Inspections In All Directions

Published Winter 2015

 The STAR-K certifies tens of thousands of products manufactured across the globe. There are well over a million ingredients and products certified by hundreds of kashrus  agencies worldwide. The following example may provide an idea of how many products are kosher certified.One million different products that are in containers measuring 6 inches in diameter lined up side by side (with no space between them) would stretch from Manhattan to Philadelphia. Since there are considerably more than a million kosher certified products, and industrial products are often sold in wider containers (e.g., 55 gallon drums), this line of products would most likely continue all the way to Baltimore. Furthermore, every kosher certified item (i.e., every container of every kosher product certified by every reliable  kashrus  agency) would easily stretch from the earth to the moon.To certify all of these products,  kashrus  agencies must adequately communicate with companies and  mashgichim  (rabbinic field representatives) and provide them with all necessary information. This is true, whether the factory is around the block or on the other side of the world, as is illustrated by a story related to us by Rabbi Joel Weinberger, director of STAR-K operations in India, and a frequent  mashgiach  in the area.There is a STAR-K certified herbal extraction plant in the Uttarakhand province of India, high above the Jim Corbett National Park, famous for its tiger reserves. The altitude above the winding roads is so high that the  mashgiach  who conducted the initial inspection had trouble breathing there. No wonder locals refer to this facility as “the factory above the clouds”. Rabbi Weinberger noted, “Plant personnel were appreciative of how the information they submitted from such a remote location was processed in the STAR-K office and was now richly detailed and concisely summarized for the company and the  mashgiach  to have at their fingertips.”This article will address how STAR-K prepares information for the  mashgiach  and discuss what the  mashgiach  does on his visit.[1]

I. PRELIMINARY OFFICE REVIEW & APPROVED INGREDIENT LISTSOnce a kosher program is set up for a company with an initial review and inspection, a company may wish to certify additional products.  STAR-K certified companies submit formulations on an ongoing basis for review and approval.  The office maintains a comprehensive “approved ingredient list” which shows ingredients for each facility.  If all of the ingredients in the formulas are on the approved list, and if there are no equipment issues, the product can typically be approved.Should the company wish to use a new ingredient or supplier, a formal request is submitted. Some ingredients can be approved for use in kosher products because they are intrinsically kosher (e.g., salt, hydrochloric acid, etc.).  These are known as “Any Source” or “Group 1.”  If an ingredient requires a hechsher, the company submits a letter of certification (referred to as an LOC, a document issued by the kosher certifying agency of the supplier indicating the kosher status of the product).  The LOC will be reviewed to confirm acceptability, to determine its  pareve /dairy status, and to confirm that it is current. Alternatively, a company can submit for review and approval an ingredient listed in the Universal  Kashrus  Database (UKD).  This repository of  kashrus  ingredient data for over a half million kosher certified productsstores  information found on the LOCs of various  hashgachos .The approved ingredient list shows the following information for every ingredient: name, approved suppliers,  pareve /dairy/meat status, symbol requirement, certifying agency and expiration date (ingredients are usually certified for one year at a time). When relevant, an inventory number is also listed.In factories, ingredients that require certification must be identified as kosher.  The conditions necessary to identify this product as kosher are stipulated in the LOC issued by the agency certifying the raw materials.  STAR-K does not necessarily accept just any certification; it must conform to STAR-K standards in order to be used in a STAR-K product.  Most often, the ingredient requires the kosher symbol of the agency certifying the product.  However, some raw material labels require more information such as the signature of a  mashgiach .  This may be necessary if the STAR-K certified company bought an ingredient from a company which requires the presence of a  mashgiach  for special  kashering  during a kosher run.  The rabbi at the supplier’s factory signs all such labels with his Hebrew name (or another stipulated designation).  Some ingredients are approved only when they have a designated lot number (e.g., they produce a kosher batch under special conditions) or when they come from a specified location.  Other ingredients do not require any kosher symbol; such an ingredient is always kosher from the specified supplier.  Some ingredients require special paperwork, bills of lading and proof of kosher transport.  This paperwork is generally necessary for bulk ingredients that arrive in a tanker or railcar, and are offloaded into large storage tanks that bear none of the visible labels or symbols which we are accustomed to seeing on packaged products.

The diverse volume of ingredients and necessary conditions highlights the need for an accurate approved ingredient list for each plant.  Even the most seasoned  kashrus administrator or  mashgiach  has no way of knowing the necessary conditions required on the packaging of every ingredient.  This is especially true when a  mashgiach inspects a facility which is the size of several football fields and contains hundreds of ingredients.


The next step after ingredient approval is a review of the entire formulation by the Kashrus  Administrator, confirmation that the  keilim  (equipment) are acceptable for preparing this product, and that the product does not impact the  pareve /dairy/meat status of existing products.  Reviewing the product label is also advisable.

Special care must be given to manufacturing facilities which produce both kosher and non-kosher, or  pareve  and dairy, etc., commonly known as “mixed plants”. Cleanouts and possible  kashering  (depending upon temperature) may be necessary. Furthermore, common steam systems, other complex heating operations, and vessels with  kavush  issues (e.g., 24 hour liquid storage) require special attention.  This is all determined on a plant-by-plant basis.  A  Pesach  product may require additional kashering , etc.

Manuals have been written about the various types of equipment that companies use and how to  kasher  them.  Since equipment can be several stories tall and may reach extremely high temperatures (e.g., spray driers or deodorizers),  kashering  may not be so simple.  Indeed, reading a manual does not suffice; learning how to  kasher  or trace production lines comes with on-site training and experience.  Every plant is different, and the  mashgiach  must be aware of any specific instructions and what is and is not allowed.  (A full discussion of this is beyond the scope of this article.)

