The Sefer Maadanei HaShulchan writes that if one warms Challa on top of the Cholent pot, it becomes Fleishig to the point where if one would eat a slice of the Challa, he would be required to refrain from Milchigs for 6 hours. Let’s analyze this surprising ruling.
It is a well known Halacha that after consuming meat one must wait 6 hours before dairy foods. The primary issue at hand is how to define which Fleishig foods incur this restriction. Clearly, one who consumes actual meat, such as a steak etc., cannot afterwards eat dairy. Furthermore, the Shulchan Aruch in Yoreh Deah Siman 89:3 describes a second category of meaty foods, called Tavshil Shel Basar. Tosafos on the Gemara Chullin 105b interprets this “Tavshil” as a dish that merely contains a meaty flavor, but without any substance. This meat-containing dish is certainly Fleishig in the sense that it cannot be combined directly with milk nor can cheese be eaten immediate after it, but according to the Gemara it may immediately precede a Tavshil Shel Gvina. Nevertheless, the Rema there concludes that the current Minhag, which he strongly endorses, is to treat a Tavshil Shel Basar as identical to meat itself, and require a full 6 hours before any dairy products.
However, he continues that there is a third category on which both the Halacha and Minhag provide no grounds for stricture. When a Pareve food was cooked in a Fleishig pot, there is no need to wait before consuming MIlchigs.
The Shach §19 observes that this case requires clarification. If we are discussing a spotlessly clean vessel where the sole concern is imparting a meaty flavor into the Pareve dish, the resultant food would be permitted to eat even in combination with milk due to the Halachos of Nat Bar Nat. Since clearly the Rema intends to distinguish between foods that may be eaten together and those which require a full 6 hour delay, we must interpret this situation as one where the formerly Pareve food would not be permitted to be combined with dairy and nevertheless does not incur a needed delay.
Consequently, the Shach concludes that we must be dealing with a pot that was not thoroughly cleaned and remains with Fleishig reside on its walls. Since there is some minimal substance of meat in the resultant food, it would only be permitted immediately prior to dairy, but not together with it. A number of Acharonim observe that if the meaty residue would be less than 1/60th of the final stew, nothing would have been accomplished by interpreting it as a dirty pot. Such a minimal quantity of residue is Halachically insignificant and the resultant dish would remain permitted even with milk. Obviously, the Shach’s intent is that the greasy remnant is greater than 1/60th of the final product.
The question arises, how is this circumstance substantially different than that of the Tavshil Shel Basar which we concluded does require a delay? What is the difference between a concoction to which a minimal amount of meat was added directly and one where it dissolved into the food during the cooking process?
The Beis Meir and Rabbi Akiva Eiger disagree with the Shach altogether and restrict the Rema’s leniency as dealing exclusively with a situation where the pot is spotlessly clean. They avoid the issue of Nat Bar Nat by interpreting the new item being cooked as being an extremely spicy one that is capable of drawing full-fledged flavor from the pot and avoiding the dispensation of Nat Bar Nat, similar to cutting an onion with a Fleishig knife. However, this is an extremely narrow definition of the Rema, and not at all implied in his words. Furthermore, it completely rejects the Shach, which we wish to attempt to avoid.
The Pischei Teshuva initially seems to accept the Shach’s ruling, with the understanding that the intention is irrelevant. Therefore, he reached the conclusion that the Shach would rule equally leniently regarding the addition of a small quantity of schmaltz. He does not quantify how much is the maximum he understands the Shach as permitting, but certainly his understanding is that the quantity is the sole critical factor.
However, the Pischei Teshuva also quotes the Beis Lechem Yehuda as ruling stringently when the meat imparts a substantial flavor to the mixture. He clearly understands the threshold of this “substantial” taste as equivalent to the typical proportion of 1/60, and assumes that this is not compatible with the Shach. The implication is that his conclusion leans towards favoring the Beis Lechem Yehuda.
The Yad Yehuda explains the logic of the Shach as being dependent upon intent. He suggests that the Rema’s leniency of an unwashed pot is only applicable due to the absence of any interest in the meaty flavor incidentally imparted. A Tavshil Shel Basar was only included in the obligation of waiting due to a Lo Plug caused by its classification as a meat dish. When the Fleishig component was unintended, the product is not called meaty and is not included in the original prohibition.
