In the world of kosher, labels are not just marketing tools or sources of information as to nutritional information or calorie counts. For the kosher consumer, labels – specifically, the kosher symbols that appear on them – serve as the guidelines and instructions that the end user relies upon to know the accurate kosher-status of the product, as well as how to properly use it.
For example, the presence of the OU D symbol communicates that the item is a dairy product and cannot be used with meat. It also indicates that use of this item would render the utensils and any product/food in which it is used in as dairy. The OU P informs the consumer that the item can reliably be used on Passover, the week in which there are restrictions that exceed the rules of kosher applicable throughout the year.
Consequently, a well-organized label room plays a highly critical role in maintaining a kosher program. Unfortunately, label rooms are often repositories for thousands of different labels, arranged in a chaotic order. To ensure that the kosher designations are correct, there must be a system in place for auditing labels.
Accurately auditing is a huge and time-consuming undertaking, time that few companies and RFR’s can spare. Perhaps one of the most effective methods that companies and RFRs have worked out over time is to have the plant affix a copy of the final product label to the batch sheet that the line operator or batcher fills out as he/she makes the product. This creates a direct connection between a particular formula and batch and the label that the product will bear.
In many cases, a situation that creates a need for specialized kosher symbols and labeling is rooted in an aspect of a product or production that is also of concern to a plant for other reasons. Therefore, the company flags prominently on the batch sheet itself. A prime example of this would be a dairy item, which requires special labeling with OU D for kosher reasons, but is also of concern to the plant since it is an allergen. Many plants will tag the formula for the dairy product with a number or code indicating dairy, or else visibly note the dairy status on the batch sheet, so that the operator will be aware of the allergen. This makes the dairy status of the item transparent, and it would stand in stark contrast to a label whose kosher symbol lacks the requisite “D”.
Similarly, if a non-kosher item produced in a primarily kosher plant has its non-kosher status clearly delineated on the batch sheet, the disparity between the batch sheet and the improperly printed label for that item bearing an OU kosher symbol, would/should immediately be obvious.
Although attaching a copy of the final label can be and often is done for the production file after the product has already been produced, doing this prior to production can be extremely advantageous, not just for kosher but also for a company’s internal controls. Affixing a copy of the final label to the operator’s batch sheet creates multiple levels of potential review where the mistake can be caught.
The chain begins with the scheduler, who affixes it to the batch sheet, and would/should notice the discrepancy immediately. It, subsequently, includes the line operator who batches/processes the product, the QA person who reviews the production and, ultimately, the RFR who audits the production records on his regular visit. This relatively simple solution forces a direct comparison between batch sheet and the label and visibly highlights any disparity between the two. OU Kosher has found it to be a most effective measure of insuring the integrity of the use of the OU symbol on a company’s product.