Picture yourself in a massive factory, surrounded by towering equipment, the whir and hum of the machines, and the scents of various foods wafting through the air. Hundreds of thousands of items are produced and packed here daily, with a dozen different products made each day. There are several production lines and each one is buzzing with another product in the works. Now, as a rabbi in a major kashrus agency, you are tasked with the enormous responsibility of setting up a kashrus system in the plant and making sure all of the kosher products are produced, packaged, labeled, and worthy of the kosher symbol affixed. The task is humbling.
Just as Hashem sends the refuah before the makka – he sends the solution before the problem – we must try and do the same. In this case, the challenge is the potential for errors in production and kashrus and the solution is an iron-clad, custom designed kashrus system that meets the unique needs of the company and the products that will be certified. What is a kashrus system and how does it work? A kashrus system is the method of supervising the kosher certified production at a particular facility. The art of giving a reliable kosher certification lies in the ability of knowledgable and trained rabbinic staff to be able to assess a particular manufacturing reality—through a thorough understanding of the industry and its unique set of circumstances—and set it up in a way that will be both practical and in accordance with kosher law. It can include the order of products produced each day, mashgiach requirements, labeling, data requirements, cleaning procedures, and koshering (if applicable).
What is the difference between a hechsher with a weak standard and a hechsher with a good standard? One of the biggest differences boils down to one word: b’di’eved (after the fact). In Shulchan Oruch there are a number of things permissible b’di’eved, but l’chatchila (from the start) are not permissible. For example, b’di’eved a drop of milk that fell into a pot of chicken soup (less than 1/60th or 0.0167% of the total volume) is permissible, but l’chatchila one cannot intentionally put a drop of milk into the chicken soup. In every part of life, there are certain things that after the fact are not the end of the world, but are not advisable from the get-go. If someone drives cross-country in an old car with old tires or that often experiences mechanical trouble and lacks airbags and other newer safety features, after he arrived safely what’s done is done, but nobody would advise someone to take such a trip in a less reliable car. Similarly, with regards to kashrus, there is a safe way to give a hechsher and the opposite.
Creating an Iron-Clad kashrus System
Giving a hechsher is a form of Quality Control and the security systems in place can be compared in a sense to Quality Control procedures set up by a manufacturing company. The kashrus agency, and specifically the Rabbinic Coordinator, is tasked with the job of setting up the kashrus system in a way that ensures there is no foreseeable possibility of “b’di’eved” situations. If, after a strong, custom tailored system is put in place, complete with continued data collection, product formulas, inspections, etc., there is a breach in the system or another problem, the agency must reevaluate and correct the situation. Our primary job, however, is to prevent problems from occurring.
When dealing with kosher supervision, it is not enough to just build a fence. We build a fence, set up an “alarm” system, monitor the system, and sometimes even require a 24/7 security guard…
By way of example: When someone wants to protect his home or office, he places a strong lock on the front door, bars on the windows and fences in his property. Sometimes, as an additional safeguard, the person installs an alarm system. To make it even more secure, he can subscribe to a central monitoring service for his alarm system, or even go as far as having a private security guard stationed at his home or office 24/7. When dealing with kosher supervision, it is not enough to just build a fence. We build a fence, set up an “alarm” system, monitor the system, and sometimes even require a 24/7 security guard, the mashgiach temidi. A good kosher certification is like a pie, made up of many slices that provide diversity and unique strength for the kosher program. We sign a legally binding contract with the company, have a senior rabbi supervising the mashgiach and all aspects of the certification, spot checks, and a complete data collection system with all of the ingredients and product formulas. We ask key questions and make sure to understand the nature of the industry before embarking on a new certification.
The financial and legal commitment required to obtain a hechsher is a significant aspect of the kashrus system. If a company is investing financially in kosher certification it is a motivation to ensure that kosher protocol is properly kept. The company also signs a legally binding contract that obligates them to follow the protocol set forth by the OK and to follow the directives of the Rabbinic Coordinator and mashgiach. If the contract is violated, the kosher status of the final product is jeopardized and can subsequently be recalled from the market.
