The Saga of the Dixie Belle Artificial Cheese Flavored’ Moon Cookie

May 4, 2004

You have just arrived at the San Juan airport in Puerto Rico after a long day of business negotiations. Famished, you are looking forward to the kosher meal that will be served on the plane, only to discover that your flight has been delayed for five hours. You search the snack area desperately for some morsel to satisfy your rumbling stomach. Suddenly, your eye catches the familiar OU on a box of Dixie Belle Artificial Cheese Flavored Moon Cookies1. You are ecstatic, and as you relieve your hunger pangs with these delectable cookies, you resolve to thank the people at the Orthodox Union who unknowingly saved the day for a stranded traveler.

How many people do you need to thank? Well, there is the mashgiach who visited the plant and a rabbi at the OU office who oversaw the supervision as well. Two thank-you notes will do it-right? Wrong. If you wanted to properly thank the entire team of people who participated in the endorsement of these cookies, you would have to send thank you cards all around the country to well over fifty individuals. Behind the two deceptively simple letters of the OU stands a network of poskim, rabbinic coordinators, mashgichim, rabbinic and lay volunteer committee members, food technologists, computer experts and back up staff who work together in a synchronized effort to provide reliable supervision for an ever-growing array of kosher food products.

Herein lies the tale of the Dixie Belle Artificial Cheese Flavored Moon Cookies. Names have been changed to protect the confidentiality of sensitive information.

One day in September of 1990, the New York office of the OU received a call from Bill Thomas, president of the Dixie Belle Cookie Company in Talapoosa, Georgia, inquiring about the feasibility of certifying his company’s products.

This call was directed to the “New Company Department” of the OU Kosher Division. Under the leadership of Rabbi Menachem Genack, who heads the Kosher Division, the staff has grown to include 22 full time Rabbinic Coordinators.

Because of the wide range of activities performed by the Kosher Division, each of these administrators has been assigned a specialized area of responsibility. In essence, there are six departments at the OU headquarters: Halachah, Ingredients (Ingredient Approval Registry – IAR), Private Labels, Pesach, New Companies and Maintenance of existing companies. (The last department is further divided into industries such as oils and emulsifiers, chocolate, snacks, dairy products, baby products, fish, flavors, etc.) As we describe the certification process, it will become clear how the application passes through different departments during various stages of the initial negotiations.

The starting point, however, was for Bill Thomas to speak to Rabbi Moshe Bernstein, who heads the New Company department. Knowing very little about kosher food, Thomas received the first of many explanations from Rabbi Bernstein on the meaning of “kosher” and the nature of OU supervision: products are kosher when they contain kosher ingredients and are produced on kosher equipment. To establish the status of Dixie Bell Cookies, two things would have to be done: a) An application would have to be submitted with a detailed list of ingredients and sources of supply. b) An on-site inspection of the Dixie Belle plant would have to be performed by an OU representative to evaluate the use of the equipment and the manufacturing process of the cookies. Because Mr. Thomas was anxious to receive certification as soon as possible, an application was immediately faxed to him, and later that day he faxed back a complete listing of ingredients and their sources.

The first stop for a new application in the OU office is at the Ingredient Approval Registry (JAR). Food technology has expanded so rapidly in recent years that there are tens of thousands of ingredients in use in the food market. The OU’s data base of kosher ingredients which contains fifty thousand entries, is the largest of its kind in the world.

This data base stands at the center of the OU operation. Kosher certification is based on evaluation of ingredients and the data base gives the OU access to up-to-date ingredient information. When the status of an ingredient changes, a computerized “where used” report can be generated immediately so that companies can be contacted and advised that the ingredient is no longer acceptable. It has taken years for the OU to build up this data base of ingredient information. Before a new ingredient is entered into the data base, it is reviewed carefully. Often, contacts are made with field mashgichim who have developed ingredient expertise by visiting thousands of plants. Sometimes it is necessary for the staff microbiologist to do technical research before approving an ingredient. Not infrequently, a decision about an ingredient cannot be made without discussion with Rabbi Yisroel Belsky and Rabbi Hershel Schacter, the halachic consultants of the OU.

Management of the IAR is a complex task. Every week, hundreds of ingredients are added to the data base and thousands of ingredients are linked from the master ingredient listing to specific companies. Ingredients are categorized as one of three different groups depending on the level of kosher supervision required. In addition, the dairy/parve/Pesach status of ingredients must be determined and entered into the computer. Two managers and a staff of six input operators are constantly busy updating this information.

At first glance, the ingredients in the Dixie Belle Cookies seem rather straightforward: sugar, wheat flour, com syrup, sodium bicarbonate, powdered eggs, hydrogenated vegetable oil, sodium stearoyl lactylate, dough conditioners, and artificial cheese flavor. The first four ingredients are acceptable from any source, while the last five ingredients require further investigation.

