It is without question that the primary objective of companies which commit themselves to kosher certification is to broaden their market and increase sales. However, the nature of the kosher program might also restrict a company from pursuing other markets that could compromise its integrity. For example, for companies that typically manufacture OU-D certified products, pursuing a pareve non-dairy market may be a total impossibility due to a host of difficulties, including compatibility of ingredients and equipment, as well other utility concerns. Moreover, companies that cater to a non-kosher market might consider kosher certification for products that qualify, but cannot do so at the expense of sacrificing the non-kosher line.
To accommodate the needs of OU certified companies and the kosher consumer, the Orthodox Union allows for a special production under the careful watch of an on-site field representative. Although placing demands on the OU RFR and plant personnel, these special runs give companies and plants the flexibility to certify products which would be impossible under ordinary circumstances. With the proper safeguards and controls, what was once perceived as unfeasible can become reality.
The “kosherization” of a production line is often very involved, and at times is the most complicated aspect of a special run. According to kosher law, equipment assumes the status of the product it manufactures. For example, if a non-kosher item is produced on a line, the status of the line becomes non-kosher. Subsequently, all products manufactured on that line will be rendered non-kosher as well. This is also the case with equipment which manufactures dairy products. The objective of the kosherization is to sanitize equipment in a similar fashion to a plant’s standard CIP or COP procedures, thus bringing the equipment’s status back to neutral.
However, Orthodox Union requirements are often more rigorous than the typical CIP or COP. The machinery and equipment must be thoroughly clean of residue from previous productions before the kosherization can begin. This is not always a simple task. Rabbi Moshe Perlmutter, a New Jersey OU RFR with expertise in the area of kosherizations, acknowledges that “one of the most challenging aspects of a kosherization is the first step, ensuring that the equipment is properly cleaned from residue of prior non-kosher runs.” A kosherization will not commence until an OU field representative assesses the equipment’s cleanliness, and confirms that it meets OU standards.
The kosherization method of machinery varies, depending primarily how the equipment is used. Equipment that manufactures with dry heat, such as an oven, is kosherized by exposing it to dry heat at an intense temperature. Lines used “wet” are kosherized with boiling water. An OU RFR must be meticulous when assessing whether the water actually reaches boiling. As Rabbi Perlmutter points out, “One could mistakenly think that water in a kettle reaches boiling by glancing at a jacket’s gauge of a steam jacketed kettle, which is only a reflection of the jacket’s heat not the water. Or, if a company uses direct steam injection during the kosherization of a tank, bubbling water is not an indication of boiling. It is comparable to blowing into chocolate milk with a straw.”
Ordinarily, a downtime of twenty-four hours is required before the kosherization may commence for “wet” lines, but may be avoided when caustic is run through the lines along with the boiling water. Downtime is not required for lines that are kosherized with an intense dry heat.
Kosherization is only required when a line’s production is hot. Lines used at ambient temperatures do not require kosherization, although they must still be thoroughly cleaned to remove any residue from previous runs. The one exception to this rule involves tanks or totes used to contain wet product mixtures for a minimum period of twenty-four hours. In these rare instances, kosherization is accomplished with boiling water.
Kosherization can be highly complicated. Accordingly, the Orthodox Union ensures that the on-site supervising rabbi must possess not only an expertise in kosher law, but a clear understanding of equipment and production.
REVIEW OF INGREDIENTS
Raw materials used for a special production are pre-approved by the OU office and attached to the plant’s Schedule A. The on-site RFR at the plant reviews the ingredients and matches them to the Schedule. The meticulous review and watch by the RFR is crucial, since the plant may use a compatible non-kosher or dairy version of an ingredient contained in a non-certified product. If an item does not appear on the Schedule A, production cannot begin until the OU office approves that ingredient. Due to the time constraints faced by plant personnel during these special runs, it is critical that all ingredients intended for OU certified labels are submitted to the Orthodox Union office in a timely fashion for approval.
It is common practice for the on-site OU field representative to sign the labels of industrial items that are produced under special supervision. In these instances, the “Rabbi’s Signature” is listed on the letter of certification as an additional restriction. This requirement informs all plants that use this raw material, and their supervising RFRs, that the product must be manufactured under special production and an on-site RFR was present. If a company or supervising RFR discovers that the signature is absent from an ingredient whose LOC requires it, the matter must be handled with the utmost urgency. A call must be placed immediately to the manufacturer or distributor of this item, and a lot letter for this product must be obtained from the certifying agency.
The signature can typically take several forms. It might simply be a handwritten signature by the on-site field representative. However, when large volumes of product are manufactured, signing each label by hand can become very labor intensive. Rabbis may also use stamps, or special stickers that cannot be reproduced.
CONTROL OF LABELS
Since a special production can only occur at specifically designated times in the presence of a supervising rabbi, it is critical that excess inventory of OU labels is carefully safeguarded. This is typically done by placing any extra OU labels in a dedicated area, which is locked and sealed by the supervising RFR. Only the supervising rabbi has access to the key of the storage area. When labels are computer generated, the OU has employed in some instances a system where OU labels are restricted and can only be printed by a company’s computer for specific code numbers. These procedures guarantee that the Orthodox Union has sole control over the labels and the usage of the OU trademark.
During the week-long festival of Passover, the kosher community is restricted from consuming many items that are acceptable during the rest of the year. Ingredients that are ordinarily considered kosher might be prohibited during this time. Lately many companies have realized that there is an opportunity to pursue a relatively open market that would further strengthen their base and increase sales. This has resulted in a recent widespread boom of Kosher for Passover certified products.
Due to the sensitive kosher nature of the Passover period, items certified as kosher for Passover are commonly manufactured with the presence of a supervising RFR. This is typical unless production at a plant is considered inherently kosher for Passover all year round. The rigors of a standard production are all the more present for Passover certified labels. However, companies ultimately reap the benefits of greater profits.
OTHER SPECIAL PRODUCTION CHALLENGES
Cooperation from company personnel is key to a successful special production. Therefore, it is crucial that plant personnel clearly understand OU requirements and protocol. Rabbi Yitzchak Friedman, a Maryland OU RFR, comments, “I always make sure that plant personnel clearly understand the process, and not assume that they are relying on instructions from a predecessor, or supervisor. When possible, written instructions are even better and give operators something to review and work with.”
Moreover, sometimes challenges of manufacturing on a special production basis occur even before the OU RFR sets foot through the plant’s door. Gary Pantelis, QA of Michigan Dessert Company, points out another aspect from his experience of producing dry dessert mixes under special supervisions. According to Gary, “We don’t have a real problem when it is an issue of segregating lines, equipment, or production schedules. The challenge is working around the logistics of arranging a production and coordinating our receipt of orders, getting a new product approved, and scheduling a production date in an expeditious manner to meet our customers’ needs. The OU has been very responsive and helpful in this regard.” New products manufactured on a special supervision basis also need to be reviewed and approved by the OU office beforehand. However, the OU commits itself to processing requests as quickly as possible to allow certified customers to meet their orders.
The dynamics of a special production are undoubtedly highly involved. The OU has risen to the occasion, and allows companies that ordinarily manufacture non-kosher or dairy products, the flexibility to pursue kosher or pareve markets. Through meeting 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.