According to this interpretation, there should be no grounds for stringency on our Challos, as there was no intention to flavor them. They were only placed upon the Cholent pot for convenience, not due to any specific desire for the taste.
The Yad Yehuda himself disagrees with the Shach as he understands him. In his personal opinion the intention should not be a significant factor. Rather, he suggests splitting the threshold of imparting flavors into two distinct categories. The Ran explains the source of the adage that foods impart taste up to 60x their volume as based on the maximum ratio defined by a rather strong flavored radish. While he concedes that most combinations will be indiscernible at a much lower ratio, 10 to 20 times their volume; Chazal did not differentiate and enjoined us to always suspect the maximum.
Furthermore, in Siman 98 the Rema rules that while the precise defining factor is the actual perception of taste and not a numeric ratio, in practice we will not rely upon the tasting of the item to determine whether this exists. The Yad Yehuda proposes that while this is true regarding eating mixtures of meat and dairy together, when the sole issue is consecutive consumption we will rely on the observed lack of taste.
Consequently, he interprets the Rema as differentiating between the addition, intentional or incidental, of a quantity of Fleishig substance which is discernible and is classified as a Tavshil Shel Basar requiring 6 hours, and an imperceptible but not less than 1/60 proportion which may not be eaten together but does not require a significant interval either. According to this understanding as well, our Challos presumably do not receive a significantly perceptible meat flavor from being merely placed upon the lid of a Cholent pot, and should not require a 6 hour delay.
The Maadanei HaShulchan based his stringent ruling on the assumption that the accepted Halacha does not allow for any leniency when we lack 60x the meat in the total mixture. Since we know from Siman 92 that steam rising off of a cooking food transfers flavor and that this taste is not impeded by the walls and lid of the pot, we will assume that some of the meaty flavor of the Cholent is imparted to the Challa above it. The Challa undoubtedly is not that much larger than the Fleishig portion of the Cholent, and if 60x is required, it is not likely to be present. He bases this primarily upon the aforementioned Beis Lechem Yehuda, and other Acharonim who require the meaty taste to be a nullified minority, which he interprets as requiring 60x.
However, according to the Yad Yehuda, it is not necessary to have a typical 60x to effect Bitul, as long as the taste is not actually perceptible.
In truth, I don’t think the Shach himself would disagree with this distinction. While the Shach undoubtedly does not require a preponderance of 60x to render the stew non-Fleishig for the purposes of waiting, I see no indication that he would be lenient up to 49% as the Pischei Teshuva seems to imply.
Actually, the language of the Beis Lechem Yehuda is not consistent with disagreeing with the Shach’s ruling as the Pischei Teshuva understood. Rather, his implication is that he agrees with the general principle, and merely limits the permissible quantity of flavor that can be imparted to an imperceptible amount. This could easily be consistent with the other Achronim the Maadanei HaShulchan cites as well; when they require a “nullified minority” there is no imperative that this refers to 60x and not merely becoming indistinguishable.
Furthermore, by my accounting the overwhelming majority of Poskim do accept the Shach’s understanding that the pot need not be clean, which logically compels us to accept even more than 1/60th of residue. This includes the Bach, Toras Asham, Minchas Yaakov, Chochmas Adam, Yad Avraham, Aruch HaShulchan and Igros Moshe.
Consequently, it is my fervent opinion that while a Challa heated directly on the lid of a Fleishig pot does become Fleishig itself regarding the restriction against eating it directly together with dairy products. Nevertheless, if one eats the Challa alone, he need not wait 6 hours before consuming Milchigs. Nevertheless, there is a simple solution that will remove any doubts by wrapping the Challa first in aluminum foil, and this would render it permissible even according to the Maadanei HaShulchan.
There is an additional issue here that the flavor as it travels through the lid of the pot should become Nat Bar Nat which would not be an issue immediately prior to dairy, or even with it. The Maadanei HaShulchan is assuming we should be stringent for the Chavos Daas’ opinion that the leniency of Nat Bar Nat does not apply when both transfers of flavor occur simultaneously. A further discussion of this point is beyond the scope of this article.