By Rabbi Yair Hoffman for 5tjt.com
This is the first of a series of two articles on Kashrus.
Most people are aware of the recent discovery that Restaurant Depot seems to be the main supplier of meat for a “Kosher” Chinese restaurant in Route 9 in Manalapan, New Jersey called Kosher Chinese Express. Many people are aware that the owners had a “history” of non-compliance with rules as well. And some people are aware that the owner of that restaurant, allegedly, had his own keys to the place.
In light of all of this, we need to ask ourselves the following question: If a hashgacha is being paid by the food establishment itself, does this not create an incentive for the Kashrus agency to look the other way, and or obscure critical information?
FATALLY FLAWED
Our system of Kashrus seems to be fatally flawed the way it is currently structured. Especially during Elul, we need to figure out how to fix it. Things just keep happening again, and again, and again.
In 2009, researchers Bernard Lo and Marilyn Field published a book called, “Conflict of Interest in Medical Research, Education, and Practice.” In the book, authors Lo and Field defined a conflict of interest as follows: “A conflict of interest is a set of circumstances that creates a risk that professional judgement or actions regarding a primary interest will be unduly influenced by a secondary interest.”
It is a little strange that the Kashrus system we have in place in this country is rather counter-intuitive in terms of its structure. The incentives or negiyos – are in the wrong places. If a hashgacha is being paid by the food establishment itself, does this not create an incentive for the Kashrus agency to look the other way?
SIMILAR PROBLEM IN ACCOUNTING
In the 1980’s and 1990’s, the entire field of accounting had a similar problem. The way the system worked was such that false information in terms of the financial health of a company was put out there and investors were being ripped off. Incomes, for example, were being misstated. Financial audit statements made companies look rosier than they actually were. Supposedly “independent CPAs” merely took the information from the self-generated company reports and spit it out as fact. They did this even though there were blaring red flags.
In response to this comical situation, the government passed the Sarbanes–Oxley Act of 2002. It is a United States federal law that set new and expanded requirements for all U.S. public company boards, management, and public accounting firms. It included criminal penalties for those who violated it. The reason for the problems was the counter-intuitive structure.
The problems in accounting still exist. Indeed, the SEC regularly comes out with new regulations on this account. The solution for the accounting problem is that there should be more watchdogs for the auditors: Hechsherim for the Hechsherim, so to speak.
When the inspector is paid by the people that he supervises there is a risk that his judgement and actions will be unduly influenced. The same is true, to an extent, for the supervisory agency. The health safety of the restaurant consumers has been placed at risk. Indeed, the general public has also been placed in danger.
An auditor friend of this author told me, “I once heard a mashgiach refer to his “boss” as the store owner and not the kashrus agency he was working for. As an auditor, I was horrified.”
SAME FOR KASHRUS
The same should be true in the field of Kashrus. The mashgiach is there to protect the public from eating non-kosher or questionable items just as the health inspector is there to protect the public from anything that can compromise their health and safety.
RAV MOSHE FEINSTEIN ZT”L
Indeed, the Gadol haDor of the previous generation, Rav Moshe Feinstein zt”l in his Igros Moshe (YD Vol. IV #1:8) writes this very idea. Rav Feinstein states that the Mashgiach should not be paid by the facility that is receiving the hashgacha, but rather should only be paid by the Vaad HaKashrus itself. Indeed, he should have no direct monetary business dealings with the company.
Let’s imagine the following scenario involving a Health Department:
It was an innovative way of saving money. The municipality worked it out that they would outsource the financial cost of the Department of Health inspectors. From now on, it would be the restaurants themselves that would hire the health inspectors. The restaurants would pay them, they would take out the FICA taxes, the worker’s comp – the restaurant would handle it all.
The move “worked wonders” for the state of health in the restaurants. Eateries that were previously designated with a C minus rating – were now rated A plus plus. There were far fewer health-violation-write ups too.
The astute reader will detect an obvious problem here. This is what is called a classic conflict of interest. The upgraded rating and lowered violations are probably due to the unique financial arrangement.
The above story of the health inspectors that were paid by the restaurants was fictitious, of course. Unfortunately, the analogy to Kashrus is anything but fictitious. It is reality.
Kashrus agency after Kashrus agencies coordinate the supervision in a manner that is in direct violation of this Igros Moshe and of common sense.