Let us begin our investigation with the artificial cheese flavor. The flavor industry is highly complex and sophisticated and utilizes thousands of esoteric ingredients to duplicate flavors found in nature. It is not unusual for a cheese flavor to contain thirty components. Some of these components may be other flavors which, when broken down into components have their own sub-units. Thus, certifying a flavor may involve researching over a hundred different ingredients. Because flavors are compounded from a wide range of ingredients, natural and artificial flavors always require certification. The OU certifies approximately twenty flavor companies. The certification of flavors is a highly specialized area and, for that reason, a special unit of five people deals exclusively with flavor certification.

The artificial cheese flavor utilized by Dixie Bell is manufactured by the Wide Range Flavor Company in Edison, NJ. This company manufactures eight thousand different formulas. The OU certifies this company on a per flavor basis. When the company seeks OU certification on a particular flavor, a copy of the formula is submitted to the flavor department for review. To date, the OU certifies 1200 flavors made by this company, but the artificial cheese flavor is not one of them. In order to process the Dixie Belle application, the Wide Range Flavor Company submitted the cheese flavor formula to the OU. The cheese formula contains the following ingredients (In truth, flavor formulae are highly confidential and I created this flavor myself): vanillin, ethyl vanillin, aldehyde, gamma decalactone, ethyl butyrate, geranyl acetate, civet, melanol, propylene glycol, vanitrope, diacetyl, benzo dihydro pyrone, artificial buttermilk flavor #3706, artificial cheese flavor #7406, artificial cream flavor #4375.

The reader will note that the fmal three ingredients are flavors, which must be further broken into their respective components. After reviewing all the ingredients, everything checked out except for civet, which is a cat extract used as a flavor enhancer. Rabbi Bernstein discussed the problem with the Wide Range Flavor Company and arranged for a kosher variation of the flavor to be made for the Dixie Belle Company. It was also determined that the artificial cheese flavor was pareve, which meant that the cookies could be labeled as pareve and have a wider range of kosher use.

The egg powder used by Dixie Belle proved to be more problematic. The egg powder was made from liquid eggs, which were under reliable kosher certification. However, the liquid eggs were sent to the Davies Spray Drying Company in North Dakota to convert the liquid eggs into a powder through a spray drying process. A spray dryer is a huge cylinder-type chamber which is used to convert liquids into powders. Spray dryers are expensive machines which generally cost a few million dollars and in order to service the widest range of customers, almost all spray drying companies do contract drying of both kosher and non-kosher products. Ordinary methods of kashering were not practical in this case: the OU halachic consultants ruled on a reliable alternative method which could be applied after 24 hours of down time.

The IAR investigated the status of this egg powder and found that it was under the supervision of “Rabbi Plonni.” The OU had no previous contact with Rabbi Plonni and therefore it was necessary to establish the reliability of his supervision. A phone call was made to Rabbi Plonni to discuss his method of supervision. Rabbi Plonni required the kashering of the spray dryer between non-kosher and kosher, but did not have a mashgiach present to observe the process. The OU viewed this supervision as inadequate and rejected the product. However, Dixie Belle was sent a computer generated list of alternate approved sources and Dixie Belle arranged for a new source of its egg powder.

Sodium stearoyl lactylate is an emulsifier which is used in the cookies to facilitate the proper blending of all the ingredients. Emulsifiers can be derived from animal or vegetables sources and as a result, require reliable supervision. The particular sodium stearoyl lactylate used by Dixie Belle is manufactured by a company in Brazil and is under the supervision of the “Sure-Kay.” Many companies had made requests to use this product, and the OU recently sent Rabbi Chaim Goldzweig to the plant to review the system of supervision.

Rabbi Goldzweig is a legendary kosher figure who resides in Chicago, and has worked for the OU for almost 30 years. He was specifically chosen to perform this inspection because of his thorough knowledge of modem food technology. Emulsifier plants are particularly complicated because of the sophisticated equipment and the complexity of the chemical processes that are involved in emulsifier production. A typical emulsifier plant may have twenty different types of machinery which stretch over a span of half a mile. Walking through the plant, an observer will not see any raw materials, as everything is contained in huge tanks, reactors, pipes, distillers, and other assorted machinery. Supervision of industrial kosher is far more difficult than supervision of a local restaurant or bakery and for that reason the OU employs a staff of approximately 15 field supervisors who visit plants around the world for the OU. Each one of these mashgichim has had years of training and experience, and has been exposed to a wide range of manufacturing facilities. Rabbi Goldzweig has trained many of these professional mashgichim and is universally recognized for his expertise.

The particular manufacturer of the emulsifier in question produces both animal based and vegetable based emulsifiers. The difficulty inherent in the supervision of this type of operation is that both systems run side by side. There are miles of pipes which criss-cross each other and it is not an easy task to make certain that the two systems are not in some way connected. Rabbi Goldzweig spent three days reviewing the entire operation, and concluded that the systems were properly segregated and that the mashgiach had the necessary skill to oversee the operation. Based on Rabbi Goldzweig’s recommendations, the emulsifier was approved for the Dixie Belle Company.

