Why Are Kosher Inspection Visits Unannounced?
When it comes to kosher inspections, there’s a connection between the element of surprise and regulatory integrity.
One distinct feature of kosher certification is the unannounced visit. For the biggest names in food production, third party audits are a matter of course. And the bigger the company, the more regulatory programs they’re likely to have. For newer or smaller companies who may not have as much experience with certifications, the concept often raises some concerns. Here, we’ll discuss the link between regulatory integrity and the unexpected.
We’ll cover in this post:
- The different types of kosher visits:
- The Initial Visit
- Annual Visits – an OK Kosher-Exclusive
- Unannounced Inspection Visits
- Kosherizations, and
- Supervised Kosher Productions.
- The need for unannounced visits, or drop-in kosher audits, and
- What to expect on an unannounced visit, and
- More commonly asked questions about unannounced visits.
What Are The Different Types of Kosher Visits?
Typically, when you receive a quote for kosher certification, the summary of services will mention at least one or two types of visits, but there can be several.
The first three listed below are the primary, and most common:
The Initial Visit
This is the first of your annual visits. At this meeting, a professional Rabbinic Coordinator (RC; a Rabbi who designs and administers the kosher program for each company) will evaluate the facility and production processes. He’ll synthesize what he learns there with information from your application and phone consultation. With all the facts at hand, he’ll design a kosher program for your company based on your goals with kosher production and labelling, while strictly adhering to a high standard of kosher law. This visit also serves as the setup for the program. It’ll be a chance to go over any instructions or training needed for plant personnel, too.
For Annual Visits, we also use the term Annual Executive Visits (and sometimes HQ Visits) because they’re conducted by an RC as opposed to a field rep, or Mashgiach (Hebrew word for inspector or supervisor), who works under the RC.
As mentioned, the Initial Visit is the first of your Annual Visits. Annual Executive Visits deserve special mention because they’re an exclusive facet of OK Kosher programs. With other kosher certifiers, the RC will set up the kosher program, and then the assigned Mashgiach) will conduct all other visits throughout the year. At OK Kosher Annual Visits, the representative from the company responsible for dealing with the kosher certification will have a meeting with the RC. This is when you can discuss any questions you have or changes you or the RC may need to make. Annual Executive Visits deserve special mention because they’re an exclusive facet of OK Kosher programs.
The late CEO and Kashrus Administrator of OK Kosher as we know it, Rabbi Don Yoel Levy, of blessed memory, was a mentor to all current members of the OK Kosher Rabbinical Council. It was his father, Rabbi Berel Levy, of blessed memory, who established the Annual Visit concept. Although Mashgichim are fully qualified to make drop-in audits, the Rabbinic Coordinators are true authorities on kosher law. Furthermore, they each have their own area of expertise. These might be anything from wines, cheeses, catering, flavors and fragrances, to logistics and transport, or manufacturing practices by region or company size, etc. When you apply for kosher certification, you’ll get assigned to the most appropriately experienced RC for your company.
Unannounced Inspection Visits
Also referred to as mid-year visits or drop-in audits, these are conducted by kosher field reps, and are unannounced. We assign Mashgichim based on how close they’re located to a given facility. As mentioned above, these representatives are called Mashgichim (plural) in Hebrew (Mashgiach, singular).
Their objective is to carry out all tasks that the RC has established as part of the kosher program for your facility. The Kosher Rules section of your Certification Agreement should clearly include this information. The Rabbinic Coordinator will also have explained these at the outset of the program. A Mashgiach’s job is to keep eyes open for anything that could jeopardize the kosher status of your products. Further down in this post, we’ll talk about what happens during these unannounced visits.
In addition to these visit types, some programs will require any of the following kinds of visits, also typically carried out by a Mashgiach:
This is the process by which a kosher representative – either your Rabbinic Coordinator or a Mashgiach – will purge the equipment of any non-kosher substance from previous runs. This may involve thorough cleaning, hot water rinsing or other methods. The RC will determine whether and how often Kosherizations need to happen for any particular facility.
For instance, if you plan on running exclusively kosher, you may need just one kosherization at the beginning of your certification. If you’ll be using shared equipment or alternating between different types of runs on the same equipment, you may be required to have kosherizations before every run of kosher certified product. Still, many kosher programs require no kosherizing at all.
The exact procedure for kosherizing depending on the equipment and ingredients at hand. For this, your personnel will get a complete rundown of the rules entailed before moving ahead. Everything will be laid out and discussed ahead of time.
Supervised Kosher Productions
Kosher regulatory standards treat different raw materials, and different equipment types, differently. Some ingredients, such as those derived from grapes, are of an especially sensitive nature within Kosher Law. Therefore, depending on your product types and facility specifications, your kosher certification may run on a per-production basis. We’ll build this into your quote, to keep you fully aware before signing your certification agreement.