A HISTORY OF FOUL UPS
It is not just Kosher Chinese Express. In recent years, there have been numerous instances of kashrus foul-ups. Indeed, the situation is somewhat akin to the wild west. Most people remember the treif chickens in Shevach Meats in Monsey, New York. There was Jin Glatt Chinese Kosher in Passaic New Jersey whose hechsher was removed suddenly. There was also Stan and Pete’s – the main caterer in Johannesburg, South Africa. It was found to be serving treif as well. There was Doheny Glatt in Los Angeles, California. These incidences are happening again and again and again with no respite in sight.
FOUL UPS WE DO NOT EVEN KNOW ABOUT
There are also Kashrus foul-ups that we do not even know about. Serious local ones, serious national ones, and serious international ones.
WILL IT HAPPEN AGAIN?
The question arises as to whether or not it will happen again or did these incidences teach us all a lesson? An expert in the Kashrus industry who is both well-known and well-respected remarked, “It is not a question as to whether or not it will happen again. It is rather a matter of when will happen again.”
The community at large needs to speak up to prevent this from happening. Feeding Tarfus to Klal Yisroel is not something that we should sit by and accept.
MAY BE A VIOLATION OF DVARIM
The situation needs to be rectified. It could very well be that allowing a conflict of interest to continue may be a violation of the Torah prohibition of “v’asisa hayashar v’hatov – You shall do the just and the good” (Dvarim 6:18).
The Ramban explains that the Torah gave this general Mitzvah because it cannot relate to all cases and eventualities that might arise. Therefore, the Torah covers all situations with a general instruction of acting in fairness and justness. In all his ways, the individual is bound to the “just and the good.” Many Poskim point to this pasuk as being the source of the obligation of acting lifnim mishuras HaDin – above and beyond what strict halacha dictates. How can there be an obligation of going above and beyond the law? Would that not, by definition, be a non-obligation?
In explanation as to why the situation in kashrus remains in a state of built-in conflict of interest, we turn to a position paper presented by an Executive Rabbinic Coordinator, at the ASK -RCA Yom Iyun held at OU Headquarters, in New York City on May 1st, 2007.
The position paper stated as follows:
“It is self-evident that it is preferable that a Mashgiach be paid by the Kashrus organization and not by the supervised facility.
Unfortunately, this is generally not a viable option for semi or full-time Mashgiachim of establishments because of insurance considerations.”
It is unclear what is meant by insurance considerations. This author knows of at least a dozen insurance brokers that would gladly offer any hechsher insurance for a full staff of mashgichim. What is probably being referred to is that the kashrus agencies cannot underwrite the payroll and its insurance if the restaurants are late in paying. But this can be rectified if the restaurant is made to pay these fees in advance.
If Kashrus is something that we truly care about – then we really need to re-structure things from the ground up. Also, when an error or problem is found, we should all use our collective heads to figure out how to resolve the problem. This cannot happen with the prevailing lack of transparency that exists in our Kashrus system. What happens now is not ideal nor acceptable.
Let’s say, for example, that an unkosher product is found in a restaurant. The mashgiach reports it to his supervisor at the hechsher (and even that is a maybe). The hechsher decides to fine the restaurant, sometimes to the tune of tens of thousands of dollars. We, the public end up hearing nothing about it. And neither do the other organizations – and an opportunity to improve is lost.
THREE SUGGESTIONS
The first suggestion is that the kashrus agencies should place a five percent surcharge on all of their hechsher income to go to an independent agency that supervises all of the hechsherim. The stress is on independence. Unfortunately, there are stories and problems with almost every single agency.
The second suggestion is that we should raise funding to employ roving kashrus inspectors to supervise if the salads we are eating are even being checked for bugs and if they are to see if they are being checked adequately. They should be paid separately, somehow. Perhaps a group of wealthy individuals could fund it.
THE PEO OPTION
The third suggestion can address the Rav Feinstein zt”l issue. In the United States and elsewhere, there are companies called PEOs – professional employer organization. A PEO is a firm that provides a service under which an employer can outsource employee management tasks. These include employee benefits, payroll and workers’ compensation, recruiting, risk/safety management, and training and development. A PEO could be hired to take over all of a hechsher’s mashgichim. We also need to significantly raise their income level to ensure that our standards of kashrus be improved and not lessened.
Regardless, the issue should be addressed by the Kashrus associations.
The author can be reached at [email protected]
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21 Responses
Re The Problem: “If a hashgacha is being paid by the food establishment itself, does this not create an incentive for the Kashrus agency to look the other way?”
