Note: For many, the inner workings of kosher supervision are a curious riddle. This article attempts to offer a behind the scenes glimpse into some common scenarios that occur in kosher supervision. I have deliberately changed some of the facts in order to safeguard confidentiality.
To be, or not to be (forceful)!
Recently, I was given the task of supervising a large plant that makes a kosher certified, strictly vegetarian product. We all know that vegetables do not pose any of the kashrus issues that meats do. Other than the issues of “tolaim,” (removing bugs/worms) and checking whether the vegetables come from Israel, it would seem that a vegetarian product should be simple to supervise.
I prepared for my visit by reading up on the company and the products produced there. I read through all of the notes in the OK database on the particular company, as well as all of the comments written by the previous kosher inspectors. I then contacted the Rabbinic Coordinator, who is responsible for overseeing the entire kosher program of this company. Lastly, I researched to find any information that would shed additional light on the company, the ingredients and the products.
I set out for my first visit to the company and the trip was a long one, with over 200 miles of driving. Thankfully, my son had recently purchased a contraption with some shiurim on Yoreh Deah, as well as rich Yiddishe music to keep me company. The trip was not too boring; my route took me through beautiful, scenic mountains, as well as a few sleepy towns. From time to time, I noticed interesting landmarks, which helped me keep awake. The hardest part of my trip was driving through the congested areas, and even worse, getting slowed down by traffic.
I finally arrived to this huge plant, nestled in the far reaches of a small village. The plant was in a rather large commercial area. I met with the welcoming staff at this large plant. In their eyes, everything was simple and straight forward. They were only using kosher, vegetarian products. What could be wrong with vegetables?
In theory this is so, yet in practice it is much more complicated. Most food processing companies that produce finished edible products do not start off with the original raw materials. In our personal kitchens, it is relatively easy to buy raw vegetables and fruit, and maybe even raw spices (other than sugar and salt), and use them in order to prepare a strictly vegetarian dish; however, this is usually not the case at the commercial level. It would seem that finished food producers see themselves as the ones who combine all of the ingredients together according to their individual specifications in order to present their unique food products. They do not see themselves as the ones who prepare all of the raw ingredients that go into the process. They would much rather purchase the already partially processed raw ingredients from companies that specialize in this type of production. Therefore, besides checking the processing of the finished product, we must also check every one of the companies that produces the raw ingredients.
When a company uses broccoli, tomatoes, other vegetables, or herbs and spices, they usually do not buy the raw vegetables as their ingredient. Instead, they buy them in their partially processed form; but, why?
There are a number of reasons (and advantages):
Expediency – It is easier for them to take a product that is peeled and cut down to their exact specifications, and with the right consistency. The food manufacturers would rather use their time and their workers for their expertise (i.e. making and preparing the finished product), instead of wasting their precious time on cutting and preparing the raw vegetables.
Price and quality – If they buy large quantities from a raw ingredient producer, chances are that they will receive a better price and quality than if they were to buy on the open market.
Consistency – The quality of the processed raw ingredients will be more consistent than the raw ingredient itself, since the food processors work hard to maintain consistency of their products. When we buy raw vegetables on the open market, their quality would depend on the rain, climate, farmer, country of origin, etc.
There are two more important reasons why the food producers may buy only processed raw materials. During food processing, one of the major concerns is that the food should remain healthy until it is eaten. In our own homes, we prepare food and eat it relatively soon after it is made. When food is manufactured by a company, there are many more chances for food poisoning to occur. Both legally and practically, these companies are very careful not to give bacteria any chances to grow. If they were to buy raw, unprocessed vegetables, there is a possibility for there to be some bacteria on the ingredients. When it is processed, the processing usually includes killing all live bacteria. This is why they use processed ingredients.
There is also an added advantage of accountability. If something were to go wrong, we would immediately know who is accountable. This helps decrease the manufacturer’s liability
Since these raw vegetarian materials are processed, each one of the processing plants must be checked to see what else was used or could possibly be used on these processing lines. The good news is that many of the processing plants in America have kosher certification. As a matter of fact, kosher certification is becoming the standard for many companies, since they wish to be able to supply the broadest possible pool of customers.
The Flavor of Flavorings
If a company is making a vegetarian product, they generally use soy (wheat, rice, or other similar ingredients) as their base and then use vegetables and spices to provide the flavor. Sometimes, the vegetables are added in order to produce a desired texture in the finished product. This is why you often see a large list of complex ingredients in many products. Some of these provide the flavor, some provide the food consistency, and some provide complex chemical reactions in order to present a savory, delectable product.
If we think about it, the real reason for using many particular raw ingredients and spices is to produce a certain flavor for the finished product. What if that same flavor can be bought in a liquid (or powder), highly concentrated form? It would have all of the components that the company would have included had they created the flavor in-house. Many of us would opt to buy this prepared flavor even if it were expensive. After all, it eliminates the need to buy and then prepare large quantities of vegetables, herbs and spices. It also saves space and the costs incurred by hiring more staff. And, you would end up with the same flavor, in a compact container. To be sure, the cost of flavoring is very high, but the benefits outweigh the cost for many manufacturers.
Many companies decide to leave the job of extracting flavors to others, who will work hard to prepare a consistent, great flavor. The food company can now focus on producing a terrific final product. Each of the flavor companies must be supervised thoroughly for kosher compliance. To add to this, when a product is expensive, the motivation for using unauthorized ingredients is greater, therefore we may require even more diligent supervision to ascertain that it is really kosher.
