In the beginning – the first step to kosher certification
When a new company submits an application for kosher certification it sets a number of people and processes in motion. This article will take you behind the scenes at OU Kosher, from the time an application is received until the letter of kosher certification (LOC) is finalized. In most cases, well over 50 individuals are involved: poskim (legal scholars), rabbinic coordinators, RFR’s or mashgichim (supervisors), rabbinic and lay volunteer committee members, food technologists, computer experts and support staff.
To establish the status of a product, a complete application is submitted with a detailed list of ingredients and sources of supply, and then an on-site inspection of the plant where the product is made will be performed by an RFR.
Once the application is submitted, the OU Kosher New Company team assigns a Rabbinic Coordinator to review and shepherd it to completion. Assuming no immediate issues jump out, an email goes to the company explaining the certification process including an invoice for the initial inspection by an RFR, who evaluates the plant’s operations and eventually establishes guidelines for certification.
Looking closely at ingredients and production methods
The Rabbinic Coordinator chooses the correct Rabbi for each type of plant. The OU has technical experts in oils and emulsifiers, chocolate, snacks, dairy products, baby products, fish, flavors, chemicals, and many other types of processes in the food industry.
In addition, plants can be very complicated in terms of their equipment, pipes and utilities. A typical emulsifier plant, for example, may have 20 different types of machinery, which stretch over a span of half a mile. Consequently, the OU maintains experts in every corner of the food industry to make sure the correct protocols are in place to ensure that the food is in compliance with kosher law.
Dealing with raw materials
The application is simultaneously submitted to the OU’s New Company Ingredient department, which collects the raw material information listed on the application and enters it into our system, thus creating the Schedule A (approved ingredient list). In order for an ingredient to be approved, the raw material typically needs to be kosher certified. Even if an item has kosher certification, not all certifications meet the standards of the OU.
The OU’s database of kosher ingredients contains over 1 million entries, each of which was thoroughly reviewed before being added. Ingredients are categorized depending on the level of kosher supervision required and their dairy/ pareve (non-dairy)/ Pesach status. The flavor industry alone is highly specialized and uses thousands of ingredients to duplicate flavors found in nature. It is not unusual for certain flavors to contain 30 components, some of which may be other flavors that in turn must be broken down into their components. So certifying a flavor can involve researching over a hundred different ingredients— each of which requires certification.
The ingredient department vets all the incoming raw material lists and compiles a list of items they have questions or concerns about. An example would be a dairy artificial sweetener listed as a raw material in a barbeque sauce that is meant to be certified as pareve. The end product could not be labeled as pareve if it contained that item. Sometimes an application is missing key ingredients and they will mention that too. For example, if the final product is listed as yogurt and the raw material list doesn’t list carrageenan or gelatin (usually not kosher) then something is missing. All questions and concerns are emailed to the applicant to address.
The product list
The OU also has a product department. The application asks for a list of products to be certified. The product department for compiles the list and creates the Schedule B (product list).
The product department also reviews the proposed labels. Sometimes a company will apply for a private label — that is, a product made to be sold exclusively by another entity, such as a supermarket — to be included in the certification. In that case, the product department will check the label to make sure the distributor information is correct and create a Private Label agreement that commits the manufacturer and distributor to keeping the product kosher.
Once the procedures are approved, a contract is generated which includes the Schedule A, Schedule B, and Production procedures along with the certification fee. The contract is sent to the company that applied for their signature. Sometimes the applicant will have questions or request changes to the contract. These are then forwarded to in-house counsel, who expertly solves any issues that arise. Once the contract is signed and the fee paid, the company is ready to be certified. A local Rabbi is assigned to conduct the ongoing inspections which continue as long as the company is certified. Once this is all complete, the Letter of certification is emailed to the company along with the OU’s welcome packet. At this stage the company is authorized to add the OU kosher symbol to their product labels.