Ever since that red-letter day in 1923, when the first OU symbol appeared on that historic can of Heinz beans, the Rabbis of OU Kosher have faced a formidable task: explaining kosher to kosher-certified companies.
While this might sound strange at first, it is really to be expected. Companies become kosher-certified because they recognize that displaying the OU symbol on their labels will open up a vast new market of smart, savvy and passionate consumers. However, they often embark on certification with little to no background, knowledge or understanding of what kosher is or means. Relating to the whole concept of kosher, and learning the OU system of certification, is totally new to them. And, since effective kosher certification involves the cooperation and acquiescence of the certified company, effectively explaining kosher is a prerequisite, not an option.
Over the course of nearly a century of dealing with food and product manufacturers, the OU has learned that there is no one way to address this challenge. Indeed, each company approaches kosher certification in its own way, and each company needs direction in a manner consistent with its own way of doing things. In a way, the approach OU Rabbis take toward explaining kosher to companies is modeled after the method the Passover Haggadah offers to explain the story of the Exodus. The Haggadah speaks to the Four Sons. OU Rabbi’s address…
…The 4 Companies:
one Overly Regulated,
one Simple, and
one that Knows Not How to Ask.
The Wise Company: “Just the Facts, Sir”
What does the Wise Company say…?
“Rabbi, can you please provide us with a comprehensive list of the standard operating procedures, good manufacturing practices, raw material specifications, temperature parameters, labeling constraints, critical control points, material handling protocols, batch sequencing restrictions and all other relevant protocols that you say are now required of us in order for us to be in compliance and produce kosher products?”
When the OU Rabbi arrives to inspect a facility, his main interaction is generally not with the production staff or plant management. Although it may seem surprising, the most common point of contact for OU Rabbis in a factory is the Quality Assurance team. QA departments are responsible for implementing and monitoring procedures, standards and specifications aimed at meeting a company’s food quality goals, and kosher falls neatly into their domain.
And you shall respond to them…
“…by providing all the requested information, procedures, protocols, rules and regulations as completely and comprehensively as possible, up to and including the appropriate size and placement for the OU symbol on the product label.”
The best strategy for implementing kosher procedures in a plant is to integrate them into the facility’s standard operating procedures and make them simply one of the many requirements the plant maintains to achieve all the quality standards their products already meet. Most or all of the areas, functions and aspects that could impact on kosher and which need to be audited by the mashgiach on his visits to the plant fall under the domain of Quality Assurance. To facilitate this integration, the OU formulates its kosher requirements in a manner that enables them to blend seamlessly into the normal functioning of a plant. This is not at all a simple task; it is a tremendous challenge to take complex halachic parameters and translate them into structured, step-by-step, detailed written procedures that a company can use to regulate their ingredients, processes and equipment. The procedures must be expressed using the same terminology, and technical details must be discussed in the same context, as the company uses with regard to all the other aspects of its productions. By synthesizing the broad practical knowledge of equipment and technology that OU Rabbis possess, with their detailed familiarity with the intricacies of halacha, the OU transforms kosher into a defined set of specifications that the company must meet in the course of its regular operations. The focus is solely on the “what,” not the “why,” since, at the end of the day, it is the “what” that the OU Rabbi translates into practical process and procedure.
The Overly-Regulated Company: “It’s Not What You Think”
What does the Overly Regulated Company say…?
“Rabbi, what are all these extra regulations, restrictions, requirements and regimens, practices, parameters and protocols — all of which are in addition to the excessive, redundant and unnecessarily burdensome rules of SQF, HACCP, ISO 9001, BRC, Organic, Non-GMO, IFS, FSSC, and other GFSI*-related certifications that we already are being forced to maintain — that you say are now required of us in order for us to be in compliance with kosher?”
This factory sees the kosher procedures as additional and burdensome rules and as being something “that you say are now required” — YOU say they are now required — but THEY do not necessarily agree! From their perspective, the extensive set of food safety regulations they already adhere to should be more than adequate to insure their products are kosher, without the need for extra OU rules.
It appears, though, that the Over-Regulated company asks practically the same question as the Wise company. In reality, the questions could not be more different. The Wise company relates to the kosher regulations as just that — regulations for maintaining kosher. They accept them as they are and integrate them into their standard operating procedures. The Overly-Regulated company, however, views the kosher regulations as a restatement of procedures they already follow and they minimize them as being redundant.
And you shall respond to them…
Although kosher requirements may, on the surface, appear to mimic other procedures you already adhere to in your existing quality program, and seem to address the same points, they are really designed to address and remedy issues that are unique to kosher. Applying your present practices to kosher cannot ensure the kosher status of the product; in fact, in some instances, using your standard operating procedures with kosher products could actually render them non-kosher!
Making kosher relevant can be a double-edged sword. For all the advantages of putting kosher in a familiar framework, there is a risk created that it will seem too familiar, and be perceived as something that it is not. A prime example of this is kashering. Kosher rules require that there be a kashering process, which entails flushing the equipment with water at a boiling temperature of 212°F between dairy and parve. The purpose is to purge any absorbed ta’am (flavor) from the walls of the equipment. Since dairy is an allergen, many companies automatically assume that the kashering requirements are intended to ensure that the equipment has been completely cleaned of the allergen and that all dairy residues have been removed. The plant already has an equipment-washing procedure in place (at only 165°F), which includes using a caustic soap, that they implement after running dairy. Following that wash, they test the equipment for the presence of dairy allergen and prove that no dairy remains, even at a level of X parts per million. If the company assumes that the purpose of kashering is to guarantee no actual dairy residue remains, it is understandable that they would view the kosher requirement to wash at 212°F as unnecessary since the regular wash has, from their perspective, more than adequately resolved that concern. In this situation, the Rabbi’s primary objective is to guide the company toward relating to kashering as a totally different standard, driven by its own set of parameters that may look familiar, but are actually quite unique. Once the plant appreciates this simple but subtle distinction, they are able to adapt to and integrate kosher rules easily and efficiently.
