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Cooking Meat and Milk in the Same Oven: The Halachic Issues
by Rabbi Michael J. Broyde*
* My thanks to Rabbi Howard Jachter, whose forthcoming
article on this topic inspired this reseach, and a debt is owed to an
excellent article on this topic by Rav Shmuel David in Alon Shvut
130.
One of the most frequently asked kashrut questions deals with the procedure
for cooking meat and milk in a single oven. This short article will address
the halachic issues involved, explain the different opinions found in
halacha, and recommend a practice to follow.
I. Aroma and Steam
The Talmud (Pesachim 76b) recounts a dispute between Rav and
Levi as to whether aroma (in Hebrew, ra'ach) emitted from food
is halachically significant or not—whether kosher food cooked in the same
oven at the same time as non-kosher food becomes non-kosher because of the
aroma. Rav states that such aroma is significant and thus the food [becomes]
non-kosher, and Levi rules aroma not to be problematic, and the food kosher.
While there are a smattering of rishonim who follow the ruling
of Rav (see Tosaphot s.v. orsa), most accept that the halacha
is like the approach of Levi and that aroma is not significant and that
such food is kosher; see Rambam, Maachalot Asurot 15:33; Rif,
Chulin 32a and Rashi, Pesachem 76b s.v. amar
lecha. However, they accept that aroma is only not significant post
fact (bede'eved), and that even Levi accepts that one may not
deliberately cook kosher and non-kosher food in the same oven at the same
time. The Shulchan Aruch (Yoreh Deah 108:1) accepts
this approach, and permits aroma post fact, but prohibits this conduct initially
(lechatchela).
Rama adds that the rules governing kosher and non-kosher foods cooked
together in the oven are identical to those governing dairy and meat items
cooked together in the oven. In addition, he states that the practice
is to be strict in each of the following circumstances:
- Passover food may not be cooked with chametz;
- Spicy food that is not kosher may not be cooked with kosher food;
- Even if the oven is well ventilated, they may not be cooked together;
- One should not ideally even cook a parve item with meat in the oven
when one's intent is to eat the parve item with dairy.
However, so far we have only discussed the issue of aroma. The Shulchan
Aruch (Yoreh Deah 92:8) adds, based on a teshuva from
the Rosh (20:26), that when two items are cooked in the same
oven, there is another problem—steam. Steam (in Hebrew, ze'ah)
rising from one item to the other is a halachic problem, and "if one places
a pan of milk below a pot of meat, the steam [from the milk] rises into
the meat and renders it not kosher." Unlike with aroma, which is permitted
post fact (bede'eved), the Shulchan Aruch rules
that dairy steam actually makes a meat item completely not kosher.
II. Meat and Milk in the Same Oven
The crucial question is why does the Shulchan Aruch rule that
"steam" arising from milk is of such significant halachic concern that it
actually renders the meat above not kosher, but aroma—at least post fact—is
permitted? This question is not merely some abstract talmudic question,
as the answers to it provide the various opinions as to when one may cook
meat and milk in the same oven.
Three famous answers are provided.1
- The Aruch Hashulchan (YD 92:55) argues that steam is
only of halachic concern when one cooks in a very small oven that is
poorly ventilated; in our modern ovens, only aroma is a significant
halachic problem, and the aroma problem is only significant when the
meat and the milk are in the oven at the same time. Thus, according
to Aruch Hashulchan, one may cook meat right after milk
in our modern large ventilated ovens, so long as the oven is clean (as
a clean oven eliminates the problem of aroma from one food to another).
This was the custom in Eastern Europe a century ago, and Rabbi Hershel
Schachter of Yeshiva University tells people that it is completely proper
to follow this approach in their own house.
- Rabbi Moshe Feinstein (Iggrot Moshe YD 40), following
the suggestion of the Pri Megadim, argues that steam is
only always actually halachically significant when it emerges from liquid
foods. Solid foods, it may be assumed, do not produce significant steam
(unless one clearly observes to the contrary). Combined with Rama's
assertion (YD 92:8) that steam is not a problem when the pot producing
the steam is covered, Rabbi Feinstein counsels that one may cook meat
immediately after milk once the oven cools down, if both of them are
not liquid foods or one of them is covered. Rabbi Aharon Lichtenstein
of Yeshivat Har Etzion encourages people to follow this practice (or
to wait 24 hours between meat and milk use of the oven).
- Rabbi Yitzchak Yakov Weiss (Minchat Yitzchak 2:50) maintains
that the distinction between aroma and steam is hard to discern and
whenever possible a person should have two ovens, one used exclusively
for meat and one used exclusively for milk. Rabbi Weiss rules that there
is a genuine halachic concern that steam is left in the oven from a
meat item which is absorbed by a dairy item, rendering the second food
categorically not kosher or that steam enters the walls of the oven
which have absorbed both meat and milk flavor, thus becoming not kosher
and making the food not kosher. Absent two ovens, one must kasher the
oven between use, or double-wrap either the meat or the dairy items.
Rabbi Feivel Cohen, the author of the Badia Hashulchan
(in YD 92:180) adopts this approach, and also requires separate grates
for the oven (a requirement which Rabbi Feinstein explicitly—and the
Aruch Hashulchan implicitly—rejects).
III. Conclusion
My own practice is to try to follow the approach of Rabbi Feinstein whenever
possible, although the generally permissive approach of the Aruch
Hashulchan is acceptable; it is not necessary even to strive to accept
the approach of Rabbi Weiss and have two ovens.
In practice, the approach of Rabbi Feinstein means that one must decide
whether one's oven is meat or dairy. If one decides that one's oven is
a meat oven, all meat items may be cooked in it without hesitation. Dairy
items, however, may only be cooked in the oven if they are solid foods
(such as kugels, casseroles, and, perhaps, even pizzas) or, if they are
liquids, if they are covered.
As an alternative, if one does not want to cover the dairy liquid when
it is cooked in the meat oven, one may either kasher the oven by setting
it to its highest temperature for an hour or wait 24 hours from the last
time the oven was used for meat, and then cook the dairy item uncovered.2
Sources
1 Three other approaches
are worth mentioning. Mishkanot Yaakov (YD 34) solves this
problem by positing that the discussion of steam found in the Rosh
and Shulchan Aruch is mistaken, and steam, in fact, is of no
halachic concern. His approach is a very minority approach and should not
be followed. Chavat Da'at (Biuirim 92:26) rules
that the problems of steam is limited to cases where one item is on top
of the other; in cases where the two items are side to side, there is no
problem of steam. While a number of authorities do accept this approach
(See Badia Hashulchan 92:166), and the result of this approach
would be that one could cook meat after milk in the same oven, just on a
lower rack, the common custom is not to follow this approach. Aruch
Hashulchan (92:55) accepts the assertion of the Rosh
that the discussion of steam is limited to cases where one of the two pots
is cold. [Continue with the text...]
2 How one kashers an oven is a famous
dispute between Rabbi Soloveitchik and Rabbi Feinstein. Rabbi Soloveitchik
ruled that one need only turn an oven to its own highest temperature for
an hour or two in order to kasher it, whereas Rabbi Feinstein maintains
that in order to kasher an oven one had to raise the temperature of the
oven to 900F by using either a blow torch or charcoals. The approach of
Rabbi Soloveitchik is well defended by Rabbi Mordechai Willig, in the
OU's kashrut journal Mesorah 4:83-96, and that is the approach
accepted by this writer.
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