“The first suggestion is that the kashrus agencies should place a five percent surcharge on all of their hechsher income to go to an independent agency that supervises all of the hechsherim.”
All that does is push the problem a bit further down the line. To re-phrase the original Problem:
If the independent agency is being paid by the kashrus agencies themself (5% of all the income of the kashrus agency’s revenue), does this not create an incentive for the independent agency to look the other way? The “independent” agency now has a conflict of interest!
To prevent this conflict of interest by the new “independent agency” watching over the kashrus agency, we need to create another independent agency watching the independent agency that watches the independent kashrus agency.
But alas, who will watch the independent agency that is watching the watchman? Who will watch that watchman who is watching the watchman watching the independent agency that is watching the kashrus agencies?
This sounds like a Story from the Wise Men of Chelem.
Oh, the response will be that the suggested independent agency is run by well-known rabbonim who are of high moral standards making them unencumbered by financial incentives, yirei shomayim and lamdonim (even though they are collecting 5% from the revenues of each “customer” kashrus agency and would have a great loss if they disqualified a kashrus agency customer).
Well, that is the original premise for the standard of all reliable kashrus agency! – that reliable kashrus agencies (such as national hechsherim like the OU or small chassidishe hechsherim) are “run by well-known rabbonim who are of high moral standards making them unencumbered by financial incentives, yirei shomayim and lamdonim.”
We can trust a reliable kashrus agency run by yirei shomayim EVEN though they have a “conflict of interest” because they are erlich. That is how it was done for generations. True it isn’t perfect, and there are times that they were deceived or made errors that led to the public eating treif or chometz etc, but humans aren’t perfect. One thing is certain, new solutions bring new problems.
Aside from pushing the problem down the road, by requiring watchmen on the watchers of the watchmen, to quote chazal say: im kain ein ladovor sof, there is another problem with the solution suggested.
The solution presented also will INSTANTLY add 5% to the price of kosher food of establishments that have this “uber” heshcher (boasting a hechsher on the hechsher), while other kosher food establishments will be 5% cheaper (for those that are not makpid on the uber hechsher).
This is like the Hershy’s twizlers that carry an OU hechsher, but for approx 15% increase in price, the identical Hershy’s twizlers will have a sticker attached on them with an uber private hechsher of another kashrus agency (a hechsher on top of the OU hechsher).
[Side note: there might be justification for the double hechsher due to twizlers possibly being mezonos, a “pas”, needing to avoid pas paltur, but the point is simply to illustrate the price difference between a single hechsher vs a double hechsher].
Let’s leave the solutions of the Wise Men of Chelem to the comical Stories of Chelem.
If any expressions that I wrote are disrespectful, I am asking mechila and that is not my intention. Rather I am adding to the debate, rischa d’oratsa, pilpul chaverim, as we plow through this difficult sugya.
Rabbi Hofman, in your neck of the woods the problems are more severe than anywhere. Many establishments have “working mashgichim” who get there full parnassah from the establishments they supervise. I anybosy brings up any issue about the local kashrus, they are bullied and vilified. The Rabonim involved who back the kashrus organazation are clueless about hashgochos or kashrus, and have no idea what is really going on.
Example: A local establishment sent some of their checked produce to Lakewood. It turned out it was infested. They were caught in Lakewood. Solutuion?!? They no longer send to Lakewood. Keep the bugs local. Bodek was never fired.
This same bodek had “checked clean” Romain lettuce throughout the summer, even during the weeks of high infestation, when nobody else had.
Last week there was heavy infestation in fresh dill. Bodkim all over the tri-state area could not get it clean. But the same establishment mentioned before had no problem selling fresh checked dill.
Did this raise a red flag? Absolutely not. Because if anybody raises the issue, the person will be attacked and the problem will never be addressed.
Rabbi Hoffman, please clean up at home, them take care of the rest of the world.
When the Torah allowed Eid echad, chazaka, and rov, was the Torah guaranteeing a 100% foolproof method of kashrus, or was the Torah allowing us to function but accepting that there won’t be 100% compliance? Meaning, is 100% foolproof kashrus a halachic requirement?
Here is a true story which happened 40+ years ago and within 60 minutes of Lakewood.
A non-religious Jew had a hashgocha for his restaurant. He hired a kid named Chris to work in the deli restaurant. Chris was a high school classmate of my non-religious niece.
