Industrial Kashrus Systems
Everyone loves to know what goes on behind the scenes. Today we take a tour of a typical factory with Rabbi Yitzchak Hanoka, Senior Rabbinate Coordinator with the OK. We’ll find out all the systems in place to ensure kashrus at the highest level.
Rabbi Hisiger: Hello everyone and welcome back to Let's Talk Kashrus presented by the Kashrus Awareness Project in conjunction with Torah Anytime. Today I am privileged to be joined by Rabbi Yitzchak Hanoka, Senior Rabbinate Coordinator with the OK. Thank you Rabbi Hanoka for being here.
Rabbi Hanoka: Thank you for having me, it's a real honor.
Rabbi Hisiger: So we're here to discuss with you the topic of industrial kashrus. I know you've put a lot of work and time and effort and thought into systems of industrial kashrus. We'll break it down into different segments. Let's start first with the rabbinic side of industrial kashrus and the systems that you've implemented. Explain to us in layman's terms what that means.
Rabbi Hanoka: Basically what it means is that in order to be able to manage and oversee thousands of ingredients, thousands of products and thousands of facilities frankly, you have to have a system. Without a system it's impossible to do that. So every hechsher on a national scale, the reliable hechsherim, they all have their own system, but the concept and the focus is really the same. They have to have a system that's going to provide the elements of security, traceability and follow up that's necessary to be able to give the hashgacha and to maintain the quality.
Rabbi Hisiger: So it's more than just dispatching a team of qualified mashgichim to factories and companies and things like that, right? It's more robust than that.
Rabbi Hanoka: It's much more robust. Essentially what we have is in the food sector, the food industry, you have probably about 20 sectors of the food industry. The baking industry, the flavor industry, the cheese industry, the wine industry, the meat industry, etc., etc. And you're dealing with, in a large agency, you're dealing with a team and a pool of colleague rabbis, some of whom are experts in various industries. And then when you're dispatched to go see a company and to do what's called an initial visit, an expert rabbi who's well-versed in kosher law and halacha, but also is well-versed in manufacturing processes, walks into a facility, understands machinery, understands processes, understands how to synthesize, how to merge halacha with processes that are going to work in the actual, in the real world, so to speak. That's when we talk about a kashrus system because you have to make sure it's going to work halachically, but also make sure it's practical. We can't give an eitzah to a customer to do something that's not going to be practical. It's not going to work. So we always look for things to make sure it's multilayered in terms of security.
Rabbi Hisiger: Could you give us an example of that multilayer where one level may catch something that slipped through another?
Rabbi Hanoka: Absolutely. Like, for example, if we go to a facility that they're processing both dairy product and pareve product. So, if the machinery and the processes and the products are totally noncompatible, which means you cannot interchange the dairy product with the pareve product, it's different machinery, different kind of equipment and different ingredients, then we know really inherently it's segregated so we have safety with regards to kashrus. On the other hand, if it's the same type of machinery, same type of ovens, there's more risk there. So you have to put in safeguards to make sure they're not going to mingle or proximity gets into the question. So we really do what's called a risk assessment. What are we talking about? What are the possibilities? Let me just share a story with you to illustrate the point. I had a customer who used to repack product by hand. They would take scoops and, you know, take it from a box to a small container. And then they grew and they got machinery to do it automatically. And then they were testing the line. And then they, what we usually do in such systems when we do it electronically, we'll often have them, and it's all cold processing. They wash them between, and there’s no bliah. But we'll have them run pareve products first and then dairy because they break down the equipment after dairy. But they said to me that the supplier, by mistake, put dairy chocolate in a pareve product. And the supplier that they were referring to happens to be a supplier that I also certified. And on the phone, I was driving on the road. My mashgiach reported this to me. I said, it's not what happened. I said, what happened is they're used to hand packing and they see what they're doing. They're now packing by machine. They're not used to cleaning the machine. When they broke it down, there was a piece of chocolate that got stuck to the machine because it was sticky out. It was moist, moisture in the air. And it got dislodged by the next packaging. And they have to get used to it. It's like, go see. And he said, Rabbi, you're right. That's because, not because, because I know the process.
Rabbi Hisiger: So you also knew that the...
Rabbi Hanoka: I knew that they switched this, but I knew what the risk was. And they were testing. I said, that's what they need to, and they were right.
Rabbi Hisiger: Wow.
Rabbi Hanoka: So just, and it's all because when you understand the mechanics of it, what the risk assessment is, then you see from what's behind. Understanding what the real question is. And that's how we train rabbis. That's how we train mashgichim. We train all our staff bezras Hashem to do that. And then, of course, Hashem is the active partner. But that's our, that's our... To do things in an Erlicha way, we have multi-layers of security in place. So that in case one of the layers falls off, you have the security in place.