Once a product is approved, it is entered into the STAR-K database and added to the company’s LOC.  The company is then authorized to place the STAR-K symbol on their product.  Certain products cannot be approved until the  mashgiach  has conducted an on-site review of the new ingredients and products.  Some products can be manufactured only with  hashgacha temidis  (i.e., a  mashgiach  present for the entire production, or possibly an on-site  mashgiach  who is there all the time).


For the plant visit, a  mashgiach  can access the STAR-K database and obtain  kashrus information about any factory which he is assigned to inspect.  Alternatively, he can request that this information be sent to him.  He will need an approved product list for all brands, including private labels (e.g., supermarket brands) and an approved ingredient list.  He should also have access to copies of the formulations and the pareve /dairy/meat status of all products/ingredients.  He should also be aware of equipment issues or special instructions for this plant.

The  mashgiach  arrives at the facility (generally without an appointment) with all the necessary information.  His review will include the following:

A)    Raw Material Review – The ingredients in the raw material warehouse must match those on the approved ingredient list.  A new ingredient, a different supplier, or the lack of a necessary kosher symbol means the plant is not in compliance.  When finding an error, the best case scenario is that the ingredient does not require certification or is certified by
an approved agency and can be added to the approved ingredient list.  The worst case scenario – and this does happen – is that the ingredient is from a non-approved supplier

and is non-kosher. This may mean that this plant may have produced a non-kosher product with an unauthorized kosher symbol due to a non-kosher ingredient.  This “nightmare” scenario, albeit rare, will create a domino effect of an immediate investigation, alert, possible recall, and even termination of certification.

Such cases illustrate the importance of the job of the  mashgiach .  The office can review paperwork with a fine-tooth comb, but without a  mashgiach conducting thorough on-site inspections, there is no way to determine what really transpires in the plant.  The  mashgichim  are the “eyes and ears” of kashrus  agencies.

B)    Product, Formula & Production Area Review – The  mashgiach  should confirm that the STAR-K symbol appears on the corresponding product and does not appear on any non-certified products.  Dairy products should also be properly labeled (STAR-K D if  Cholov Yisroel , or STAR-D Dairy if  cholov stam ).  Relevant additional label statements must be accurate (e.g.,  pareve , Kosher for Passover, fish,  Yoshon Bishul Yisroel Pas Yisroel , the  brocha , etc.).

If a  mashgiach  sees a kosher symbol on a non-approved product, it could indicate a major problem.  The product may be non-kosher, and his discovery may have stopped the distribution of thousands of packages of  treif  products that consumers would otherwise consider to be kosher.

Furthermore, the  mashgiach  should review formulas and in-house batch records (either in paper files or on the computer) to confirm that the formula submitted to the STAR-K office is the one currently in use.  Companies often produce “New & Improved” products and may occasionally fail to notify their certifying agency of the new formulation.  Therefore, the  mashgiach  needs to review records of finished goods in the warehouse and label room.  The mashgiach  should also ensure that products requiring  hashgacha temidis  were not produced while he was not present.  The  mashgiach  must review the production area and records to ensure there are no  keilim  (equipment) issues,[2] and monitor  kashrus  safeguards in place (e.g., there are no compatible non-kosher ingredients).

C)    Additional Steps Advised For  Mashgichim :  File a detailed written report and indicate any discrepancies.  Know when a problem requires immediate attention and respond ASAP.  Possess excellent technical knowledge of the plant.  Companies respect this and, more importantly, the  mashgiach  is more likely to ascertain problems that affect  kashrus . Keep all information confidential.  Never share information with Company A about Company B. Never discuss other  kashrus  agencies with plant personnel – especially in a negative manner.  Follow up on previously raised issues and review oldpolicies, as well as  piskei halachah , to confirm that they are still applicable to the current production setup.  Discuss issues with the  Kashrus  Administrator and, when necessary, ask for a conference call with the STAR-K Rabbinic Administrator, Rabbi Moshe Heinemann,  shlit”a , who is readily available to offer his assistance.

Maintain the necessary frequency of visits, and inform the office if the factory should be visited more often, or if the designated frequency can’t be met.  Notify all necessary agencies when a plant has dual  hechsherim.  Carefully follow in-house factory policies. Sometimes, legal issues must also be taken into consideration in case of a possible mishap, for example if  kashering  at high temperatures or with a blow torch is dangerous or could ruin the equipment.  Therefore, there are times when certification may be impossible. Maintain a good relationship with other  kashrus  agencies and their field staff.  Be courteous and on time (when an appointment is scheduled, for example to kasher ).  Maintain a good relationship with plant personnel.

Factories can be enormous operations, and many steps are necessary to certify a product.  The “chain” of all steps involved is only as strong as its weakest link.  The mashgiach  forms a critical link in this chain.  The STAR-K takes pride in its mashgichim , who travel to all corners of the globe, and work at all hours of the day and night to ensure that the food that ends up on the tables of kosher consumers worldwide meets the highest  kashrus  standards.


[1] The article will focus on ongoing visits of facilities that are certified by STAR-K and will be addressed in a general manner.  It is not meant to be a comprehensive guide for  mashgichim .  Furthermore, plants that require  kashering hashgacha  of food service establishments, and setting up a kosher program in facilities by performing an initial inspection are beyond the scope of this discussion.

[2] See Section II, Product Approval, for a brief discussion about equipment.