Tens of thousands of square feet. Manufacturing equipment of enormous size. Products and ingredients numbering in the hundreds. Employees scurrying back and forth to keep the production moving.

This is the modern food manufacturing plant into which walks the mashgiach, to inspect the facility and insure that the rules set out by its supervising kosher agency are observed. Armed with a list of the ingredients that are permitted in the facility, he crosschecks it against the physical inventory.

Some products don’t require a hechsher. Others need special markings. Yet others, which are not kosher, don’t belong in the plant at all. A competent mashgiach, trained to observe the details of even the largest operations, will succeed in performing a thorough inspection. But a complicated task it is.

The food industry is enormously large and variegated. Some companies have just a few products or ingredients. Others deal in thousands of ingredients, and many of these ingredients can be purchased from more than one supplier. To efficiently manage their operations, companies develop sophisticated inventory systems. With proper product coding, companies can track the source of every ingredient that goes into a product.

Into this mix comes kosher, introducing its unique set of requirements. While there are many facilities that are entirely kosher, there are also many that manufacture both kosher and non-kosher products. Kosher law requires a system to separate these operations. Add the fact that the identical ingredient often can emanate from a kosher or a non-kosher source, and it is easy to see how managing a plant from the kosher perspective is difficult. When one considers that the plant, the food distributor, and the kosher agency may term the identical ingredient by a different name, the burden is even greater.

Why should consumers care about all this? Ultimately consumers buy and eat these products, and so it is important for them to understand what goes on behind the scenes.

Some years ago, the need for order was addressed by the creation of categories commonly referred to as “groups.” In this system, every ingredient fits one of seven classifications. These categories range from ingredients that are deemed implicitly kosher to certain non-kosher ingredients that cannot even be permitted to remain in a plant. (Please note that the group system concerns products on the industrial level, not on the consumer level, where a product’s kosher status is attested to by a kosher symbol.)

The grouping system proved very advantageous to food companies. The system allowed for much simpler categorization of their products. It also meant that a mashgiach visiting a plant would have a coherent list of ingredients and products that he could match to the physical inventory.

Grouping quickly became the standard in the kashrus industry, with every major (and many minor) kashrus agencies going along.

Except the OK.

For a long time we chose not to implement a group system — neither this one, nor one of our own. The reason for our hesitation was not in order to spoil the party, but rather because we sensed inherent weaknesses in the system, on two counts. First, we had determined that because of the complex nature of ingredients, a division into only seven groups was not adequate. There were too many ingredients that did not quite “fit” any of the groups. Second, we believed that some of the categories were not defined clearly, and that the potential for mistakes by a mashgiach or a company was not worth the convenience achieved by grouping. Instead, we continued to evaluate each ingredient on its own.

In time, the OK, in conjunction with New Era Solutions, a Brooklyn-based computer consulting firm, developed the TRACKTM computer system, a groundbreaking program that collects and links all relevant kashrus information. Once TRACKTM was in place, we felt comfortable developing our own grouping system.

In determining the makeup of our groups, we wanted them to reflect greater specificity than is found in the standard grouping system — that is, we wanted to more clearly define the parameters of each category. However, while we felt the necessity to fine-tune the groups, we did not want to abandon the structure that had already been adopted.

Food companies and mashgichim (many of whom work for more than one kashrus agency) had adapted themselves to the universal grouping system; the inconvenience of having to implement a second system would have been enormous. How could we set up the groups to our liking while at the same time preventing any confusion for companies, distributors, and mashgichim?

Our answer was to maintain the same basic groups that already existed (with some modifications), while adding subgroups to these in order to satisfy our requirement for better precision.

We developed our own list of close to thirty groups. This list was much more cumbersome than the universal group system, and we subsequently managed to narrow our list to thirteen groups — the seven existing groups plus six more. In the OK group system, while maintaining the seven groups, we created six subcategories to house the new groups we had developed.

We also took the additional step of changing how some of the established groups were defined, to arrive at greater clarity. A comparison of the two grouping systems may be made by studying both; they are reproduced for the reader in the sidebar to this article. The changes in definition may seem to be minor, but in reality they substantially redefine several groups.

Let’s take a closer look at three of the groups, why they present difficulties in their traditional incarnations, and how the OK has amended them.

According to the universally employed Group 1, an ingredient fitting that category is acceptable “from any source.” No certification is needed for the ingredient, and a food company is not required to identify the source from which it is receiving the item. For example, plain table salt is a Group 1 item. If a company wishes to use salt, it may purchase the salt from any source. Furthermore, the supervising kashrus agency does not require the company to identify that source.

By contrast, the OK Group 1 description reads: “Product source required, but presently no kosher certificate required. Approval status may be changed at any time.”

The difference between these two definitions is obvious. In both cases, any salt may be used, thus achieving consistency in the overall meaning of Group 1. However, the OK adds two limitations. First, we do want to know the source of the salt, even though we will not require the company to submit a kosher certificate attesting to the product’s kashrus.

(When an end product is composed of many ingredients, it is common that some of these ingredients, which come from different sources, will have the supervision of agencies other than the one certifying the end product. In seeking approval for the end product, the company will submit to the agency the kosher certificates that attest to the kashrus of these ingredients. Equipped with the kosher certificates issued by the other agencies, the agency supervising the end product decides upon the acceptability of the ingredients that comprise it.)

Second, we emphasize that Group 1 is transient, that approval may be withdrawn or amended if the need arises. It is possible, and it does happen, that an item is removed from Group 1. (In fact, Group 1 has historically been an abused category. Many items that are classified in Group 1 should not be permitted without certification. Read “The Myth of Group One,” by Rabbi Don Yoel Levy, The Jewish Homemaker, June 1995. This article may be accessed on, and downloaded from, the Organized Kashrus Laboratories website, at www.OK.org.)