Rabbi Hisiger: Now, when you say layers, are you referring to personnel as well? Where you have different levels of senior coordinators, and then mashgichim, and things of that sort? Or is it just like you were mentioning in the facility itself?
Rabbi Hanoka: I'm focusing on the facility itself. It happens to be that every facility that's certified by a national agency will have a rabbinic coordinator, who's an expert rabbi with smicha, who's very knowledgeable in halacha and food manufacturing, oversee that facility. Part of the process is that we write an extensive report describing the on goings of the facility, and exactly how we give a hechsher, what we're doing, so in case someone else has a question, one of our colleagues, they can review our reports. Plus we do peer-to-peer review. And then included in that, we talk about what the areas of sensitivity are in place, what safeguards we're putting in place, and how we're addressing them. And, of course, we have mashgichim instructions, which will come later. But an example of things that we'll do is, if it's a facility that handles kosher-sensitive ingredients, for example, they handle hard cheese. Even if it's not chalav Yisrael. Hard cheese, that's not chalav Yisrael. To make a kosher is quite expensive. To make gevinas Yisrael, you need a mashgiach temidi. So there's a lot of non-kosher cheese out there on the market. So we may require the customer to have a large supply of kosher cheese on hand at all times. We may require the mashgiach to visit more often. We're going to have safeguards in place to secure against what we would consider a more sensitive type of raw material. And that is diagnosed by an expert rabbi.
Rabbi Hisiger: Who makes that diagnosis of the risk assessment? Okay, over here in this facility is a little more risky, or we have reasons to suspect, so we're going to put in X, Y, and Z safeguards. Who makes that?
Rabbi Hanoka: The rabbi would make that assessment, but he's using principles that are known in the industry. Kosher sensitive ingredients are treated with more sensitivity. Kosher setups that are more sensitive are treated more sensitively. And some setups require a mashgiach temidi, depending on what we're dealing with. But all that has to be factored in in the setup process. So there's many things going through the rabbi's mind in the process itself.
Rabbi HIsiger: Talk about what goes on in the office of the OK in terms of implementing some of these, we'll call them safeguards and structures that you put in place.
Rabbi Hanoka: All the hechsherim, reliable hechsherim, have a data system. Exactly what they do, there may be slight variation, but the general theme is the same, where they want to be able to get the requisite data from the customer. So just so the consumers and our audience understands, every raw material, every ingredient that's used in a kosher certified product has a kosher letter that actually attests to the status of that product. They'll say this particular ingredient is kosher pareve, kosher dairy, or whatever it is. And they'll also say it's got to have a symbol on it, or it doesn't have to have a symbol on the industrial level, or if it's bulk, if it's coming by a tanker truck, how it's supposed to be received. It gives instructions of under what circumstances it's actually being certified, known as a restriction. So on the industrial side, we harvest all this data. The customer will send us all the ingredients with the kosher letters.
Rabbi Hisiger: To clarify, when you say customer, you mean the company you're certified, right? I just want to make sure, because viewers may be hearing customer, and they're thinking of themselves.
Rabbi Hanoka: So I mean the certified client will submit the kosher letters with the ingredients. In many cases, many hechsherim require the formulas. Some do and some don't, but formulas are important as well. Product lists, and then we also look at the labels. So we call these critical control points. You have the receiving of the ingredients, and then you have the final product that they're producing, which refers to the finished product label. We want to make sure the label is accurately printed with the right kosher information, pareve for pareve, dairy for dairy, or Passover for Passover. So we try very hard to have the customer send us a soft copy image of the finished product label whenever possible so we can review that. Sometimes the mashgiach will review that on the field. But we try to review that before it's printed, so human error does happen, people make mistakes. We try to vet that out in the process of our harvesting of our data. Another thing that I want to make it clear to our audience is that there are thousands of product labels out there on the market, but a little-known secret, without revealing who, what, when, and where, is a lot of products are made in the same facility under different brands, known as private labels. So you'll have some people that don't even have an entity of a factory, but they just have a brand, and they'll make it by various factories. Of course, that's kept confidential. But again, the hechsherim has to harvest that information, know where to issue a kosher letter for that. So the data side of the support system of kashrus is very complex. There's many, many different angles to it. As I said, you have the ingredients, you have the finished products, you have the formula, you have the private labels, you have the contract, all these things, and they're all tied in to provide support for the kashrus and the company.