One day, Chris shared with my niece, “I do not understand my boss at the deli. He buys his meat at the market next door and pays retail prices. My father is in the wholesale meat business and could sell him meat at wholesale prices, but he refuses to buy from my father.” My niece immediately realized the problem.
My niece told my sister-in-law, who called us. I immediately contacted the Rav HaMachshir and related the story. He did not withdraw the hashgocha. I related the story to a famous kashrus expert who told me, “When they started that hashgocha, they asked me if they needed a mashgiach tmidi or whether a yotzei v’nichnas was sufficient. I told them that min hadin a yotzei v’nichnas was sufficient. However, I advised them that as more kolel families move in the area, they had better upgrade to a mashgiach tmidi.”
Several weeks later, the rabbi’s wife was shopping in the market next to the deli and she observed the deli owner making food purchases, including chicken and beef. She watched him check out and surreptitiously followed him out of the market. He carried all the food into his deli. Within a day, the rabbi had withdrawn the hashgocha.
Perhaps the author makes some points however a little bit of knowledge is a lot dangerous.
If the author has such wonderful ideas, why doesn’t he get in touch with AKO and ask to present them at an upcoming conference?
I was reading through some of these things and I have to say I was laughing because there is a yenta group on Facebook called Great Kosher restaurants. Unfortunately the word kosher there is a misnomer because whenever something happens in relation to kosher, it’s always the Kashrus agency is always the first ones that be people in the group jump on, to attack. They also have no problem promoting establishmens that have poor if any certification, as long as somebody makes a claim of kosher it’s good enough for them. The moderator then gets his 2 minutes of fame being quoted here in “Yeshiva” World News.
The bottom line is if the author has anything positive that he feels he can give over to an international group of kashrus professionals, he should contact AKO and see if he can give a presentation at an upcoming conference.
I find it remarkable that Rabbi Hoffman is expressing, point by point, the reasons Matan Kahana gave for his Kashrus reform, for which he has been vilified endlessly. For years, the D”L community which relies religiously (pun intended) on the hechsherim of the Rabbanut, voiced its concerns that mashgichim are paid directly by the businesses that they supervise, that there is essentially no supervision on the supervisors and that there is no real competition where the local supervision is questionable. So minister Kahana put together a reform by which businesses would no longer directly pay the masgiach, the Rabbanut would supervise the supervisions and where it was possible to have local competing hechsherim.
חמירא סכנתא מאיסורא
During the past 12 months, I heard of at least 11 stories that happened in NY and NJ (including Lakewood) that some how by mistake dairy ice cream was being served for desert after a Fleishig (meat) meal at a catered Simcha. One time this mistake happened in a Fleishige (meat) restaurant in Lakewood. It could be it happened more than once. One time dairy chocolate was at the Sweets Table at a catered Fleishig meal.
I don’t know where the Mashgiach was during these 11 stories.
Danger:
A woman in Israel died last year from dairy ice cream, due to the fact that she was allergic to dairy. She ordered ice cream after a meat meal assuming that it will be pareve.
My best advice:
If you are allergic to dairy, stay away from ice cream at a catered Simcha. Also be careful, sometimes the chocolate syrup that they put on vanilla ice cream can be dairy.
Eat at home.
i posted above a comment pointing out the flaw in the solution presented by the esteemed author in addressing the “conflict of interest” problem.
I was asked to propose my own solution. Here it is:
Kashrus agencies enter into a contact with the establishments under their hechsher.
Kashrus agencies MUST include a clause in their contract with establishments, that if the establishment wilfully breaches the standards of kashrus, aside from immediately losing their hechsher, the establishment will pay the kashrus agency a specific large sum of dollars (e.g.$1 million) for damages they inflicted on the reputation of the kashrus agency.
It is common to include in a contract a clause that addresses the penalty for breaching the contract!
If such a clause is included, now the kashrus agency has a huge incentive to bust the establishment for the slightest breach of kashrus standards. We just turned the conflict of interest into a motive to catch the establishment if they are cheating!
Such a clause also creates a huge “mirsas” (fear) on the establishment, a disincentive from the benefit of saving a few dollars vs the huge cost it could inflict on their business.
Kulanu chachomin, kulanu nivonim – our collective intelligence can easily adjust the current practices of kashrus agencies to plug the holes in the system, WITHOUT changing the system or creating new agencies to watch the agencies that watch the independent agencies that watch the kashrus agencies…
Business is Business.!!!!
