we started this, we call site level risk mapping, which is your overview considering external factors, regulatory compliance, internal standards.

And I’m trying to replicate now this as well, but yes, it makes totally sense. So this is a very high level, but it’s needed because now you’re talking, not the workstation, but workstation is just the entire organization. The exposure you have is related to business continuity, is related to regulatory compliance.

So yes, it’s relevant and you’re right. Not a lot of companies are thinking on that level.

Hilary Framke: And I think it’s important too, because it can help you, as there are always sites that have similar processes. This site has molding, this site has molding.

But they’re not the same molding, we might be doing large scale molding over here and small scale molding over here. There should show a quantitative risk exposure difference, between the two types, even though they both have molding. And gaining the perspective as a regional EHS person and a global EHS person to how the sites vary by program, right?

So to have your overall global picture, but then your site by site, like you said, site level mapping also allows you to look across right and to say if we have an incident at this location and it’s in molding these other four locations have molding so they should all be on like a little mini call and be having a conversation right about what happened at the site and to see if it’s applicable across the network and that’s what that type of assessment allows you to do.

And then again, trending against the proactive data. Very cool stuff, Rogelio, very cutting edge.

Rogelio Cuellar: Absolutely. Yeah.

Hilary Framke: So lastly going back to the previous point and more because I’m curious. How has the diverse cultural background that you have, the regulatory landscapes that you’ve seen, how has this influenced your approach to developing cohesive EHS programs?

Rogelio Cuellar: Thank you, Hilary. I believe, it’s not easy task as well because it depends on the culture of the organization, the culture of the countries, but the short answer to that is take the best of the best. That’s my thing. That’s my mindset. Again, culturally perspective, most of the times, each country thinks that they have the best of the best.

The regulatory aspects are the best that nobody can fight against that. And we are very proud of what we have and this is worldwide. So this is not US stuff, is every single one. So it’s hard to deal with. You have multiple regions, multiple countries trying to standardize, because they are doing some stuff in this level and some other countries here, but they still think that this is better.

So it’s complicated. But again, my thinking is, the best of the best. So this is a huge administrative task because you need to understand first what they have locally, regulatory aspects, internal standards as well, and start to collect, understand each piece that you have in front of you regarding countries and regions, and then try to create a matrix to compare and try to find what is the most robust or strict policy for X, Y, or Z topic and then start to create the standard.

And this is just the first step, but the management of change for that standard is complicated. It’s going to be basically what I mentioned about the record keeping process. Because eventually some of the activities they may have regionally or locally, will remain in place because those are legal requirements.

But now we have a more robust company standard. So they need to meet our standard for sure. If we meet the company standard, they will meet for sure, the regulatory aspects. That’s the intention to have the best of the best. However, sometimes it’s not easy to sell the idea that by moving to the company standard, you will meet your regulatory aspects and you will comply with your company.

It’s not simple because they think that they have the best of the best. So the management of change process for this type of change, it is a challenge, but if we do right, we can achieve a world class operations by exactly doing that. World class meaning taking the best of the world to put it in place for everyone.

So it’s not simple task. It takes years sometimes, but I think it’s the right thing to do.

Hilary Framke: Do you know what’s exciting, though, is that I think with DE&I and all that is coming out and becoming more prevalent and visible in the world about how diverse teams, inclusive teams, how equality gets us to the best result in our talent and in the things that we do. I think that this concept that you’re sharing is the same. It’s an outlook. It’s not about talent. It’s about program content. And so your idea is, the more diverse and inclusive we are about different program elements from different regions and points of view and perspectives, the better we’re going to be as an organization because we’ll have a more holistic picture, having evaluated all the different jurisdictions and saying, based on risk, this is where we have the most people. This isn’t, who has the biggest book. The smallest text. This is purely about risk exposure. Show me how that activity drives risk reduction or engagement or collaboration some benefit, that the organization is going to get. If you can’t explain how this activity, which is an administrative burden to the organization, adds value, then why are we doing it?

Now, if you have to do it for your country of origin, that’s non withstanding, that’s always going to be a thing. All of us, in the US will always have to deal with all the deep 1910 and 1926 standards. But why should we put that administrative burden on other countries outside the US, if it doesn’t add value? If it doesn’t reduce employee injuries or protect our environment, then that’s just, again, distracting. It takes us off where we should be looking, to really change the organization and grow it. So I really hope with the emergence of DE&I that this concept of diverse standardized global EHS systems will become more accepted.

Rogelio Cuellar: Yeah, the key word for this is flexibility. And usually safety professionals, we are not really flexible because again, as I mentioned, discipline and standardization is our core business. So, being flexible sometimes is not in our vocabulary. So, we need to learn to do different stuff.

Hilary Framke: Agreed. We’re all guilty of that. Myself included. Sometimes you get an idea about how you want to do things and it’s hard to break that cycle. But I think resilience is key here. So if you really feel that this is the direction we should take, and I’ve said no the first time around, don’t give up.

Keep asking. Every time when there might be signs that this isn’t the right solution, just say, you did bring this up. Just reminding you. You should be resilient like that. And you need that from your teams, from your business.

You need that resiliency from your EHS person to keep pushing for the things that you believe in. That you believe are the right choices, the right direction for your organization. Don’t give up. Don’t give up on the first no or the hundredth no. If you feel that it’s right.

Rogelio Cuellar: Yeah, always do the right thing. Absolutely.

Hilary Framke: Just like the Boy Scouts.

Rogelio Cuellar: Exactly. It was a commercial at the end.

Hilary Framke: Exactly. Rogelio, it has been a pleasure. Gracias. Muchos gracias for your time, for everything that you shared today. Such deep insights and I love that we stayed on this topic of global implementation and diversity and culture and regulatory organization.

It doesn’t get talked about enough and I love that we were able to bring it to the Elevate EHS podcast platform. So thank you for being with me today.

Rogelio Cuellar: Thank you very much. It was really fun. I totally enjoyed. So thank you for inviting me and it was a really pleasure.

Hilary Framke: Goodbye, listeners. See you next time.