Our desire to know ingredient sources is predicated on the concern that the categorization of an ingredient may change. Now it may happen that such a problem is localized rather than universal, affecting only the item as produced by one manufacturer.

Say that we determine that Company A, a salt producer, has begun pressing its salt into blocks on a dairy presser. If we didn’t ask our companies to identify the sources of their Group 1 ingredients, we would have to request that all our companies who use salt retroactively identify their source or else recall their products or re-label them dairy. The nightmare that would ensue is avoided by our insistence upon knowing the source that each company uses for salt. Using our TRACKTM system, we can instantly identify which products certified by the OK contain the salt produced by Company A. Rather than being forced to issue a universal recall, we need focus only on these particular products.

Let us now examine the traditional Group 3, which, as noted in the sidebar, must come from a “specified source” and must have a “kosher symbol only.” The difficulty here is the vagueness of the term “kosher symbol.” On the consumer/retail level, these words refer to the trademarked symbol of the kashrus agency in question. However, on the industrial level, there are several kinds of kosher markings, with the type of product determining which designation is necessary. One of these markings is a stamp given to the rabbi, with which he individually marks every package. The fact that this stamp must be individually applied reflects the agency’s conclusion that a preprinted symbol is an inadequate mark for the product in question. Let us say that an agency utilizing the universal grouping system decides that a certain item must carry the mashgiach’s stamp. In the agency’s paperwork, this requirement is indicated by classifying the product in Group 3.

The mashgiach, carrying this paperwork, arrives at the plant in question. He sees that the product has a preprinted label and notes that this matches his paperwork, which simply calls for a “kosher symbol.” He proceeds to the next item, satisfied that the company has met the requirement set forth in its kosher certificate. In truth, the requirement has not been met, because the group definition does not detail the kind of symbol that must be on the item. The mashgiach has accepted a preprinted symbol, which according to the agency’s determination is not proof of kosher certification.

The OK Labs’ Group 3 is divided into four categories, as detailed in the chart. A simple Group 3 classification means that the item needs only a preprinted kosher symbol. If an item is classified 3A, it requires a rabbi’s stamp. A 3B designation means that the rabbi must stamp the label and sign it as well, while Group 3C is for products that must be accompanied by a special letter from the rabbi.

When an OK mashgiach goes to a plant, his list of Group 3 ingredients accounts for all these subcategories. The chance for error is therefore much smaller. In this way, we abide by the universal grouping system, yet can fine-tune it to reflect the greater detail upon which we insist.

There is a flavor company whose products the OK categorizes variably as Group 3, Group 3A, and Group 3C. The traditional grouping system, which does not differentiate between these, creates a great potential for error on the part of the visiting mashgiach.

Say that the mashgiach’s files categorize Ingredient A as Group 3, that is, “from specified source with kosher symbol only.” However, on the kosher certificate issued by the agency, approval for Ingredient A is actually given only if a rabbi has personally stamped the package. The mashgiach, having no way to know this, goes ahead and accepts Ingredient A with a preprinted label, against his own agency’s criterion for acceptance of the product. In the OK system, the mashgiach’s files will note that Ingredient A is a Group 3A item.

Finally, let us examine Group 6, whose universal definition is “not kosher but may remain in plant.” Many plants produce both kosher and non-kosher items, and kashrus agencies must determine which non-kosher items can remain in a facility. The most likely candidates for exclusion from a facility are items that have a kosher equivalent in the plant. We are concerned that the kosher and not kosher versions may be inadvertently switched. The best way to safeguard against a mishap of this sort is to exclude the non-kosher version from the plant. These items are classified as Group 7. When a not kosher item is permitted in the plant, it is classified as Group 6.

Unfortunately, as in the case of Group 3, Group 6 is also not defined with sufficient clarity. Therefore, the OK further refined the definition by creating three categories: Group 6, Group 6A, and Group 6B.

Our Group 6 definition is: “Not approved for use, but may be used on non-kosher equipment.” We permit the not kosher item to remain in the plant, but it cannot be used on the kosher line.

An example occurs with a company that manufactures hard candy under OK supervision and soft candy that is not kosher because it contains gelatin. The OK permits the gelatin to be present at the plant for use on the non-kosher line where the soft candy is made. There is no chance that the gelatin will mistakenly be added to the kosher hard candy, because gelatin ruins hard candy, turning it soft. A contributing factor for leniency is that the gelatin is used only one month out of the year.

Subgroup 6A is defined as follows: “Not approved for use in OK products, but may be used on the same equipment.” An example would be a plant where all the OK-certified products made there are parve. These items are individually stamped by the OK’s supervising rabbi who monitors the production. The company also makes dairy runs, but these are not supervised by the OK. The line is used only for dry products, and is washed thoroughly between runs. (Because the products are dry, the equipment does not absorb non-kosher taste, and thorough washing is the correct method for kashering.)

Here there may be no reason not to permit the item to be used on the kosher line; however, it is not an ingredient approved for use in that plant’s OK-certified products, because of its dairy nature.

Group 6B’s definition is: “Not approved for use in OK products, but may be used for research and development.” This permits a company to use non-kosher items in its research lab, located separately, because we have determined that they will not be used in the kosher section of the plant.

Armed with these very specific definitions, the OK mashgiach can navigate a plant with a clear understanding of the status of the items he is reviewing. The result is a group system that truly does the job of ingredient classification without compromise.