Frumkit is Reserved for Shul ONLY and NOT in dealing with spouse and children.
Tip your feather hat a bit to the left and you are Frum, then you can cheat in business, treat your kids like they are encroaching on your time, disrespect your father, mother, say lashon Hara, but in Shul you must listen to everyones problems and yell out your donation so people can hear you and be baal Chessed.
Isn’t that what they teach in Yeshivos by role models and rabbis?
BUSINESS IS BUSINESS.
You want Kosher food? Go home and ask your maid (wife) to cook for you.
Eating at home or at your rebbe’s tisch is the only 100 percent foolproof option (and even then you are reliant on the hashgacha of the markets where you or your wife purchase the fresh produce you cook at home). Eating at a restaurant has its own issues and unless your LRP (or someone else whose attention to kashruth is more rigorous than your own) is a regular at that establishment, probably avoid it. Finally, there is also the question of the “quality” of the mashgichim employed by commercial establishments. Without being harsh, the yidden I’ve seen at many restaurants appear distracted, uninterested and bored with their work. Some sit at a table in the corner with their head in a sefer or seemingly staring for hours at their phones. I’ve even seen some napping. Their interaction with the waiters and kitchen staff is minimal.
Its easy to say “what you pay for is what you get” but at times, that seems to be the case with mashgichim.
Rebbitzen Goldenpickanicerscreenname ‘s idea sounds very good. Obviously with inflation the paltry sum of one million dollars would need to be raised.
I think it was about 20 years ago. A guy I know, (a simple fellow in learning, who knew zero about Yoreh Deiah,) got a job from one of the major kashrus agencies to be the mashgiach in a meat restaurant owned by a goy in Deal, NJ.
One day, this mashgiach sees a bottle of dairy cream in the kitchen’s refrigerator. He asked the chef, what’s this doing here. The chef responded, he must have it for one of his popular (meat) dishes.
The mashgiach immediately called the kashrus agency. They told him to wait right there, do not speak to anyone, and they are coming. The big honchos from the kashrus agency arrived, told the mashgiach to leave, not tell anyone about this, and he will be paid for the whole day. They said they will take care of any infractions and thanked the mashgiach for catching this and for calling them.
The mashgiach told me the story.
There was a similar “incident” in a goy-owned restaurant in Flatbush Avenue J caught selling treif hot dogs. He ran out on a busy night and the only nearby place open was a treif grocery. He had a worker buy a bunch of packs of treif franks. One of the customers saw a bunch of those treif wrappers in the garbage. (It was a small tight place.)
Years ago, the Jewish Press would often list restaurants that violated “NYC Kosher Laws” and were fined “$200.”
My father a”h taught us, OK to eat out if you want, but only if the fleishig restaurant is owned by a frum yid, not a goy or irreligious Jew. It starts with that, then ask about the hashgachah and shechitah.
I taught my family this.
That is why we never ate from this Manalapan store or from that Deal place.
Years ago we were invited to a close relatives sheva brochos in a very upscale Manhattan restaurant. I called and asked for “the rabbi.” I asked him if the owner is frum. He told me he is not, but he is the mashgiach blah blah blah… I told my wife a”h we cannot go. That very week, that restaurant was reported in the Jewish Press as having violated NYC Kosher Laws and was fined $200.
Sometimes the parve ice cream tastes just too good…
>> The first suggestion is that the kashrus agencies should place a five percent surcharge on all of their hechsher income to go to an independent agency that supervises all of the hechsherim.<<
Raising the hechsher charge to the restaurant will have the restaurant raise the prices to the consumers.
I think the kashrus agencies make enough money that they can pay this to keep themselves in line.
>>The first suggestion is that the kashrus agencies should place a five percent surcharge on all of their hechsher income to go to an independent agency that supervises all of the hechsherim.<<
Raising the hechsher charge to the restaurant will have the restaurant raise the prices to the consumers.
I think the kashrus agencies make enough money that they can pay this to keep themselves in line.
As follow up to my earlier proposed solution and to address the comment of 1a2b3c regarding the contractual monetary penalty clause needed for any establishment breaching the agreement with the kashrus agency –
To keep it in focus, the concern raised by the author was the conflict of interest that the kashrus agency would have a financial loss of their customer if they revoke the hechsher.