Perhaps, most importantly, the rabbi placed in charge of the kashrus of the company is an expert in the particular area of food production. The OK has Rabbinic Coordinators who specialize in various fields: dairy, meat, flavors, bakeries, liquid transports, etc. Each rabbi is trained, with much hands-on experience, to see beneath the surface and to foresee possible scenarios and their ramifications BEFORE they occur. Working in tandem with the Rabbinic Coordinators are the mashgichim, who undergo training specific to the type of production, as well as in carrying out OK policies and procedures.
Another crucial facet of the kashrus system is data support services. There are various levels of data support, beginning with the OK’s proprietary computerized data tracking system. At OK headquarters an entire department of staffers works full-time to maintain and update a data system containing every ingredient and formula for OK supervised products and facilities. The system even includes products made in the facilities that do not bear the OK symbol, but are made in the same factory. The Rabbinic Coordinators and mashgichim have access to this vital data over the Internet, via the OK’s specially designed software, so it is available to them in real time anywhere in the world!
Early in my career, I had the zechus of mentoring under Rabbi Dovid Steigman, Senior Rabbinic Coordinator at the OK, and was taught that a rabbi has to learn to go with his gut feeling. (See “Who’s Behind the OK” in this issue.) After going through all of the proper protocol, the rabbi has to feel comfortable about the setup. If he feels uncomfortable, even if he can’t “put his finger on it”, it usually means something is wrong. When a rabbi setting up a company feels this way, he has an obligation to investigate further, by discussing with his colleagues, making another visit to the facility, and getting to the bottom of the issue.
Perhaps most important, is the understanding that situations change and may require modification. Companies by nature are in business to make money and prosper. In order to make money, they need to be in a spirit of movement and growth – selling product, expanding the product line, getting into new markets, even changing their business model if needed. When the company was new, we set up a system that worked well. In a few years, when the company has experienced growth and change, the system needs to be reevaluated and tweaked if necessary.
Different Levels of Complexity
While every company is indeed different and its kashrus system is unique, there are some general differentiations between the levels of complexity in kosher certification.
One company used to repack items by hand. Now, due to growth, Baruch Hashem, the company packs bulk products by machine, which changes the whole dynamic. A vertical bagger machine carries a risk that product gets stuck in the machine and later dislodged into a later batch. If the company packs dairy items in the morning and pareve items in the afternoon, there is a real possibility that a dairy item that gets stuck in the bagger ends up in a pareve product when it is dislodged later. The system for this company requires pareve products to be packed in the morning and dairy products in the afternoon to prevent a dairy item from ending up in a pareve package. The machinery is then dismantled and fully cleaned each evening for general quality control purposes and to ensure no product remains lodged in the machine.
Every change in manufacturing has a ripple effect that is much deeper than meets the eye…
Meat, cheese, Cholov Yisroel and some fish productions require hashgocha temidis and much more monitoring is necessary to ensure the kosher protocol remains intact.
Sometimes, there is a situation where there is a kosher meat product and kosher dairy (or kosher pareve) product OR kosher meat product and non-kosher meat product and they both look exactly the same. An example would be meat ravioli and cheese ravioli, which both look the same from the outside. When we go to a factory that makes ravioli and make a kosher production, the kashrus system is as vital and sensitive as, l’havdil, open heart surgery. The kosher production is done first thing in the morning after everything is cleaned and kashered if necessary — first pareve ravioli and then milchig. The OK does not allow dairy and meat production on the same line on the same day in case some product gets stuck during the first production and then dislodged later into the other product. This is a prime example of the necessity for the rabbi to understand every manufacturing situation and establish a kashrus system to address every unique scenario.
Of course, Passover production has a whole other set of kashrus protocol and requires a high level of supervision. While some facilities produce only Passover products, others need to be kashered for Passover production. Passover usually involves more complexities and potential for changes.
For example, a company makes chocolate products for Passover and gets their chocolate from a supplier. During the year a chocolate melter is used for kitniyos. For Passover use it must be cleaned and kashered. Now, the company has grown to a point where they want to purchase their own chocolate tank and use bulk liquid chocolate instead of melting blocks of chocolate. Passover is approaching and liquid chocolate is suddenly not available with Passover certification. If the company is not able to flush out the chocolate tank and clean it in time to melt the chocolate themselves, then changing the kashrus system is not going to be complete in time for Passover.
