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Applying For Kashrus Certification

Rabbi Don Yoel Levy     As the Jewish Homemaker is widely read by the food industry, this article will be devoted to giving an overview of the intricate process of obtaining kashrus certification for products and ingredients.

    We will approach this from two angles. First, we will look at what the kashrus certifying agency requires from the manufacturer in order to certify a product as kosher, and second, the steps a company needs to take to insure that it is properly set up.

    The process begins when a company comes to the conclusion that it needs kashrus certification for its product or products. It approaches the kashrus agency and requests such certification.

    The kashrus agency is basically interested in three factors: the components of the product(s), the actual production of the product(s) including the equipment on which it is produced, and the location of the plant.

Components/Ingredients
    First and foremost, the agency needs to know which ingredients are being used. Depending on the product, the number of ingredients can range from a few to hundreds. Cellulose and pectin are examples of products that have a few ingredients. Flavor companies can use thousands of ingredients.

    Ingredients are the main determining factor. If an ingredient is inherently not kosher (for example, pork or pork products), it is rejected immediately, which saves a lot of paperwork. With the thousands of ingredients available today, most manufacturers cannot be expected to know whether all the ingredients they are using are compounded from kosher or non-kosher components. Even if the ingredient seems to be inherently kosher (for example, vegetable oil), it can be non-kosher if it is produced on non-kosher equipment, and this requires constant monitoring.

Production
    Assuming all the components used are kosher, we need to know how the product is produced. This is necessary because in the event the company is producing non-kosher products on the same equipment, a special kosherizing process will be required between productions in order for any product to be certified.

    After we have collected all the information the company has submitted, we send an expert to the plant to inspect the facilities.

    Being familiar with food plants, we often find that companies inadvertently omit information crucial to the certification process. Often a company will not submit information on ingredients which it does not consider to be part of the product, such as production aids like catalysts and initial inoculation ingredients. Or sometimes, the ingredients are not used in the products in question, but in other products made on the same equipment.

    The person visiting can often be helpful in finding replacement ingredients once he understands the needs of the plant.

    While visiting, we also discuss the possible needs for kosherizing. Even when the company itself feels that it may not be able to comply, we often help to find ways to kosherize or adjust its facilities to kosher production.

    An example of this is steam (condensate) return. According to Jewish law, steam used in a closed system to heat non-kosher products (like a steam jacket), which is then returned to the boiler, cannot be used to heat kosher products. We are able to help producers solve this problem.

Location
    For continuous monitoring of a plant, the OK has local rabbis on staff to either visit on a regular basis or to be there for every production. We must know how close the rabbi is to the particular plant in order to calculate costs. We also need to monitor the location of the plant (or plants), as changing locations or adding plants can jeopardize the whole process.

    For the initial set-up, we always send a rabbi from the home office. Why is this necessary if we have a local representative? Sending a local rabbi can eventually cause problems as he usually does not have the expertise to set up a complicated plant. If a plant is set up incorrectly, it can cause aggravation and financial loss later on when it has to be set up again. A plant that is erroneously set up as "kosher," has to recall its products and put production on hold until the problem is rectified.

    As all decisions are made from the home office, it is also critical to have someone from the home office who is familiar with all the processes and is up-to-date on all the developments visit each plant yearly. An advantage of this is that when the company contacts our office, they have personal contact with someone who is familiar with their specific circumstances.

Application Process
    When a company contacts our office in order to apply for kosher certification, usually one of the rabbis will discuss the company's specific situation with them. Based on the type of facility being discussed, he can then advise them what is needed to get certification.   

    An application form is then sent out. It is very important for the company to submit as much information as possible before we make a visit. Simply put, we do not need to make a visit to find out that non-kosher ingredients are being used if this can be done by mail.

    All ingredients are submitted with as many kosher certificates as possible. A company using a thousand ingredients may require a thousand certificates, although chances are, many ingredients are already on our data base or do not currently require kosher certification. We can also help the companies by advising which ingredients fit the above, or where they can find replacement ingredients.

    Now our rabbi comes for a visit. He will want to set up a system whereby all the ingredients and processes can be verified as kosher.

    Special mention needs to be made of ingredients which are received unlabeled (e.g. in tank trucks, rail cars or ship holds). These require a paper trail for monitoring, as do the vessels themselves.

    Production records play an integral part of kashrus certification. We have to have accurate records of what was produced, with which ingredients, on which equipment, etc.

    Once the evaluation has been completed, we can now present the company with our proposal for certifying their plant. They will now receive an approved ingredient list, protocol for kosherization if necessary and a contract outlining our legal requirements.

    All information submitted to the OK Labs is kept in the strictest of confidence and is never passed on.