Rabbi Hisiger: Now, I'm curious, because on an office side, that's quite a lot of information to store. I'm imagining you don't have file cabinets, right, with papers of, or maybe I'm wrong, maybe years ago. But I imagine, do you have a custom-made computer software that digests all this information?
Rabbi Hanoka: Right, so there's custom-made software that digests all this information, but even more than that, it's built in such a way where if you ever have one of the ingredients that could lose their certification mid-year, because usually the certification is from year to year, then you can just say, tell the system that this particular ingredient is no longer kosher, and it will spit out a report, who is using it, where it's being used, and then we can tell the customer no longer to use it. So we have traceability and targetability instantly. So it's very, very sophisticated. It's not my expertise, but I know it exists, and I know enough about it that if there's something I have to report or to trigger, we'll know what to try to respond to.
Rabbi Hisiger: I'll say that it does sound sophisticated, but it's really not a luxury if you want to maintain proper hashgacha, right? I mean, if there's an ingredient that's being used that's losing certification mid-year, and you have products that contain that ingredient, I mean, you have to be on top of that, right?
Rabbi Hanoka: It's an absolute must, and I want to share, just to share a mashal, I do quite a lot of driving in my work. So think of it in these terms. If you have a customer, somebody who has a trucking company, if they only own one truck, they can remember in their head that every month they have to change the oil, they've got to check the brakes, whatever maintenance involved in the truck to keep their truck safe. Once you have a fleet of 100 trucks, it's physically impossible to remember exactly what has to be done with each truck. The only way to do that is to have a system. So if you want to be able to enjoy the freedom of the high seas, you have to become a slave to the compass. The compass is your system. You must have that, and the data is a big part of that. And again, what I want to bring out to our viewers' attention is that we're trained to think in systems. Like whenever there's something that goes on, we ask ourselves, okay, is this going to be in congruence with the system or not? And if not, we have to react to it. That's kind of what we do.
Rabbi Hisiger: Anything else you wanted to share about maintaining the database and maintaining all the information that you need so that you have this industrial system in place?
Rabbi Hanoka: My final thoughts are the people that harvest the data, that bring it in, that enter into our system and monitor the data, they're the unsung heroes because they're sitting in the back. No one sees them.
Rabbi Hisiger: No one sees them. They don't get the accolades.
Rabbi Hanoka: Right, but they are really the backbone in terms of providing that prong of support. And you couldn't do it without them, so it's quite an important…
Rabbi Hisiger: It's our gratitude to them for what they do really under the radar. And they support the rabbi very much in his work. Probably these personnel are available at a moment's notice to provide that crucial information, right? If a mashgiach is in a plant that needs an update or something like that, he's going to rely on them to give a minute to minute update.
Rabbi Hanoka: Or if he has a question about what's been changed on the data side to make sure it's all in compliance, he'll rely on them. So there's multi-layers of security. Whenever we see something that doesn't balance, we check it on multiple layers so there's many layers of protection in place.
Rabbi Hisiger: Just a final component of the conversation, and that is the role of a mashgiach within the umbrella or rubric of industrial kashrus and the other items that we discussed. So talk about that for a moment.
Rabbi Hanoka: So the mashgiach is primarily… His task is to carry out the instructions of the rabbinic coordinator, the rabbi who set up the kashrus of that facility. So the rabbi who set up the kashrus of that facility will have to write detailed instructions. Depending on the facility, they could be smaller in terms of size or very large. Some large facilities may even have 20 or 30 points to cover on every visit.
Rabbi Hisiger: Can you give an example of what those points might be?
