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Working in the Trenches

One day, early in my career in kosher supervision, I arrived at a bakery certified by the O.K. and proceeded to inspect the facility. Looking around, I was puzzled by the presence of a certain skid. The product inside was encased so well by the plastic wrapping that I could not identify it. I thought I had discovered something amiss. Clearly the bakery was hiding something from me. Here was my chance to impress my employer at the O.K.!

When I confronted the bakery owner, he told me that inside the wrapping was . . . more wrapping. This was a skid of shrink wrap! While the incident is humorous, it does help to illustrate the task of a mashgiach (English translation: monitor). Acting as the eyes and ears of the supervision agency for which he works, he serves a critical role in maintaining its standards.

When a kosher supervision organization grants certification to a particular company, how does the agency insure that the standards present on the day of initial certification will continue? The answer is that field mashgichim pay periodic visits to monitor the company’s compliance with the agreement it has made.

Far from being a policeman, the mashgiach actually serves the best interests of the company at the same time that he serves the kosher consumer. The O.K. will not undertake supervision if we believe a company is untrustworthy; we do not expect companies certified by us to engage in subterfuge. The last thing an ethical company wants is for something to go wrong with its kosher program. But we also know that kashrus is complex, and that the best-intentioned companies can make mistakes. The field mashgiach, who is versed in the rules of kashrus, can find such errors and help correct them.

The field mashgiach tends to work behind the scenes; he is the unseen and often unsung hero of kosher supervision. Yet he is an important line of defense, for while at the O.K. the mashgiach is backed up by an annual visit from a Rabbinic Coordinator, the field mashgiach implements our policies on a day-to-day basis. He is our eyes and ears.

How exactly does the mashgiach fit into the O.K. Labs system?

At the O.K., onsite inspection is divided into three distinct stages. When a company seeks kosher certification for one of its plants, we perform an initial inspection of the facility. This visit generally is made by one of the Rabbinic Coordinators located in our main office. Our Rabbinic Coordinators have a broad knowledge of kashrus and its application to today’s food technology. They are best equipped to determine whether the plant can be set up for kosher production.

Working with the company, we set up a kosher liaison at the plant. Every facility under the O.K. has a kosher contact, overseeing its kosher program from the company’s perspective. The Rabbinic Coordinator who performs the initial inspection of the plant guides this employee concerning his or her role, so that a clear channel of communication is maintained between the O.K. and the company. Along with a kosher contact at the plant level, there will also be a contact at the corporate level. This allows for a better communication flow between the O.K. and the company. (In smaller companies, one person often fills both roles.)

After kosher certification has been granted, one of our Rabbinic Coordinators will visit the plant on a yearly basis. This inspection, called the Annual, provides a broad overview of the plant’s compliance with kosher regulations. (For a detailed description of the O.K. approach to kosher supervision, see “A Different Standard,” by Rabbi Don Yoel Levy, April 1998. This article can be accessed on our website, at www.homemaker.org/pesach_58/ kashrus.html.)

What happens between annual inspections? A mashgiach, preferably one who is located near the plant, is engaged to monitor it on a regular basis. (In the New York area, due to the proximity of these plants to the O.K. home office, the role of mashgiach is often filled by a Rabbinic Coordinator.) The frequency of his visits is determined by the nature of the facility. Some facilities require minimal inspection; others, with a more complex setup, require permanent supervision (a mashgiach temidi). Yet others require periodic monitoring (yotzei v’nichnas). Whatever the case, the O.K. arranges such monitoring at a reasonable cost to the company.

Preparing the Mashgiach

How does the mashgiach go about doing his task properly? In reality, his preparation begins long before he arrives at the facility. First, if at all possible, he will accompany the Rabbinic Coordinator on the initial visit. This helps assure that our field representatives function with our home office as a team. The local mashgiach must do his homework; at the O.K., there is no such thing as “winging it.” No two plants are alike, and general knowledge of kashrus does not suffice to assure quality hashgachah work.

 

The O.K.’s decision-making process is centralized. Policy is made not by the field mashgichim, but by the central office. The task of the field mashgichim is to apply the O.K.’s policies to each particular facility. We hold an annual conference at which Rabbinic Coordinators and mashgichim exchange information about developments in kosher supervision. Additionally, a periodic newsletter to mashgichim apprises them of significant kashrus news. The O.K. central office equips the mashgiach with the company’s ingredient list. As the name implies, this list itemizes every ingredient that has been approved for use in the plant. The mashgiach is also given a plant profile. This report details the basics of the plant. Included is whether the plant is entirely kosher or produces non-kosher as well; whether the plant is pareve, dairy, meat, or a combination; whether the plant is chalav Yisrael; and whether the plant produces for Passover. Each of these elements impacts the mashgiach’s approach to the facility. (It is critical to note that all proprietary information is kept in the strictest confidence. The O.K. utilizes company information for the sole purpose of maintaining kosher supervision.)

Inspecting the Facility

Now the mashgiach, armed with the necessary data, arrives at the plant.

There are plants that are entirely kosher and plants that are used for both kosher and not kosher production. In a kosher facility, the mashgiach’s task is considerably eased by the fact that no non-kosher ingredients are present anywhere. (If non-kosher ingredients are found, the facility’s kosher status will be in jeopardy.) The mashgiach will inspect the raw materials in the storage area to ascertain that all are approved by the O.K.. If the facility is all pareve or all-dairy, such an inspection generally suffices. However, if both dairy and pareve are produced, the mashgiach must also determine that the dairy and pareve ingredients are properly separated, and that the equipment for dairy and pareve manufacturing does not cross.