The Simple Company: “It’s Kind of Like…”
What does the Simple Company say…?
“What is this?”
There are numerous ways that a company will pose this question: They might ask “What is this?” Or, perhaps “What is this?” Possibly, “What is this?” Or, maybe even, “What is this!?” No matter how they ask, or where they put the stress, the underlying message is the same: they are lacking a context for doing what they are being asked to do and are feeling lost. In the end, asking “What is this?” is essentially another way of asking “why?” This is more common in smaller companies, which tend to be less formal and have a more personal element to them. These companies often feel a heightened sense of connection between themselves, as producers, and the consumers that use their products. The Simple Company does, of course, still run on rules, but it is motivated by meaning. They tend to ask “What is it?” before asking “What do we need to do?” For them, the “why” is part of defining the “what.” Explain kosher to them in a way they can relate to and understand, and full compliance will follow.
And you shall respond to them…
The kosher requirements date back to the time of Moses, and following them is essential to making your product kosher. These rules have been adapted and refined over the centuries by the scholars, ensuring that they will always be relevant to the realities of the day, but they are firmly rooted in the same fundamental principles that were fixed 3,000 years ago.
Portraying kosher to this company in an inherently religious context is important, but it necessitates striking a delicate balance. Since religious requirements are fundamentally a system of beliefs, not something that can be reasoned with or disputed, compliance is easier. However, framing it solely in a religious context can be counterproductive, since it evokes a sense of kosher as something more mystical than real, which can diminish a plant’s appreciation of the very real consequences potentially incurred from kosher mistakes. It is especially challenging when dealing with concepts that are fundamentals of kosher but might seem to be somewhat counterintuitive. A concept such as basar b’chalav, where two permitted materials such as milk and meat — both accepted items when used alone — create a non-kosher mixture, can be extremely confounding to the uninitiated. Using the parallel of mixing ammonia and bleach, each of which are safe on their own but which create a toxic poison when mixed together, is a helpful tool in relating that concept. Such real-world examples provide a framework to understand these concepts without compromising the religious authority behind them. The goal in explaining kosher to the Simple Company is more than education; it is about creating a window through which they can see and relate.
The Company that Knows Not What to Ask: “Ask for Them”
For the Company that Knows Not What to Ask…You must be proactive and reach out to them, anticipating their issues and taking nothing for granted.
Nothing can potentially undermine a kosher program more than an unasked question, and nothing sustains and strengthens a kosher program more than open and clear communication. OU Rabbis are trained not only to see what is happening in a plant, but also what could potentially happen in the future, no matter how unexpected. Even companies that have some background in kosher are not always so clear on the rules, such as the ravioli manufacturer who, during the certification process, was eager find out exactly what would be needed to get his products certified kosher for Passover (answer — this would require a different Torah). Proactively discussing upcoming kosher issues, anticipating future developments and expecting the unexpected are the hallmarks of effective kosher supervision.
In the end, it all boils down to this: kosher may be different, but that does not mean that it must be difficult. By presenting kosher to our companies in terms they find relevant and relatable, and focusing on proactive education and guidance, the OU makes kosher certification factory-friendly, and one of the best decisions a company can make!
The Very Best Answer: The OU Educational Training Seminar
The OU has developed a comprehensive educational training seminar for its companies that covers the basics of kosher and combines all of the four approaches in a single 90-minute session. The seminar, which generally takes place on-site at a factory and often incorporates a company’s remote locations via video conferencing, provides a balanced overview of kosher tailored for that particular company and facility. The presentation targets the people who are actually working on the lines and producing the food, and addresses the various pieces of the puzzle that companies sometimes struggle with, including:
Why kosher? Explaining that, for a kosher consumer, non-kosher food is not an option. A company should appreciate that by producing a kosher product, they are making a notable difference in peoples’ lives.
What is kosher? Outlining the basics, such as: the Biblical and rabbinic sources of kosher rules; the difference between kosher and non-kosher; the prohibition of milk and meat together; the concept of parve; the idea that equipment can also become non-kosher.
The systems and methods the OU program implements in a factory to manage kosher. Explaining the nuts and bolts of the systems the OU has developed for ingredient control and raw material management, in addition to limitations on processing and equipment usage, as well as labeling the finished products.
How the kosher program affects each particular facility. A practical assessment of each division of a company — receiving, processing, quality assurance, research and development, labeling, warehousing — and demonstrating to the division’s personnel how compliance with the kosher program directly impacts the way they must do their jobs. It explains exactly what the kosher program requires from each individual and makes them feel a part of its successful performance.
How to deal with possible kosher problems. The presentation concludes by assigning a designated person within the plant who will function as the address for all kosher questions. It also provides the cell phone and contact information for the mashgiach, so that everyone in the plant feels they have a means to reach him directly at any time, day or night. It reinforces the critical need to ask when something doesn’t seem to be quite “kosher.”