Ask the Rabbi
BY RABBI CHAIM GOLDBERG
Q: My company cuts pollock on a floating processor in Alaska (a large fishing vessel which also has the ability to process the catch onboard). We make a fish oil out of the waste, and we have a customer that would like the oil to be OU certified. Having a rabbinic supervisor onboard the vessel is inconvenient (especially if we wish to use multiple floating processors). Is it possible to certify fish without a rabbi on board? What are your concerns, and how could we address them?
A: Whenever OU Kosher certifies a product, there are several considerations which must be addressed. Assuming we can address all of them sufficiently, we would potentially be able to certify the item. Let’s discuss some of those issues:
• Non-kosher fish: We are always concerned with the presence of non-kosher ingredients in a manufacturing plant. A bakery which has lard lying around, a candy manufacturer which colors its product with carmine or a French fry plant which fries in tallow are all concerns. In a fish plant, our primary concern is the presence of non-kosher fish in the plant. This includes by-catch (incidentally occurring species which were not the target catch), which must be handled in a way that doesn’t affect kosher production. If your plant can show that non-kosher fish need to be removed for business reasons, or that the amount of by-catch is negligible even in the worst-case scenario, we may be able to certify the product.
• Other seasons: Fishing vessels rarely fish for a single fish (whose season might be for a few weeks per year). What does your vessel fish for in the off-season? Is it cod, herring, tuna or salmon? Is it crab or shrimp?
• Additives: what else is added to the oil on board? Are there any anti-foam agents, antioxidants or other items that might affect the kosher status of the oil?
• Off-loading: Once produced on the vessel, how is the oil off-loaded? Do you pump into brand-new drums, flexi-tanks or iso-tanks? Do you pump into railcars or trucks directly? How could we track the delivery of the oil to confirm the oil received was the oil produced under OU certification?
• Blending: Fish oils are often blended with oils from another species to achieve desired levels of DHA/EPA. What do you blend your oil with? How can we guarantee the integrity of the product before it is sent to the secondary producer?
In addition to the concerns about the oil, we also have some concerns about the handling of the supervision itself, such as:
• OU policy requires unannounced inspections. How could we facilitate that on a floating processor?
• How long would a rabbinic field inspector need to spend once on the vessel (assuming he is unable to swim the hundreds of miles to shore)?
• Are there appropriate accommodations for the rabbi to be safe/comfortable during his stay onboard, including the ability to store and consume his own kosher food?
Assuming all these questions could be answered favorably, we should be able to certify the product.
RABBI CHAIM GOLDBERG HAS MANAGED THE LION’S SHARE OF OU CERTIFIED FISH COMPANIES
FOR 11 YEARS, AND HAS REVIEWED THE OU KOSHER PROGRAMS IN FISH FACILITIES ON FIVE CONTINENTS, EARNING FREQUENT FLYER STATUS ON TWO AIRLINES THIS PAST YEAR. RABBI
GOLDBERG STORES HIS PASSPORT IN BROOKLYN, NY IN A FORT HELD DOWN BY HIS WIFE, THREE CHILDREN AND QUAIL.