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KEEPING KOSHER CITRIC ACID ON PASSOVER
by Rabbi Bernard Levy
To continue our policy of taking our homemakers behind the scenes so that they will have a better under standing of what is involved in certifying a product as O.K. Kosher for Pesach or year-round, we are bring ing the following to your attention. It represents ex tensive observation and analysis by outside experts, in addition to intensive personal attention and on-the spot inspection.
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The subject is Citric Acid, produced by Miles Labor atories. The question: Is it permissible for Passover? The answer: Yes, it is.
We bring three items of correspondence: a letter from Rabbi Moshe Tendler in which he states that Ray Moshe Feinstein says, unequivocally, that “the product described in the report of Feb. 22 visit is ab solutely acceptable for Passover use, without reserva tion, even by those who follow our custom of pro hibiting bean product derivatives.” Two, is the report of the on-site visit by Dr. Tendler, with his conclusions. Three: a note from the Plant Manager, Elkhart Citric Acid Manufacturing.
Letter from Moshe D. Tendler
Dear Rabbi Levy, shlita: April 27, 1979
Mr. Robert 3. McGrath, president of the citro-tech division of Miles Laboratories Inc., informed me that the report of the on-site inspection of his plant, which I made on Feb. 22, 1979, has been forwarded to you.
I discussed, in the fullest detail, with my father-in-law Ray Moshe Feinstein shlita, the halachic analysis of the data contained in this report. Since CORN meal is the source material (not one of the five chametz grains) and NO GRAIN PRODUCT or derivative is used in the citric acid production, the sul~sequent digestion (“eekool”); chemical conversion to tasteless and odor less calcium citrate before Pesach; and final regenera tion with a highly toxic and corros~ye acid (H2S04) to give a chemically distinctive, crystalline citric acid (sour salt); obviates any concern for the laws govern ing use of bean products (“kitniyos”) on Pesach. Corn syrup ies a conversion product (hydrolysis) of starch, while citric acid is a metabolite of the fungal organism used by Miles Inc. to produce their citric acid. It is analagous to the production (metabolic conversion) of milk from grain that is consumed and digested by the cow before Pesach.
Ray Feinstein shlita stated, unequivocally, “the product described in the written report of Feb. 22 visit, is absolutely acceptable for Passover use, without re servation, even by those who follow our custom of prohibiting bean product derivatives.”
I trust that this clarification and analysis is helpful to you in evaluating this product.
With kindest personal regards,
MOSHE D. TENDLER, Ph.D. Prof. of Microbiology
N.B.—a further note of clarification:
The fungal organism used to produce citric acid is not absolutely dependent on starch for its raw material. Given other nutritional media based on protein deriva tives it will also produce citric acid albeit by lesser quantitative yield.
I. THE PROCESS:
A. Starting material—corn (maize) flour
B. Flow chart, with emphasis on steps relevant to Biblical dietary laws.
1. After starch is separated from the gluten component (following liquifaction and saccharification with two enzymes) the pH (acidity) is lowered to approximately 1 .~.
2. The fermentation medium consists of the corn syrup (glucose) with added mineral nutrients.
3. After fermentation the pH is approx. 1.7.
4. The fermentation broth is filtered free of the mycelium, and lime (ca(ah2) is added to precipitate the citric acid dissolved in the broth. This precipitate of calcium citrate is a dry, tasteless, granular material when recovered by filtration and drying.
5. Sulfuric acid is added to the calcium citrate to regenerate the ‘titric acid. The pH at this step is approx. 0.5.
6. The 2 enzymes added (at the liquification saccharification step) are manufactured by fermentation of broth containing no derivative of wheat, barley, oats, or rye. The isolation of these enzymes from the broth is also a “chametz-free” process.
II. ANALYSIS & CONCLUSIONS
A. The starting material is not a grain that is forbidden by biblical law for Passover use. Its prohibition is of a lesser severity, with its origin in rabbinic in junctions designed to protect the integrity of biblical law. As such it is fully binding on all Ashkenazi Jews but with more leniency than biblical chametz.
B. The substance in question enters into the state of “chametz” only on Passover. The citric acid to be sold as Kosher will be manufactured before the Passover (Pesach) holydays.
C. During the process, the mixture becomes “unfit for human consumption” because of the low pH (1.4 at one step and 0.5 at another).
D. The fermentation product upon removal from the fermentor is in the form of a white granular powder essentially tasteless and odorless.
E. The citric acid is not (like corn starch) a component of the original material (corn flour). It is a meta bolic by-product of the impaired metabolism of the mold cells, similar in its relationship to the starting nutrient as cow milk is to the grain con sumed. The citric acid is further removed from the starting material than is the simple hydrolytic pro duct corn syrup or glucose. Many enzymatic steps must occur before the glucose is “digested” to give citric acid.
F. The final product, citric acid, is not designed to be a food substance but only an additive in significant dilution.
Conclusion
In my opinion the citric acid manufactured by Miles Laboratories in Elkhart, Indiana conforms with the Jewish dietary laws as a product acceptable for yearround use including Passover.
SUBJECT: Citric Acid Produced in Elkhart, md. by Miles Laboratories, Inc.
Dear Rabbi Levy: 3/27/79

This letter is being written to document our conver sation that the starting material does not contain citric acid. Citric acid is produced from dextrose by chemical change. Citric acid is a tricarboxylic acid that is com pletely different, both chemically and physically, than dextrose.
Sincerely,
Paul D. Francis, Plant Manager Elkhart Citric Acid Mfg.