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Ou Kosher Publishes New Manual for the Food Service Industry How to Read a Bill of Lading

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ww ww VOL. t f / NO. 1 CHESHVAN 5773 / NOVEMBER 2012 s xc THEDaf a K ashrus A MONTHLYH NEWSLETTER FOR THE OU RABBINIC FIELD REPRESENTATIVE first is that the commodity indeed comes HOW TO READ A BILL OF LADING from the approved source. Second, he will RABBI GAVRIEL PRICE want to see that the oil is shipped in a tanker RC Ingredient Research trailer that is kosher certified. Since the BOL identifies not only Midwest Transport AN RFR sometimes has to do detective Iowa Vegetable Oils (IVO) hires Midwest but also the specific trailer number, the work to determine whether a bulk commod- Transport to ship 45,000 gallons of veg- mashgiach will cross reference that number ity originated from an approved source. Let etable oil to Pennsylvania Potato Chip (PPC) with Midwest Transport’s kosher certificate us say a mashgiach is visiting Pennsylvania a series of transactions takes place: IVO (certified companies should retain the cer- Potato Chip Company, and the only vege- transfers custody of the product to Midwest tificates for the transportation companies table oil approved on his Schedule A is from Transport who, upon delivery, transfers cus- used to bring product to their facility). In Iowa Vegetable Oils. If the vegetable oil is in tody to PPC. A BOL is generated that mini- cases where a product is only acceptable a drum or tote bearing a label stating “Iowa mizes the legal issues that can arise as the when sealed under rabbinical supervision, a Vegetable Oils” and the relevant kosher product moves along this chain of custody. mashgiach should also cross-reference the symbol, the problem of origin doesn’t begin. It identifies the Shipper (IVO), the Carrier actual seals with those identified on the bill But most of the time vegetable oil is stored (Midwest Transport) and the Consignee of lading. Unfortunately there is no standard in a tank with no identifying features indicat- (PPC). It also identifies the type of product form for presenting information on a BOL, ing the oil’s origin. How should he verify (vegetable oil), the specific unit in Midwest so some careful reading is needed to find the vegetable oil indeed came from Iowa Transport’s fleet used to actually ship the what is pertinent. Vegetable Oils? product, and the seal numbers physically In the vast majority of cases the BOL will applied to the trailer. The resource mashgichim most commonly be sufficient for a mashgiach to confirm that use is the bill of lading (BOL) associ- The mashgiach at PPC should use the BOL a commodity originated from its approved ated with shipment of the product. When to satisfy two distinct requirements. The continued on page 2 OU KOSHER PUBLISHES NEW MANUAL PUBLICATIONS FOR THE FOOD SERVICE INDUSTRY SO YOU’VE attended a sit-down Bar Mitzvah but for other kashrut organizations, local or wedding for 600 at a luxurious hotel, with the Vaadim, and kashrut professionals who are meal strictly kosher, and your major concern is seeking guidance in this complicated field of how much to eat at the smorgasbord, so as not to kosher food service. spoil your appetite for dinner. This is the fifth in a series of OU manuals, That is because you know that the hotel’s following its predecessors on baked goods; kashrut is under the supervision of the Orthodox fish; oil; and the most recent, the third edi- Union, and as a result, there is no concern for tion of “Checking Fruits and Vegetables,” the skills of the mashgiach or mashgichim who which rolled off the presses just before are stationed in the hotel’s kitchen to keep a Passover this year. very keen eye on the food preparation and ser- “Kosher food service supervision has evolved vice in all of its aspects. into a complex industry which requires both Now, with the publication of the OU Manual strong management skills and a broad knowl- for the Food Service Industry, the complexity edge of halacha,” declared Rabbi Yaakov of supervising hotels, catering halls, synagogue Luban, OU Kosher Executive Rabbinic kitchens and other locales where meals are Coordinator and Editor of the Manual. prepared for large gatherings, is set down “The OU is fortunate to have on staff an for the benefit not only of OU Kosher staff, continued on page 4 Published by the Orthodox Union, Eleven Broadway, New York, NY 10004 Please direct your comments to RABBI YOSEF GROSSMAN, EDITOR at 212-613-8212 or [email protected] BOL source. However, was able to provide a complementary BOL Smolensky (senior RFR, Chicago) pointed continued from page 1 there are potential that identified the