At this juncture, we’ve covered the different kosher visit types and what they’re about, so you have the necessary background. Read on below to learn about the most frequent type of kosher inspection – the Unannounced Visits.
What’s The Need for Unannounced Kosher Audits?
Let’s get to the main question you’re all thinking. Why do drop-in kosher visits need to be unannounced?
Unexpectedness Breeds Accountability
This is one of the foundational principles of good regulatory efforts. We’re a third party certifier. That means, while we’re rooting for your company’s success, we are officially impartial on business matters. Our goal is one thing: to make more high-standard kosher food available to more people all over the world. Our regulatory standards are the bedrock of our organization. That’s why we train our representatives in our methods, even though they may have previous kosher inspection experience.
Trust is Key
Further to that, trust is key in kosher certification. Our clients trust us for top service and high quality certification. At the same time, consumers trust us to be honest and upright about what we put our stamp on. In turn, we need to hold our clients accountable for their side of the deal. We establish this relationship from the beginning, by setting up a culture of transparency and partnership with companies.
In our short documentary film, Inside OK Kosher, one of our longstanding clients in France probably said it best:
“We’ve built trust together, between our companies. The rabbi in charge of our certification understands the spirit of our company, and vice versa…The confidence between us is key.”Eric Angelini, VP of Global Regulatory Affairs, V. Mans Fils
In addition to those happy feelings, there’s the mutually signed Certification Agreement. It contractually holds the company to the kosher standards we’ll educate them in. We create a set of guidelines specifically for each company, fully documented and explained.
On top of that, the most dependable way to ensure this ongoing trust is to stop by unexpected. Our reps need to see your facility as-is.
Think of it like a surprise visit from your in-laws. It may not be the kind of surprise you like, but they sure do get to see what your home looks like on an average day.
It’s the same with kosher…kind-of. Let’s say, for instance, your supplier sent a non-kosher ingredient in place of a kosher one that was out of stock. It may be tempting for a plant worker to just use it. They may not even realize it wasn’t kosher! These are normal, human errors, but there’s no room for that when it comes to kosher. While these instances are rare, we want to preclude them.
Remember – You Hired Us
We know that each manufacturer has its own process and flow. Your kosher certifier’s calls aren’t meant to get in your way, but rather to allow you to continue operating – and remain kosher! Barging in unannounced, demanding documents and your staff’s time immediately are not our way. The whole objective is to allow for your company’s uninterrupted kosher production. Therefore, we make the drop-in visits as quick and painless as possible. Just ask anyone working at a veteran OK Kosher certified facility. They’ll likely tell you that over the years, their Mashgiach has become their friend.
With the understanding of why we need to make unannounced inspections, you may be wondering what these drop-in visits actually consist of. For that, read on.
What do mid-year kosher visits look like?
To answer this, I spoke with one of our long-time OK Kosher Mashgichim, Rabbi Dovid Feder. From his wealth of expertise, here’s what you can expect when your unannounced kosher audit rolls around.
First Things First
When the local kosher representative drops in, he’ll want to meet with your company’s kosher contact person. (We also ask companies to designate a backup person in case the main contact ever isn’t available.) One of the related personnel such as Quality Assurance, Quality Control, or the Production Supervisor or Manager should be on-site at all times anyway. Any of these professionals are great options to receive the Mashgiach at the facility.
The Mashgiach will start by either requesting to go over documentation, or will ask for a guided tour of the site. In either case, he’ll look for any noticeable changes to your operations. For instance, he’ll need to verify that the list of ingredients we have on file corresponds to what he sees.
Speaking of Ingredients…
The Mashgiach’s survey of the plant will be mainly focused on ingredients – the cornerstone of kosher considerations. The kosher symbols and other identifying features on ingredients being stored there need to match our records. In a properly set-up kosher program, the facility personnel will be aware of this, and there will be no issues.
Mashgichim, or kosher field reps, carefully detail the findings of their visit in a visit report. These get logged in our system and are reviewed by the RC, as well as the Mashgiach before the next visit.
In the process, the Mashgiach will ask if anything is new or has changed with the products in the kosher program. In support of this, he’ll check labels to see that they’re all on the approved list we have on file. Another consideration is the presence of Private Label brands produced for an outside company. These require the outside company to sign a Kosher Private Label Agreement with us if they want the OK symbol printed on their labels. Mashgichim will keep an eye open for any private labels in your facility using the OK symbol that are not properly registered as such in our system.
Kosher Production Rotation
When your facility produces both kosher and non-kosher products, we have to make sure the switch-overs (Kosherizations) happen properly. Remember, they’re detailed in the Certification Agreement and gone over in the initial training.
If he notices an irregularity, the Mashgiach will take copious notes as he asks what steps the plant personnel have already taken, if any. This gets immediately passed onto the RC for review. And of course, the Mashgiach will reiterate our rule that any such changes in the future need to be reported by the company ahead of time.