The dough conditioner used by Dixie Belle provides an enzyme which, when added to flour, produces sugars necessary for the yeast fermentation. Dixie Belle utilizes a specialized dough conditioner which contains an enzyme called CL-Y2, manufactured by the Mitong Company, an OU endorsed company in Hong Kong. Much of the biotechnology industry is in the Far East and Rabbi Shmuel Lazar Stem from Los Angeles, California spends much of his time in the Far East inspecting plants for the OU. During his visit to Hong Kong, Rabbi Stem stopped at Mitong, reviewed the status of the CL-Y2 enzyme and faxed back a report with details of the enzyme production. After halachic review, CL-Y2 was approved for kosher use.

Finally, Dixie Belle was using vegetable oil from the Oregon Oil Company. This company produces animal and vegetable oil on the same machinery without any clean-up between products. There was no supervision in the plant and this source was rejected. There were numerous alternate sources from which Dixie Belle found a suitable substitute.

Concurrent with the review of ingredients, Rabbi Bernstein arranged for an initial plant inspection of the Dixie Belle Company. One of the OU field mashgichim in the South was contacted to carry out the inspection. In order to ensure that the initial inspection covers all possible problems, the OU headquarters has designed a ten-page questionnaire which is completed by the inspecting mashgiach. It was also important for the mashgiach to establish the practicality of certifying the product as pareve, as the Dixie Belle company also manufactures a dairy butter cookie.

In addition to completing the questionnaire, the rabbi wrote his own comments. “The dairy and pareve cookies are produced on two incompatible lines. The company maintains very precise records which detail what is made on each line with exact times and dates. Therefore, there are three ways we can control the segregation of lines:
a) incompatibility of equipment
b) spot inspections by mashgiach
c) review of production records by mashgiach.”

There was another issue raised by the rabbi. Occasionally, the dough does not mix well and is reworked in order to achieve the proper texture. In these instances, the dough is emptied from the mixing tank into troughs where it is held until it can be run through the system again. The company uses the same troughs for both the dairy and pareve doughs. Does this practice compromise the pareve status of the cookies? It was decided that this question would require further attention from the halachic consultants.

With the ingredient review completed and a detailed initial inspection report in hand, Rabbi Bernstein was now ready to bring the application to committee. The OU is structured with a careful system of checks and balances and every new application is reviewed by two committees.

The first committee to review the application was that of the Kosher Commission of the Rabbinical Council of America. Every month, Rabbi Emmanuel Holzer, Chairman for many years, convenes this committee of approximately ten RCA rabbanim. The committee meets with members of the Kosher staff and discusses each application in detail.

Copies of the initial inspection report of Dixie Belle were distributed to members of the committee and all facets of the application were reviewed. In particular, the RCA discussed the issue of the common troughs for the dairy and pareve rework. The RCA recommended that the company institute a standard procedure between products. Rabbi Bernstein presented the recommendations of the halachic consultants as well. Questions were raised and discussed in detail. Satisfied that all concerns had been addressed, the RCA gave its approval the application.

The Joint Kashruth Commission was the second committee to review the application. This committee, as the name implies, is a joint group which is composed of RCA rabbanim and lay leadership of the OU. It is headed by Mr. Julius Berman, a former President of the OU with many years of distinguished Jewish communal service. This committee meets with the staff and reviews policy issues that relate to every application. Rabbi Bernstein raised the following policy question to the committee.

“In addition to making the Cheese Flavored Moon Cookie on their own brand name, Dixie Belle plans to produce a private label for Great Price Supermarkets. Great Price has another source for a natural cheese flavored moon cookie which is not kosher. As a general rule, when we approve a private label, a special private label agreement is drawn up between the OU, the manufacturer and distributor. The manufacturer agrees not to transfer the labels to a non-OU plant. The distributor agrees not to produce a parallel product which is not kosher, in order to avoid consumer confusion. Here is the question: Is there enough of a distinction between Great Price Natural Moon Cookies and Artificial Cheese Moon Cookies to ensure that consumers who see the OU on the artificial cheese cookie will not accidentally purchase the non-kosher cookie?”

A spirited discussion ensued. Some members of the commission felt that natural and artificial are sufficiently distinct, while other members disagreed. One of the staff members suggested that the two cookies have different color boxes which would minimize the possibility of error. This recommendation was accepted and the application was approved.

Rabbi Bernstein was now ready to put the final touches on the application. A tailored contract was drawn up for the Dixie Belle Company which included a list of approved ingredients and products and stipulated specific requirements. The contract was then sent to Bill Thomas. Once signed, a mashgiach was assigned to the plant and he was given specific instructions about his responsibilities and the frequency of his inspections.

From this point onwards, a Rabbinic Coordinator specializing in baked goods will oversee all aspects of the Dixie Bell supervision. If Bill Thomas wishes to add a new ingredient or product, his request will be forwarded to his Rabbinic Coordinator. If the mashgiach discovers any irregularities during his inspection, the information will be reported to this department.
By November, 1991, everything was finalized and two months after the application was submitted, the OU appeared on Dixie Belle Cookies. The next time you are in a remote location (or even at your local grocery) and you see an OU on a food item, you can ponder the enonnous efforts and the many, many people who enabled it to be there. We hope you savor every bite – and you don’t even have to send out the fifty thank-you notes.

1 “Dixie Belle” and the cookie product mentioned are fictitious.


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