The story is quite different in a plant that also makes not kosher products. Here not kosher ingredients will be present on the premises. The mashgiach must assure that these are not found in the section of the facility used for kosher production. In such a plant, he must be especially careful that no unapproved items are mistakenly being used. Furthermore, the O.K. does not allow the presence of compatibles — non-kosher items that are identical to, and hence may be substituted for, kosher items — on the premises. The mashgiach will keep an eye out for compatibles.

A mashgiach must have his thinking cap on. Upon arrival, he should ask himself: Has anything changed since I was last here? Is there any new equipment on the premises? (New equipment almost always indicates that new products will be made and new ingredients will be used.) Do things look different? Are there new employees, who may be uninformed regarding kashrus regulations? The mashgiach should feel comfortable dealing with the company’s kosher contact. The two should have a cooperative relationship, with open communication.

We can break down the mashgiach’s inspection into three categories: ingredients, equipment, and labels.

First, he checks to make sure that the ingredients present in the plant are all acceptable. These should correspond with the ingredient list supplied to the O.K. by the plant, since this list represents the items we have approved for use there. If he finds any additional ingredients, then, if the ingredient has kosher certification, we ask the plant to submit proof of such certification. If the item requires certification but lacks it, the mashgiach will arrange for the plant to remove the item. The mashgiach has to recognize where he can spend his time most productively. The company receives a list of ingredients that the O.K. has approved for use in the plant. The mashgiach will note any products that are not on the list. Even as innocuous a product as bottled water should be noted in the plant inspection report that he files with our office. But he should not expend time on the matter, because water does not require supervision. It would be very unfortunate if the mashgiach misses something significant because he spent time on a matter that is inconsequential.

Next on the list is equipment. The mashgiach must ascertain that the plant equipment is used in a way that does not compromise its kosher status. Among the examples of something wrong: pareve equipment is being used for dairy runs; and equipment is not being properly cleaned or kashered between productions.

The third category is labeling, which refers to the packaging of items. The mashgiach makes sure that finished products are labeled correctly.

The plant’s kosher contact is trained to keep an eye on new labels, making sure that the O.K. is printed only on labels of approved products, and that any appropriate limitations, such as a D for Dairy or P for Passover, are properly printed.

The O.K. supervises some companies that repack products from larger to smaller containers. The mashgiach will check the company records to make sure the dates and quantities match the intake from the supplier approved by the O.K..

Receiving is another area of the plant that the mashgiach must monitor. The receiving department is where products come in to the plant. It is not uncommon for a company to receive the wrong goods. What happens if the substitute goods are qualitatively identical to the products they are replacing? Will the receiving department accept a substitute oil for the kosher-approved oil that did not arrive? The mashgiach must ascertain the quality of receiving and monitor it on a consistent basis.

Sometimes a company will order an approved product but the distributor, seeking to clear out inventory of a similar, unapproved item, sends the latter. This can happen with a variety of products. Unfortunately, not all distributors are dependable. A reputable distributor who needs to send a substitute item will confer with the company to make sure that the replacement product is an acceptable alternative.

Kashering

Kashering is one of the more difficult tasks for a mashgiach. Kashering, often called kosherizing in the industry, means purging equipment of food that cannot be present in the supervised production. Kashering involves a change of status for the equipment, and it is critical to verify that this change is properly accomplished. Therefore, in most cases a mashgiach must be present during kashering.

The type of kosherization required for particular equipment depends on any number of factors. These include but are not limited to: 1. Previous productions made on the equipment. Were they not kosher? Were they technically kosher, but not to the standard the O.K. demands? Were they dairy and the equipment is now to be used for pareve? Were they chametz and the equipment is now to be used for Passover production?

2. The nature of the previous productions. Were they made at cooking temperature or as a cold process? (In the case of cold process, cleaning the equipment often suffices.) Were they liquid or dry? Did the productions remain in the equipment for twenty-four hours?

3. The nature of the equipment. Of what material is it composed? What is the most feasible way to kasher in each instance? The logistics of kashering depend on the type of plant in question. A typical case is a large plant that makes both kosher and non-kosher products. Such a plant often prefers to make its kosher runs at the beginning of the week. The reason for this is the halachic requirement that non-kosher equipment be aino ben yomo, unused for twenty-four hours, before it is kashered. Such downtime is a financial drain on a company. And so companies prefer to have their downtime over the weekend, which generally is less busy. Therefore, kashering often takes place on a Sunday evening, sometimes in the wee hours of the night. Many a dedicated mashgiach makes himself available at odd hours to accommodate a company.

One of the stumbling blocks here is the presumption of a seamless production schedule. But production is dependent on human and natural factors. Among these are quality control. If a company produces an item on Saturday but determines that the item does not meet its standards, it will run the product again. This may delay the onset of downtime and thereby delay the kosher run.

The mashgiach for such a plant must be flexible enough to accommodate schedule quirks, while the company must be prepared to permit twenty-four hours’ downtime regardless of any inconvenience. Otherwise, the company is not a candidate for O.K. supervision.

Some kosher supervision agencies do not require downtime, relying instead on the leniency of kashering and then re-kashering. The O.K. does not accept this leniency in cases involving a Biblical prohibition. Only in instances concerning a Rabbinic prohibition, and only in plants where the only situations that require kashering are Rabbinic rather than Biblical, is the double kashering method acceptable to us. Moreover, we do this only when there is no other option. The mashgiach should leave the plant with a sense that kashrus is under control there. While he should not be complacent, he should feel he can sleep at night, confident that kosher consumers are getting the truly kosher product they are promised.

Ultimately the mashgiach’s role is to insure that the standards set by the O.K. are observed. The O.K. is determined to engage only the best mashgichim for this difficult task. We are proud of our mashgichim, whose dedication assures the public that the kashrus of O.K.-certified products is uncompromised.