As we face huge challenges from COVID-19, I am reminded daily of the parallels we faced in the 9/11 aftermath and related Anthrax incident nearly 20 years ago when I was Director of FDA’s Center for Food Safety and Applied Nutrition. So I thought I would share those reflections with you, and how they might apply to the food industry in today’s COVID-19 crisis.

Like this one, 9/11 was a sudden and traumatic event, and the concurrent “Anthrax in the mail” episode was something that threatened government employee health, but on a much smaller scale than with COVID-19.  The main differences are, on the upside, that COVID-19 is not a direct threat to the food supply in terms of safety (something we are all deeply grateful for); but on the downside, COVID-19 potentially affects every American consumer, every food industry employee, and every member of the relevant governmental staffs.  So the “it’s personal” aspect is especially important to pay attention to.

There are 10 thoughts for those in the food industry to consider and reflect on:

  1. Times of crisis call for new paradigms.  In post-9/11, we went from thinking about accidental (and invisible) food contamination to intentional contamination – so the new lens then was all about access — where and how could an intruder invade and contaminate food?  In COVID-19, the new paradigm is about food safety and worker/consumer safely becoming merged and intertwined.  How to keep workers safe, how to react if a food company employee gets sick, and how to ensure that our consumers feel safe has become our new focus.
  2. The good news is that the same analytical and problem-solving skills that worked with the old paradigm can work equally well with the new paradigm as well – we all just need to be focused in the right direction.  But it is important to keep articulating the new paradigm.  The first stages are brainstorming stages, where ALL ideas are welcomed without judgment, and from that list solutions can be devised and then tailored.  Those who are the most creative will thrive, and the rest of us need to be good listeners to learn from them.
  3. Social distancing is now part of our everyday vernacular, but how to apply that most effectively–and economically–in the workplace is still evolving.   As we hear in the news of illnesses of workers at food establishments, we need to remind ourselves that this is a new art and that continued innovation and experimentation needs to be embraced.
  4. The stages of recognizing and dealing with crisis are the same as in grief – denial, followed by anger, bargaining/exploration, and ultimately solution-finding.  People need time to process what is going on – and everyone has not processed at the same speed.  This is especially so since there is very personal side to COVID-19 where no one knows how they or their families will fare – either medically or just coping with the new reality.
  5. Those who are comfortable with IT will fare the best – as we become more and more a virtual society.  Working from home is the most obvious example of this new virtual world, as well as expanded use of video chat technologies and the like. Even “old dogs” need to be open to learning “new tricks.”
  6. Speed of response – and outside expectations — are now at an unprecedented high.  I see FDA putting out guidances in a matter of days that before took months or even years.  Knowing that the system can sometimes process quickly can be motivating to all who are depending on emerging policies.
  7. The principle of fighting against perfectionism has never been more important.  Being able to respond quickly at the 80-90% level is far superior to taking months to reach that desired/perceived 100% level.
  8. You can expect your staff to rise to the challenge, but also, soon (if not already), fatigue and restlessness will inevitably start to settle in.  We all need to allow for that.  That includes those in leadership positions as well.  The phrase “rescue the rescuer first” applies here, as leadership teams need to be at their best, and being too tired or burnt out will not allow that to happen.
  9. As in all crises, over-communication is imperative.  This is a time for leaders to really lean into being able to articulate clearly and openly what current expectations are.  All forms of communication are welcome, both to keep your company staffs informed as well as lessen the feeling of isolation for those working from home.
  10. At the top of the organizational pyramid, COVID-19 is the 1st, 2nd, 3rd, and all other priorities – likely for the next month or two, at least, perhaps even into next fall. This involves both the operational and financial consequences of these times.  But lower down on the organizational pyramid, more routine work can continue, and it is a good time to empower middle managers and build their capacity for leadership and growth.

Ultimately, the slogan “We Are All In This Together” applies as never before.   And like with other crises, we will come through this, Together.


Mr. Levitt is a partner in the Washington, D.C. office of Hogan Lovells US LLP and a former Director of FDA’s Center for Food Safety and Applied Nutrition.

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Photo of Joe Levitt Joe Levitt

Partner, Washington, D.C.

As the FDA’s former top food regulator, Joe Levitt brings a true insider’s knowledge to helping food industry clients deal effectively with the FDA. Whether influencing policy making or confronting a threatened compliance action, Joe’s 25 years of FDA experience…

Partner, Washington, D.C.

As the FDA’s former top food regulator, Joe Levitt brings a true insider’s knowledge to helping food industry clients deal effectively with the FDA. Whether influencing policy making or confronting a threatened compliance action, Joe’s 25 years of FDA experience puts clients in the best position to succeed.  In the private sector, Joe was on the ground floor when Congress developed the landmark FDA Food Safety Modernization Act (FSMA). Joe was also a leading voice for the food industry when the FDA developed regulations that all food companies must now follow. No one can help navigate the labyrinth of FDA’s FSMA regulations better than Joe and his team, and no one can better put your company in the driver’s seat when the FDA inspector knocks on your door for your first FSMA inspection.

Joe adeptly handles high visibility recalls and compliance actions. If a company finds itself in trouble with the FDA, they need someone with a deep insider’s understanding of what works and what doesn’t. Joe knows what the agency expects in the compliance arena, and the bar clients will be expected to meet. He can communicate his client’s position calmly and effectively to the FDA so the matter gets put behind them. His record of “helping startups and multinational companies… survive Food and Drug Administration investigations and avoid import bans that could shutter the companies,” led to Joe being named a Law360 Food & Beverage MVP (2016).

Joe is among the most decorated officials in FDA history, with his achievements being recognized by multiple U.S. presidents, cabinet secretaries, and FDA Commissioners. He maintains close working relationships with senior FDA officials and has served as the Board Chair of the FDA Alumni Association.