Fresh water is innocuous from a kosher perspective, but when reclaimed from a non-kosher production it can have serious implications for future kosher productions. Here are four cases where a company has reclaimed or reused water from one production for use in another. Read carefully, because plant processors themselves are often unaware of the consequences of these recovery systems.
Vapor Scrubber Water
In the course of vinegar production a significant volume of vapor escapes into the atmosphere. In some regions, like southern California, environmental regulations mandate that a vinegar manufacturer capture the vapors. Some manufacturers, even without regulatory pressure, choose to recover the otherwise lost vapors and return them to the vinegar stream.
A non-descript column called a vapor scrubber is nestled above each vinegar manufacturing tank. A scrubber is composed of packing material that absorbs the vapors. Water courses through the material, stripping it of the condensed vinegar.
If a company is manufacturing both kosher white distilled, and non-kosher (red or white wine) vinegar, both types of vinegar vapor will be recaptured. What will the company do with all the vapor-laden water? Sending it to the drain not only means losing perfectly usable water; typically municipal fees are associated with wastewater treatment.
The most efficient usage is for the production of white distilled vinegar, which is essentially made from ethanol, water and nutrients. This in fact was the procedure at a vinegar manufacturer a number of years ago, until a sharp-eyed and tenacious field representative realized what was happening.
Separation Column at an Animal and Vegetable Fatty Acids Plant
What happens, specifically, is that oil or fat is pumped into the bottom of the column and water is pumped into the top, while steam is being injected into the column. Oil makes its way up the tower and water sinks to the bottom. The collision of the two, together with assorted perforated metal trays and intensely high temperatures, forces the oil to split into its two components, fatty acids and glycerin.
The standard switchover from tallow to vegetable processing allows for something called a clean-break, and uses the same water that induced the splitting of tallow to induce splitting of the coconut oil. The non-kosher water, freshly cooked with tallow, is literally the same water used for the coconut oil processing.
COW (Condensate Of Whey) Water
What about the water used for cleaning, or for kashering? At many cheese companies separation technologies remove fat and protein fractions from whey, which leaves over lactose, minerals, and water. The permeate stream can be further separated, leaving what is referred to in the industry as “polished” water.
This water is so commonly used in the industry it’s been honored with a nickname: COW (Condensate Of Whey) water. The water is dairy and cannot be used in kosherization for equipment that will be running a non-dairy (pareve) product; if the water comes from non-kosher whey it is considered non-kosher. Typically COW water is used in cleaning equipment, although in one case an OU representative has reported seeing it used in the production of fruit juice.
Wheat and Corn Starch Processing
Passover productions are also vulnerable to creative reuse of water. A European processor of corn starch was interested in having its product certified for Passover as non-chametz (free of wheat and other grains). Separate from the corn starch division is a wheat starch division.
Wheat starch production requires a wheat/water slurry, in which wheat is cooked at about 160°F. The slurry is then spray-dried, a process that removes the water component. This bonus water is used in the corn starch production.
There’s yet another way water can be recovered from wheat starch processing. Alpha amylase is added to wheat starch to initiate decomposition to glucose (dextrose). Water is a byproduct of this process. This water too is recovered and has multiple applications, including use in corn starch production.
What is the implication? Corn starch, which appears to be straightforward non-chametz, is (when originating from this manufacturing plant) chametz. The corn starch could not be certified as non-chametz.
OU representatives are trained to be attentive to the creative usage of resources such as water to ensure it does not contravene OU standards. If you have an opportunity to reclaim or reuse a byproduct that would otherwise be lost, contact your RC to find a way of resolving the issue without compromising the kosher program.
Rabbi Gavriel Price services the transportation, ingredients and flavor industries at the Orthodox Union. A frequent contributor to BTUS, his “The OU Symbol: Handle with Care,” appeared in a recent issue.