Salad Days for the OU

January 24, 2005


Condiments such as salad dressings and sauces have become a regular fixture of today’s meals. Whether at a fast food restaurant,
an elegantly catered meal, or in one’s own home, these products are ever present. It is for this reason that many companies seek OU certification, to provide kosher condiments to the large market of consumers who demand them. This has proven very challenging for the OU, as the level of supervision at salad dressing and sauce plants tends to be more complicated than in many other industries.

MONITORING OF INGREDIENTS
Since salad dressing plants may manufacture numerous varieties of non-kosher products, the possibility of a non-kosher source finding its way into a kosher product is a major concern. Standard OU protocol provides an airtight level of supervision to prevent this type of mishap. All raw materials at the facility should appear on the Orthodox
Union approved ingredient listing, Schedule A, regardless as to whether they are used in an OU certified product. Non-kosher ingredients that are used in non-kosher products appear on the Schedule A and are classified as Group Six Allowed. This enables the OU to monitor the presence of all the ingredients in the plant. Furthermore, OU certified dressing companies do not purchase compatible sources of kosher and non-kosher ingredients, once
the kosher source is used in an OU certified product. All equivalent raw materials used for nonkosher labels must be kosher approved as well. Checking for compatible kosher and non-kosher ingredients is an integral part of the RFR inspection.

Mixed plants (kosher dairy/non-dairy/nonkosher) must submit their formulas to the OU office for review. The company’s formulas are kept in an office file under strict confidence. The formula review allows for the confirmation of the
kosher pareve or kosher dairy status of the certified product. Due to the sensitive nature of the information handled by the OU office, at times companies may insist upon a legally binding non-disclosure
agreement prior to releasing any confidential information. The Orthodox Union is very sensitive to the security concerns of companies, and gladly respects this request.

The use of modern technology has also greatly facilitated the OU’s work in monitoring plant raw materials. Most plants are now capable of generating a where used report, which allows the OU to trace non-kosher ingredients and confirm that they are used in non-kosher labels only.

REVIEW OF LABELS
Salad dressing and sauce companies typically possess a plethora of kosher or non-kosher in-house and private labels. Extreme care and attention must be devoted to the graphic design of the labels, to ensure that the OU symbol does not inadvertently appear on a non-kosher product. To safeguard against any labeling error, companies will develop an internal system of proofreading, and should always verify that the OU symbol properly appears on a label. Reviewing all labels, whether kosher or non-kosher, for the presence of the OU symbol should be part of standard proofreading procedures. The OU RFR is especially careful to inspect all the labels at salad dressing plants due to the possibility of this type of serious labeling mishap.
Since the number of labels may be vast, plants often possess a label book that greatly facilitates the RFR’s inspection. The presence of a label book at the plant inevitably brings benefits to plant personnel as well, as it provides an organized and concise record of a company’s many labels.

It is not uncommon for companies to consider reformulating existing products. In these instances, it is imperative that the OU office be duly
informed, even if it does not involve the purchasing of new raw materials. Lack of communication in this area could result in an unfortunate mislabeling. For example, if a company intends to change a formula from pareve to dairy, proper notification given to the OU office will help guarantee that the product label will now correctly bear
the OU-D symbol.

PRODUCTION ISSUES
Common lines used for pareve, dairy and non-kosher salad dressings will not present cross-contamination concerns when production is cold, which is typically the case. However, product residues from previous runs do. Therefore, standard OU protocol requires that production on common lines follow a specific order. Typically, plants will begin running kosher pareve, followed by kosher dairy, with non-kosher run at the end of the day. This requirement provides additional protection to help avoid cross-contamination between pareve and dairy, kosher and non-kosher products, in addition to the CIP. However, production of sauces is commonly done hot, and in such instances lines must be segregated or require a special production to avoid cross-contamination from the line. Moreover, there is one stage of the production process for dressings that is hot, starch cooking. Starch cooking is common in the industry, although not uniformly done. OU
policy requires that all raw materials that are used in the starch cooker must be kosher and pareve. This requirement avoids any cross-contamination from the heat exchanger, if it previously cooked non-kosher or dairy ingredients.

At times mixtures may sit in holding tanks for extended periods prior to the production or filling of the product. Tanks that hold cold mixtures for a period exceeding twenty-four hours assume the status of those mixtures. If the mixture were dairy or non-kosher, the tank would be considered dairy or non-kosher. Salad dressing plants must therefore ensure that mixtures do not sit in a holding tank for too long a period, to avoid any potential complications.

The dynamics of the Orthodox Union’s supervision at salad dressing and sauce plants is undoubtedly highly complicated. The OU has risen to the occasion, and now certifies thousands of condiment varieties commonly found on consumers’ tables. Through meeting these many demands and developing an excellent working relationship with the plants, the OU services its certified companies and the kosher consumer by offering an unparalleled level of supervision.


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