By Kasriel Oliver posted October 14, 2016
One of the most important functions for me to perform, at a Kashrut audit at a processed-food factory, is to assess the formulations of the products.
The most important aspect of the formulation is the list of raw-materials, often called “bill of materials” which are the names of the components in the finished product.
One may have thought that one could assume that the names of the raw materials, in the formulation, would be the same names as the raw materials that I would find when performing an on-site inspection of the raw material warehouse. Not necessarily so! One may have thought that if there were slip-ups, and inconsistencies between the computer print-out and the actual raw materials in the warehouse, this phenomenon would have a greater probability of occurring in a small unsophisticated company than in a large sophisticated multi-national company. Not so!
We need an analogy...This is where the biro’s and band-aids enter! Biro is a brand-name of the Bic company and the name biro has become a common name for a ball-point pen. The pen may be a Pentel brand or a Pilot brand – but may still be referred to as a biro. Similarly band-aid is a brand-name of Johnson & Johnson. Other bandages that have a similar appearance and perform the same function as a band-aid, may be made by various companies and hence they are not a “Band-Aid” product. Yet they are commonly referred to as a “Band-Aid”.
This practice also takes place in the food industry, and it may present in an unsavoury manner during a kashrut audit. For example, a common food ingredient is Xanthan gum which is used as a stabiliser or thickener in many processed foods.
“Keltrol” (like “Band-Aid” and “Biro”) is one of the most commonly used brands of Xanthan gum and it may be listed in the official and confidential formulations, as the name of the raw material. In fact, when inspecting the raw material stores another brand or brands of Xanthan gum are used, that may not be kosher, unlike Keltrol which is kosher-certified. Thus, the inspection of the raw material stores reveals which brand of xanthan gum is actually used. Then we must ascertain whether that brand is kosher-certified. Often the manufacturer refuses to change the raw material name in the formulations from Keltrol to Xanthan gum!
Upon further investigation, it is revealed that there are several brands from several suppliers, of Xanthan gum, that are “approved for use” in the formulation. In actual fact, only one or two brands may be used at any one time.
My function is to ensure that all the brands of the Xanthan gum that are approved for use, by Quality Control in the factory, are in fact kosher-certified, whether the brand is being used or not at the moment.
Another example is Medium Chain Triglycerides (MCT), which is an oil product that requires Kosher Certification. This may be listed in the formulation as “Miglyol” which is a brand-name of MCT. At one multinational food-ingredients manufacturer I asked the Chief Chemist to stop referring to the Miglyol brand! In 20 years of auditing that factory, I can assure you, they never used the Miglyol brand of MCT – yet they still insist on referring to the raw material as Miglyol. In fact several other kosher brands of MCT are used interchangeably.
Tween 80 (another “Biro”) is a popular brand name of Polysorbate 80 which is polyoxyethylene sorbitan mono-oleate, a food emulsifier. It requires Kosher certification. It may be listed in the formulation as “Tween 80”, yet Tween 80 may not be used and often was never ever used. “Lipo” brand or “Crillet” brand or others may be used, yet the company insists on listing Tween 80 as the raw material name.
Even more frustrating are the large manufacturers with hi-tech infrastructure who perform tests and evaluations on incoming raw materials, and then put a sticker on the raw material drum or the box, with the “band-aid” or “biro” name on the sticker that the product is approved for use. So, on the drum or the box is a label that states that the product is one brand, and there is another label that states that the product is another brand. The internal “approved for use” labels and the manufacturer’s labels may be different brand-names of the same product. The name that is incorrect and may not be “approved” is the “approved for use” brand, i.e.; the name in the formulation that may not reflect reality. The brand that is in fact being used is as per the manufacturer label.
But what is the Kosher audit procedure when the internal “approved for use” label is stuck over the top of the real manufacturer's label? I would need to write another article on that subject!
Did you enjoy your time in the land of “biros” and “band-aids”?