Being that your Mashgiach acts as an agent of the RC, they’ll make no decisions in the field. They’ll need to carefully collect detailed data such as affected inventory, and what product is still in the facility, any already on the market, and label inventory.
What to Have On-Hand
A well-run and organized facility should always have a label book, or other form of access to label data. From an unannounced visit perspective, there should also be production records, ingredient receiving records/incoming log. These are crucial to a smooth visit and overall kosher program.
All-Kosher vs. Multiple-Program Facilities
In an all-kosher facility, the Mashgiach’s radar is out for exceptions to the norm; anything that seems non-kosher. This stretches beyond actual ingredients and includes equipment lubricants, accidental food contact from employees, and incidental ingredient or raw material substitution.
In a facility with multiple programs that include non-kosher runs, the kosher program will maintain more control factors, to protect the kosher aspect. This includes making sure that kosher-dedicated lines remain kosher. At the unannounced visit, the Mashgiach will check that glow plugs (and any automation devices such as indicator lights) are operational for products requiring Pas Yisroel or Bishul Yisroel programs. For instance, in the event that there was a power failure, the Mashgiach will need to turn the mechanism back on. In facilities with both Pareve and Dairy lines, they’ll check production records for the Pareve line against the Dairy, as is often the requirement in bakeries.
“In a multiple-program facility, it is common to include ingredients of the non-certified or non-kosher products, in your OK Ingredients List. This might seem odd, but it assists the Mashgiach in recognizing items seen on the tour and also those seen in your receiving records. It is much easier to have one receiving plan for all ingredients; employees will have fewer questions or errors with only one system!”Rabbi Dovid Feder, Mashgiach.
More questions you might have about kosher audits.
Here are some other queries about kosher inspections we’ve been asked before.
How can we prepare for these visits if they’re unannounced?
At a minimum, your Mashgiach will expect to see some basic records on a drop-in. These are things you’re likely to already have on hand as part of safety protocols. He’ll want to see your label book (or other system of viewing all your current labels), production records, and receiving records for ingredients. If any of these were not already part of your facility’s setup, your RC should have helped you set up something like this ahead of launching your program.
Can we know how many unannounced visits you’ll be making this year?
No. Again, it’s that integrity aspect. We want to see your facility as-is, to be on the lookout for changes.
In short, it depends. To explain, we’ll break the answer up into two parts.
The OK is Different
Listen, you chose OK Kosher for a reason. Maybe that reason was because our symbol is the most recognized world-round. Or maybe it’s because the wholesalers you’re working with are requiring it. Neither of those are an accident. While it’s true that manufacturers love working with our conscientious RCs and friendly account reps, the demand for OK Kosher certification boils down to the consumer. They know our high standards, so they trust in the symbol and what’s behind it. They may not know the details of why we’re better (though many do), but they definitely know our reputation precedes us.
As mentioned, OK Kosher is the only kosher certifier that requires Annual Visits from the RC. We can’t state how often this executive-level, in-person meeting has prevented mishaps, predicted issues, and given companies the chance to plan and set up for success with kosher certification. It’s the proactive, rather than reactive, approach to regulatory that your company may just have been looking for all along.
So now down to the second part of the question.
High Standards Translates to High Frequency of Visits
Earlier, we touched upon how our RC’s design a custom program for each company, and the Mashgiach gets assigned to drop in and inspect the facility periodically throughout the year. Our kosher field reps are specially trained in OK Kosher standards that Mashgichim from other certifications may not be. At the same time, they are independent contractors and often work for more than one kosher certifier simultaneously. If we are familiar with a particular Mashgiach’s skills and reputation, their existing drop-in visits to the facility for another company may suffice for our program.
So for instance, if OK Kosher has determined that your company requires six unannounced visits to the facility annually, and there is a Mashgiach we know who already visits four times for another certifier, we may approve the use of his visit reports for those four visits, and hire him to conduct another two. In such a case, our costs will be lower, and we’ll be happy to pass the savings on to your company.
In some cases, however, we can’t offer this option. One reason could be that we don’t have any relationship with the Mashgiach currently visiting. Another could be that the visits we’re calling for are different in nature than the ones being made because of your products or our standards. This can be because of the need for kosherization or RPRS.
In short, if sharing visits is in option, we’ll look into it and certainly allow it whenever it benefits the kosher program and your cost savings.
OK Kosher designs and runs comprehensive, and totally customized programs for each company, and each facility, we certify. We either require or offer several types of visits, including our special Annual Executive Visits. The unannounced, drop-in inspection visits are a core regulatory measure that all good kosher certifiers use. High standards are great, but for us, they don’t exist in a vacuum. The unannounced aspect is how we ensure that our high standards actually hold water, and keep things kosher.