To address that concern, if the kashrus agency must revoke their hechsher and still be fully compensated by thecestablishment – say, the annusl hechsher fee x 5 (or 10), that removes any concern of conflict.
Plus, it inflicts financial pain on the establishment, that now must pay for the hechsher fee without getting the hechsher and the income it generates.
This in itself creates a disincentive for the establishment to cheat and deceive the kashrus standards. And it creates an incentive for the kashrus agency to hold the establishment’s feet to the fire.
Now I will address a comment someone told me, “Rebbitzen, if the contract has a penalty ckause, no establishment eill agree to getting the hechsher! It would drive away all the business from the kashrus agency!”
That is a fallicy. The clause simply states that the establishment won’t cheat and will be honest orcelse therecwill be $××× penalty for cheating. An honest sincere establishment won’t have trouble with that. But yes, it will weed out those that plan to get a hechsher and cheat. Which is a good thing!
From what I can tell, restoring (or attempting to make stronger, constitutionally acceptable) NYS’s kosher consumer protection laws don’t seem to be part of Gov. Hochul or the state legislature’s agenda.
[Typos corrected] As a follow-up to my earlier proposed solution and to address the comment of 1a2b3c regarding the contractual monetary penalty clause needed for any establishment breaching the agreement with the kashrus agency –
To keep it in focus, the concern raised by the author was the conflict of interest that the kashrus agency would have a financial loss of their customer if they revoke the hechsher.
To address that concern, if the kashrus agency must revoke their hechsher and still be fully compensated by the establishment – say, the annual hechsher fee x 5 (or 10), that removes any concern of conflict.
Plus, it inflicts financial pain on the establishment, that now must pay for the hechsher fee without getting the hechsher and the income it generates.
This in itself creates a disincentive for the establishment to cheat and deceive the kashrus standards. And it creates an incentive for the kashrus agency to hold the establishment’s feet to the fire.
Now I will address a comment someone told me, “Rebbitzen if the contract has a penalty clause, no establishment will agree to get the hechsher! It would drive away all the business from the kashrus agency!”
That is a fallacy! The clause simply states that the establishment won’t cheat and will be honest, or else there will be a $××× penalty for cheating. An honest sincere establishment won’t have trouble with that. But yes, it will weed out those that plan to get a hechsher and cheat. Which is a good thing!
Such a clause MUST be included in all kashrus agency contracts with restaurants (note: food production establishments/factories need other types of clauses with different considerations – they are not the subject of this article).
This is practiced widely and sometimes exclusively in countries such as the People’s Republic of China, Taiwan, South and North Korea, Japan, Vietnam and Hong Kong.
If a patient became sick, the doctor would not be paid until the patient’s health returned. This notion is not as ridiculous as you might imagine. It is a basic philosophy of Chinese Medicine that has been practiced for over 3,000 years – the prevention of disease and the maintenance of health.
The kehillah pays the rav or kashrus supervisor .
as long as the costumers are “healthy” – eating kosher food, the restaurant does not have to pay.
the restaurant etc pays only when they did NOT keep the kashrus standards and then they pay a hefty fine.
Final point to add to my earlier comments: The author refers the reader to kashrus “foul ups” and brings the examples of mass fraud and deceit. Foul ups are errors, mistakes happen (sometimes more often than expected). Mass deceit and fraud against the kosher consumer is rare.
The common errors and mistakes are not publicized (except the occassional “kosher alert”). The are frauds are well publicized and draw public attention.
But let’s not forget, they are rare.
To parallel this with other consumer activity, it is common that an error will be made when buying items from an establishment. The gricer may overcharge you, gave you too few or extra items etc. But mass fraud by a business against consumers is rare. It makes headkines but it is rare.
The takeaway is, establishments are generally not out to deceive the kosher consumer. They might make honest mistakes but generally are not out to defraud. There is little benefit for the consumer to treat each establishment as if it is run by crooks.
The mistakes are prevented by better training of kashrus agencies and mashgichim, sharing expertise between kashrus agencies and continued professional development. This is the real risk that needs to be addressed. It doesn’t get the publicity but is the weakness of all kashrus agencies.
Let’s not call deceit and frauds “foul ups”. The deceit and fraud must be sued for breach of xontract and enforce the penalty clause of $1 million (or 10 years of hashgocha fees) to accomplish general detterance l’man yishmiu v’yirou v’lo yazidu od.
Bimchilas kvod harav, this is the solution.