Every change in manufacturing has a ripple effect that is much deeper than meets the eye. Each effect is lingering and has a very far reach and it is only through hands-on experience that rabbis perceive the ramifications of these changes and act upon them accordingly.
Affixing the Kosher Symbol
There are different levels and requirements for kosher supervision and, as a result, there are different methods of affixing the OK to a product that vary depending on the particular circumstances. The most popular for consumer products are the OK symbol printed directly on the product label or traceable OK seals affixed personally by the rabbi. A product that does not require hashgocha temidis usually has the OK printed directly on the product label and the mashgiach checks the company’s label book and the log of labels affixed to the products at his surprise inspections. A product with a mashgiach temidi is generally stamped or labeled individually with traceable labels by the mashgiach himself. The label numbers are then recorded by the mashgiach and submitted to OK headquarters in his report.
One OK certified company was an exceptionally complex case. For many years the company had pareve line to produce only pareve products. The company experienced a strong upsurge in dairy business, so we cancelled the dedicated pareve line because they needed to use it for dairy also. We sealed up one small portion of the pareve line and then kashered the rest for pareve productions as needed. During that time period, pareve products were no longer labeled with the OK symbol. These products required the rabbi’s personal stamp on each product since it required the rabbi’s presence for pareve production.
Handling a Breach in the System
What do we do when there is a breach in the system? I have trained myself to ask, “What went wrong?” define the problem, and then define the solution. One cannot define solution without defining the problem. What is the source of the problem? Why did it happen? Where in the production line did it happen? Was it something random, or is this a pattern? If it is a pattern then we are dealing with a deeper problem.
What do we do when there is a breach in the system? I have trained myself to ask, “What went wrong?” define the problem, and then define the solution. One cannot define solution without defining the problem. What is the source of the problem? Why did it happen? Where in the production line did it happen? Was it something random, or is this a pattern? If it is a pattern then we are dealing with a deeper problem.
Assessing the situation is all part of maintaining the certification. It is no different than an assessment after damage to a new house. The house passed inspection, but later flooded from a hurricane. Was the person who built the house, or the person who inspected and gave the Certificate of Occupancy at fault? No, but something happened that was not foreseen. It all must be figured out.
In another situation, a company accidentally labeled an uncertified product with the OK symbol. Due to kosher laws in that state, the state fined the company a significant sum. They complained that the fine was so expensive that it was almost equal to the cost of supervision! In this case, the label was for a test item that was mistakenly printed outside the protocol requiring extensive label review and was never entered into the label book. Our systems are designed to protect the consumer AND the manufacturer. That label book would have protected the manufacturer from the loss incurred by recalling the product.
There was one customer that had a few incidences of mislabeled products. It was very difficult to pinpoint why and how they happened, so we revamped the entire system. The products could no longer have an OK preprinted on the label. The mashgiach was required to put special numbered stickers with permanent adhesive on each product to indicate that he supervised the kosher production. We changed the system so there would be no doubts about the kashrus status of the product.
Only Settle for the Best
When shopping for anything important, such as a good family doctor, one looks for the best in his field. Just like in any industry, people are limited and very few specialize in many fields. One can be the best neurosurgeon, but usually not also the best orthopedic surgeon. A person looking for kosher food also has to rely only on top notch specialists. A quality hechsher needs to have a variety of top specialists and not rely on one person to be their meat, dairy, flavor AND bulk oil specialist all rolled into one. The art and the ability to set up, diagnose, establish and record a kashrus system for a particular type of manufacturing process is a specialty that requires a lot of mesorah and hands-on shimush (practical training).
t is only possible to give a hechsher when a proper system can be put in place, which includes having enough personnel to see it through. If a company is disorganized or doing too many different products (kosher, non-kosher, pareve, dairy, etc.) all manufactured together in the same facility, we cannot even get involved in such a venture. The quality of a hashgocha is measured in part by the companies that do not meet the agency’s kosher standard and are turned down for certification. A true top-notch kosher certification has the expertise AND the Yiras Shomayim to know when to say, “No, this product cannot be certified,” or, “No, this product cannot be certified without significant changes in the facility.” As the consumer, if you regularly insist on kosher without compromise, companies seeking certification will also insist, and the food that graces your Shabbos, Yom Tov or weekday meal will always adhere to the highest level of kosher protocol.