If all of the bulk products were labelled as clearly as some of the retail products, our job would be easier. Many companies choose not to affix a kosher label on their bulk product. Instead, they send a letter of kosher certification stating that a certain lot number, date or place of production is kosher certified. At times it is difficult to match the letter with the delivered product. When this happens, the mashgiach must begin his research. It can be quite time consuming to track down the supervising rabbis to clarify the kosher status of the item in question. There are also times when the supervising agency and company ask their distributor to send an ingredient with a particular kosher certification and the distributor substitutes it with a similar product bearing a different kosher symbol. At that time, the product needs to be reviewed to see if it may be approved. This is where the complications begin, because the standards of the second kosher agency have to be reviewed in order to verify that it satisfies the standards of the agency supervising the finished product.
During my visit, I had noticed that the company’s 256(!) approved ingredients were spread out in their sprawling warehouse. I needed to figure out the best way to verify that all of the ingredients were really the approved ones. I also spent a long time watching and studying the plant and the various machines they use. I felt quite comfortable with this aspect of the production.
Boruch Hashem, the company had a batching room at the plant. In this room they would measure out all of the ingredients that were to be used in the upcoming production. The room contained one case of each of the ingredients used on a regular basis. It was relatively easy to inspect those ingredients, as they were readily available. I found that most ingredients had a proper kosher symbol on them; however, I found some ingredients that did not have a kosher symbol on the product label. I went through my paperwork and logged into our online system to download the kosher certificates, so I was able to ascertain that they were all approved for use.
I was amazed by the previous rabbi, who is well known as a Yorei Shomayim and a thorough mashgiach, and his success in checking all of the 256 ingredients. After all, the storehouse for all of the ingredients was almost as large as a football field. There were rows of shelves carrying all kinds of ingredients. Ingredients on the bottom row were within reach, but the storehouse had four levels of shelves and each level was about six feet high! I needed to figure out how I would be able to check an item that was stored on the top shelf, in the far corner, a seemingly impossible task.
I realized that I would have to devise a new approach to examine the records. I went into the files and printed out a list of all the ingredients and quickly discovered a real problem. This company was purchased at one time by another company, and was subsequently sold again and became independent. During the various stages in the company’s history, ingredients were added to accommodate an expanding product line. The challenge was that these ingredients were, at certain times, assigned different codes and different names. This meant that the same ingredient could have 2 different names and/or 2 different codes. The internal coding system worked very well for the company; however, it needed to be adjusted so that it could also be useful for kosher tracking purposes.
Actually, I wanted to institute a system where each ingredient would be inspected for a kosher symbol as it was received at the facility. There would be somebody accountable for each ingredient, and I could easily review the ingredients by checking the records regularly, in addition to physically checking all raw materials in the plant warehouse during my inspections. I was faced with quite a dilemma – do I come out strong and demand real change right now, or do I work with them slowly and patiently in order to get the job done? [I must add that I have never found any violation of kosher protocol at the company, but in order to continue in the ~ tradition of “an ounce of prevention is worth a pound of cure”, a better system needed to be put in place.]
I am, by nature, rather laid back and non-aggressive, and I decided to go back home and ask for guidance. I discussed it with some rabbis and I eventually asked the rabbinical coordinator of this company, Rabbi Dovid Steigman, if it would be proper to work slowly, step by step, with the company to advance their kashrus accountability. Rabbi Steigman agreed, and I started trying to implement this approach. It has been a few months already since I started working with the company on their paperwork and, while I have been frustrated at times, I marvel at what has been accomplished to date.
The company started to review each ingredient. They overhauled how they coded their ingredients. They removed many redundancies. They found certifying letters for each ingredient. They instituted a system where the ingredients are divided into various groups, making the review much easier. They are also working on simplifying the names assigned to each product.
Last, but not least, we are working with the receiving dock on ensuring that there is a person accountable for checking the kashrus symbol on each product to verify that it matches our requirements (as listed in the database). Of course, I will still be spot checking the actual ingredients, but this will in addition to a clear, almost fool-proof system of accountability.
I discussed my previous quandary with the management of the company and asked them their opinion. They explained to me that they really were ready and eager to comply with whatever I wanted. They just did not understand exactly why… and what it was that the OK required and what steps were necessary in order to implement these changes. Furthermore, they wanted to take these steps in a way that would make the employees feel part of the bigger picture rather than antagonized. Accordingly, Rabbi Steigman’s approach was exactly the right way to handle this situation.
Providing kosher supervision at a plant entails creating a partnership between the kashrus agency and the plant workers. Kosher supervision can only be given to a plant which employs people who want to maintain the kosher standards and are honest and straight forward. If, G-d forbid, a company is dishonest, it is impossible to give a certification. Yet, as well-intentioned as a company is, they are not as sensitive to the kashrus details as the kashrus agency itself. The more both sides understand each other’s needs and concerns, the better the certification will be. This must be the basis of the partnership between the plant management, plant employees, and the certifying agency.
I would like to end off with the Tefillah, “Sheloi ta’ara d’var takala al yadee …v’loi oimar al tamai tahor…” May the A-mighty ensure that no error will occur during my watch. May I not mistakenly misrepresent non-kosher as kosher.
I welcome your comments and feedback, and look forward to hearing from you at [email protected]