Rabbi Hanoka: Yeah, sure. So we'll talk about if it's a facility that has multi-status, kosher pareve, kosher dairy, or non-kosher, we'll talk about all the segregation systems in place to make sure there's no commingling, and how that's being done, how that's being monitored, making sure all those safeguards are in place. We also make sure in certain facilities where they have steam return, if they're using the shared steam, making sure there's no steam return between kosher and non-kosher. They'll often dump the steam, or they'll treat the steam to make it pagum. There's always a system in place to avoid that concern, and anything that is a potential kashrus concern was addressed by the rabbi. The mashgiach's job is to make sure that those systems, we call them critical control points of security, are in place. In addition to that, I want to stress something else, that I often tell… I've trained many mashgichim. I've also trained a lot of my colleagues, because I have a passion for education. I think I get that from my wife's grandfather, who was also into education. Rabbi Berel Levy who worked for Torah Umesorah. It's a very interesting piece of information. But at any rate, so I've trained many mashgichim, and I tell them that we're not policemen. We're not there to try and catch the customer do something wrong. Our job is to guide them what to do, to do it right. So our job is to guide them, and I really encourage everybody to have conversations with the customer. So when we go to do a visit, or if I do an annual review, I sit down with the customer for about 20 minutes, I schmooze with them. What's happening? I look at the word emes. Aleph at the beginning of the year, Mem at the middle of the year, and Suf What's happening at the end of the year? So where were they? Where have they been? Where are they heading? You want to get a sense. You want to know your customer. You want to know what the client is up to, because they might share something with you. Oh, we're planning an expansion, and we're planning this. Oh, suddenly that changes implications. But again, it comes about through conversation. And I like to have conversations with people, even about information that I may be familiar with already, because I want to make sure that everything is coming across very clearly, and I tell my mashgichim the same thing. So I encourage them very much to have a very good relationship with the client, and that helps kashrus, because when the client has a question, they pick up the phone, they say, Rabbi, we want to plan something. Can you guide us to do it right? And that's really where the security comes in. In addition, the mashgiach has to be very well-versed, exactly what's going on in his facilities. If there's any change going on, he will be able to detect it right away. And I can tell, based on the questions the mashgichim ask me, if they understand the facility or not. So I've had situations where a mashgiach asked me a question exactly the same way that I would ask the question, because I trained him so detailed. That's what we're looking for, such a level of communication, and I would say a bond, if you will.
Rabbi Hisiger: Would you say the relationship between a mashgiach and a facility, he's certifying is kabdeihu ve-chashdeihu, right? It's giving them respect, that they feel that the mashgiach respects what they're doing, but also, in the back of his mind, kind of having an eye out for any change in the status quo?
Rabbi Hanoka: Yeah, I would say that, but I would say that the mashgichim are also told that if there is a change or there's a concern, that they have to send it over to the rabbi. They have to remain impartial. I would say they have to just say, you know, my job is to report, and in this case, if I'm the rabbi of the facility, Rabbi Hanoka will be in touch with you, and I'll talk to the client. But I don't want the mashgiach to be the one to front it, because they have to interact with him all the time. Because then it creates a tension, and maybe the facility won't be transparent with him. So I don't allow that. In fact, I'll guide them to do just the opposite, and then I'll have to front it. I'll have to navigate, and that's why we're in this position. We have to figure out how to navigate that. And also, which brings me to mind, what my shver Rabbi Levy taught me was, everything we do for kashrus ultimately is also to protect the client, to protect the certified customer. Whatever system you have in place, the amount of visits, the amount of requirements are there to ensure the product remains kosher. So you tell them that I'm doing this for you. It's for your sake. So you can have clients. You can sell the product, make money. So when they see it from those terms, they usually back off and say, thank you very much, Rabbi. They see it from the lens of it's for your own good. We as a hashgacha have to provide an environment where they're well-versed in what they need to do. We support them through the process. The mashgiach works with them on any possible changes. We rebalance the system as needed. And then I would say that you're providing an environment where kashrus is secure, and the customer feels like, yeah, this is working well for me.
Rabbi Hisiger: Very impressive.
Rabbi Hanoka: One more thing I want to say. During COVID, when raw material supply was hard to procure, and you had all kinds of raw material shortages, I wrote an article about that in our magazine, all agencies did this. We warned our mashgichim, be very careful, because when customers are in short supply of raw material, then they'll be incentivized to find alternates. So we encourage them to submit alternates. But that's, again, being proactive. So we work with the customer.
Rabbi Hisiger: You preempted it by reaching out to the customer.
Rabbi Hanoka: We understand what their issues are. If a customer is hurting financially, it's very dangerous kashrus-wise. So we'll put safeguards in place. We'll work with them. We'll find alternate suppliers. We'll even help them with alternate suppliers to provide kashrus security and to make sure that the system flows.
Rabbi Hisiger: Listen, the lesson that I learned from the conversation with you is that kashrus is by no means a system where you just push a button and just let the system roll. It really involves so much activity and being proactive and really staying on top, staying on the tips of your toes and constantly being active and involved.
Rabbi Hanoka: And the certified customer appreciates that. When they see that level of professionalism, they're paying for hashgacha. They see they're paying for something very, very substantial. And they appreciate that. It's very special.
Rabbi Hisiger: Well, we appreciate as well everything you've done for the field of kashrus in general over the last quarter century, what you've given to the OK and to the field of kashrus in general. So continued hatzlacha in your avodas hakodesh. And a special thank you for shlepping out all the way from Brooklyn to here to the Let's Talk Kashrus Studios. It was a real honor to speak to you. Thank you.
Rabbi Hanoka: Thank you for having me. Be matzliach.
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