The RFR Who Wouldn’t Leave: Onsite Supervision Explained

Paul Pendelton of Paul’s Perfect Pies finally perfected his Pecan Praline Pudding pie –confident that prosperity would soon follow. He figured it was all systems go. He learned otherwise.

The product would be his first OU Kosher non-dairy item manufactured in an all dairy plant. If Paul planned on producing his pudding pie with an OU, and not OU-D (indicating to consumers that it was dairy-free), he would need onsite rabbinic supervision (referred to as Hashgacha Temidis).

In order to authorize the kosher status of the product, OU’s professionals would have to inspect the processing and labeling facilities to establish systems that would maintain its kosher integrity. A label marked OU-D or OU Dairy alerts the consumer that the product was produced on equipment that otherwise handles dairy or the product contains an ingredient, flavor, processing aid, enzyme, pro-biotic or any other element with dairy origins.

This heads-up proves critical for kosher consumers who (per kosher law) cannot consume dairy with meat, as well as for those who suffer from allergies to dairy products. Here is where Paul’s parve product poses a concern.

Since his plant handles dairy regularly, OU Kosher could not confirm that the parve product is made on exclusively parve equipment (e.g., pie pans and cooking vessels). We wouldn’t be able to determine exactly which pie plates are being used simply by viewing records. In addition, we couldn’t verify that the oven would be kosherized prior to parve production. Also, several proprietary parts of Paul’s parve product are similar to some of his dairy Pecan Praline items. Thus, the OU couldn’t independently substantiate that only the parve ingredients would go into his parve productions without having an onsite supervisor present to confirm the parve systems were being upheld.

In fact, most of instances where onsite supervision is required arise from the same issue; OU Kosher is not comfortable sanctioning that the kosher systems would be maintained without our own representative watching the production, as is the case with any deviation from standard practice, such as parve on an otherwise dairy line or kosher on a non-kosher line.

Other examples of required onsite supervision: 

Screen Shot 2017-01-30 at 2.26.48 PMFish fillet processing

In many OU plants, the removal of the skin from a fish (which in kosher law can often render it unidentifiable) would require onsite supervision. In order to run a production, the onsite supervisor would first confirm the plant doesn’t have any skinless fish prior to the start of production, he would verify that all the fish received are “skin-on,” of a kosher species, and that no other fish are introduced to the production or finished product-holding areas until the end of production. He might apply a signature or seal to the finished product to indicate to the recipient that the product was made with the rabbi present. OU Kosher may also issue lot-specific letters of certification to indicate the day’s production, and thus exclude products not made under these conditions.

Screen Shot 2017-01-30 at 2.26.57 PMPassover productions

The OU requires onsite supervision for most products certified as OU-P or OU Kosher for Passover. Sometimes the plant had been previously used for non-Passover products, requiring a kosherization prior to OU-P production, though OU-P production may require rabbinic supervision just to be sure. Onsite supervision is also essential when there are any small changes (even if they aren’t noticeable) in ingredients to suppliers approved for Passover production. The OU instituted the need for an onsite supervisor to act as an additional set of eyes to make sure Passover products are made with the utmost concern for Passover requirements.

Wine/Hard Cheese productions

Screen Shot 2017-01-30 at 2.27.04 PMDue to their sensitivity in kosher law, the formations of certain food products require onsite supervision. Wine production demands onsite supervision from the beginning of the grape harvest through the end of the bottling; this is to ensure that no addition of non-supervised wine is made and that the entire process is done in accordance with OU requirements. In the case of OU Kosher hard cheeses, the onsite supervisor may be asked to kosherize equipment, substitute dedicated-kosher equipment (for the usual pieces of equipment) or add the rennet to the processing. He may also need to apply special OU Holograms to each package to further guarantee his presence to the end-user of this product.

Screen Shot 2017-01-30 at 2.27.20 PMCompatible ingredients

To meet a kosher order, a plant might need to handle multiple editions of the same ingredient. They also might need to purchase a more expensive kosher version of an item (normally dealt with in-house) that wasn’t acceptable for use in OU products. Under those circumstances, an onsite supervisor may be required to confirm that only the kosher version is being used.

If a kosher glycerin is comparable to the non-kosher form, or the kosher beef gelatin would accomplish the same result as the non-kosher gelatin, the OU may stipulate that a rabbi be present for the production. Occasionally a plant that uses a dairy chocolate may need a parve chocolate for an OU parve production or is handling a kosher flavor that comes with a rabbi’s signature of seal. In such cases, onsite supervision would be necessary.

So, it’s not that the rabbi can’t tear himself away from the plant– although he certainly enjoys his work. It’s because he’s needed there.

Your OU rabbinic coordinator would be happy to explain why onsite supervision is required and offer viable options that your company may be able to use to avoid the need. Concerning Paul and his Perfect Pies, due to the presence of dairy on the production equipment, the ultimate decision was to revert to OU-D, despite the lack of dairy in the product. We wish him success.

Rabbi Chaim Goldberg has been manning the fish desk at the OU for 14 years, managing roughly 400 OU certified manufacturing plants and traveling to five continents to inspect and establish kosher protocols at processing plants of all types. Rabbi Goldberg’s tackle box can be found in his family home in Brooklyn, NY.