approved manufacturer as out that (back to our original case) IVO limits to its use- the Shipper and the Consignee (that is, the may be the Shipper of record, but really the fulness. The BOL receiver) as the Newark trading firm. The product is coming from a depot someplace described above identified IVO, the manu- seal numbers noted there were identical to else. Everything matches the Schedule A – facturer, as the Shipper. This is standard those on the BOL for the Newark-Kansas but, and a big but – if you look carefully at practice in the transport of kosher certified shipment. The ISOcontainer, it seems, had the BOL you notice that the point of origin goods, since most commodities are only been shipped from Italy to Newark, where has something called Marigold listed, and acceptable from specific manufacturers. A it was held before being shipped again to there is a lot number of BRTX12345. Now, BOL can, however, identify the broker as the Kansas City. someone in the field who is hopefully astute Shipper of goods, recognizes that the lot number is remark- and not the man- ably similar to a rail car registry number. ufacturer. In this And what is Marigold? Turns out, IVO ships case the BOL is their vegetable oil via rail car to a depot in useless to a mash- Chicago which in turn transfers that oil to a giach or, at best, a piece of a puzzle truck and sends the truck to a local customer. that needs to be Only problem, is Marigold certified? Are completed. they pumping kosher and treif in the same hoses? Are there holding tanks that may be Identifying the treif? broker as the Shipper is used in In this case, a mashgiach/RC would be a “blind” BOL. obliged to research the status of the depot. The broker wants A BOL can be an instrument of subterfuge. to keep the iden- What if IVO notices that its vegetable oil tity of the man- has failed internal quality specifications, but ufacturer from it desperately needs to make good on an the customer so urgent order to PPC? It might send trailer he can remain 613, from Midwest Transport, to its com- the middleman. petitors, Missouri Vegetable Oil, to fill the This is a perfectly order for them. If IVO is keen on ensuring legal, and com- that PPC does not think anything is amiss, mon, stratagem. It is unacceptable, the IVO name, not Missouri Corn Oil’s, will however, in an occupy the section titled Shipper (which, arrangement when after all, it is). This scenario is conceivable the commod- in theory but, for a number of practical and ity is approved probably legal reasons, not at all likely. only from Rabbi Smolensky pointed out that the wash manufacturer(s) ticket associated with the trailer that deliv- specified on a ered the product may be helpful in evaluat- Schedule A. ing the validity of a BOL (a wash ticket is If a mashgiach issued by the facility that washes a trailer does find that the before it picks up its next commodity). If a Shipper identi- BOL identifies the Shipper as IVO (i.e., in fied on the BOL is not the manufacturer Another potential resource when dealing Iowa) but the wash ticket is from a facility in approved on the Schedule A and the Shipper with a blind BOL is a certificate of analysis Birmingham, Alabama, an eyebrow should (COA). This document provides data about is confirmed to be a broker or distribu- be raised. tor (and not simply an unapproved manu- the physical and chemical properties of a When in doubt, a mashgiach/RC can and facturer) he may nevertheless be able to sample taken from a specific lot of product. put together a picture of the supply chain It will be generated by the manufacturer of should communicate with the mashgiach reaching to the original manufacturer. For the lot, and bear its name. If a mashgiach can at the approved manufacturer, who should example, recently a mashgiach encountered relate the specific lot identified on the COA either know first-hand or be able to review an ISOcontainer (essentially a large, mobile to a specific lot in the plant he’s visiting, he’s shipping records to confirm the kashrus of storage tank) holding refined grapeseed oil performed his job. However, a broker who is a shipment. The main point is to be patient at a Kansas City food production plant. The keen on concealing the identity of the manu- and use good judgment when determin- mashgiach duly reviewed the BOL, which facturer will be careful to change the name ing whether a BOL faithfully demonstrates identified a trading firm in Newark as the on the COA to his name – again, all without that a bulk commodity originated from an Shipper. The seals on the BOL matched necessarily indulging in anything deceitful. approved supplier. It nearly always will.
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