Based upon all of these aforementioned factors, the poskim have generally advocated three approaches to using ovens for dairy and meat. The most cautious of these is brought in the Chelkas Yaakov 2:136, Minchas Yitzchok 5:20, and the Badei ha-Shulchan 92 who, ab initio, advocate separate ovens.
On the other hand, though, the Aruch ha-Shulchan allows for the same oven to be used interchangeably for both meat and dairy as long as the oven remains clean. In practice, I know many rabbonim who will rely upon the Aruch ha-Shulchan provided that the oven rests for 24 hours or is kashered between uses.
A moderate opinion and, perhaps, the most commonly relied upon da’as in the
1. Because of the distance between the food and the interior surface of the oven, any zeya emitted would cool to below yad soledes bo before it reaches them.
2. Our household gas ovens are vented, thus allowing enough of the steam to escape.
3. The interior surfaces of the oven are sufficiently hot to either thoroughly desiccate or burn off any remaining material.
Reb Moshe felt that these three reasons are not strong enough to create a convincing heter. Addressing them one-by-one, Reb Moshe derives some practical halachik directives for using the same oven for both milk and meat. Here is the bulk of Rav Moshe’s analysis:
Regarding the Gas Oven, Common in Our Areas,
And the Problem of Steam (
Tammuz 14, ‘714
[Thursday July 15th, 1954]
To my most honorable friend, Rabbi Chayim Schloss, Shelit”a,
Shalom u-veracha,
Regarding the gas oven common in our countries and the problem of zeya when cooking uncovered dairy after having cooked uncovered meat, you wished to permit the food on account of three reasons. However, these reasons are somewhat weak.
The first rationale is that the distance between the cooking food and the walls of the oven is so much [that the zeya produced would not longer be yad soledes bo by the time it reached the walls or roof of the oven]. This cannot be relied upon. Even if we measured the distance and were certain that the steam could not be yad soledes bo, this knowledge would only help by a non-hot pot placed above the steam (as discussed by the Rama, Y.D. 92:8). In a gas oven though, all of the interior walls and the ceiling are yad soledes bo when the steam reaches there and the steam, in turn, will be heated to yad soledes bo. See Rabbi Akiva Eiger[1] in the name of the Maharai who write about a hot pot becoming osur even if the steam that reaches it is not hot. See also in the Pri Megadim M.Z. 92:29. Additionally, the possibility that the distance between the food and the interior surfaces is so great that the steam cannot travel to the walls is uncertain and difficult to prove.
The second possible reason to permit is that gas ovens have a side-vent for fumes. I have not seen gas ovens with such a vent. Even for those gas ovens that do posses a small side-vent, this vent would not help the problem of reicha (see the Shach 108:13)[2]. All the more so zeya would pose a problem and such a vent would be ineffective. Even if an oven was entirely open, having only a roof and no walls, zeya can ossur if the oven ceiling or the zeya itself is yad soledes bo.[3] The walls of a normal oven could also be affected as the steam rises throughout the oven on its way to the ceiling. This scenario is learned out from the mishna in Machshirin 2:2 which teaches that all zeya from a tamei bath can render tamei the walls and, eventually, the entire house. This mishna is the very source for the law of zeya – see the Pri Megadim and the Biurei ha-Gra 39. Additionally, we can learn from this mishna that it is not possible for all the steam to exit from a small side vent unless the complete side is open; even though the house discussed in our mishna undoubtedly has doorways and openings the mishna is nonetheless concerned about zeya.
The possible third reason to permit using an oven for milk and meat dishes cooked uncovered, one-after-another, is that any actual food material left on the interior surfaces of the oven would either be dried out or burned away by the heat. The only lingering concern would be that of blias, mere absorptions. Yet, this reasoning is hard to understand since the fundamental issue by zeya is one of blias! Actual food material that remains in the oven between cookings must be scrubbed off between uses. Also, it is hard to say with certainty that any dairy or milk matter that splashed inside the oven would be dried out to the point that the zeya of the second pot couldn’t soften it. We likewise cannot rely upon the assumption that any splashed food has been burned up. The interior surfaces of the oven, being located some distance from the main heat source, usually do not reach temperatures high enough to incinerate anything splashed upon them. See Yoreh Deah 92:6 that, even by a pot sitting right against a flame, we do not rely upon the assumption that the fire has burned off any splashes [unless the splashes are small and fall on the side directly in contact with the flame].
Therefore, if there is zeya it is not permitted to cook meat and dairy, both uncovered, one-after-the-other, for any period of time in the same oven. However, I am doubtful if we must be harbor a suspicion for zeya when we have not actually seen any. The Rama 108:1 writes: “However, if they were roasted one after the other we are not concerned as long as there was no zeya given off from both of them. If there is zeya, then the heter is ossur even though they were roasted one after the other [if they were uncovered].” This statement implies that, in the absence of proof, we do not suspect there is a zeya problem. Rather, zeya only becomes an issue when we know for a fact that it is present. However, perhaps in our ovens, which have closed ceilings and walls, zeya is certainly present or at least more likely to be present. Accordingly, it is proper to be strict and not to cook meat and milk dishes uncovered in the same oven, even one-after-the-other.
B’dieved, however, provided that 24 hours have passed and thus rendered pagum any blias involved, the food would be muter since it is a safek. Regarding the possibility that actual zeya condensed and fell into the food[4], perhaps the amount that fell in became batel[5]. Since this latter possibility also involves a safek, we can therefore construct a safek safeka: 1) Perhaps there was no zeya, and, 2) If there was zeya then perhaps only a minute amount of condensation fell back into the food such that it was batel in 60[6].
Another relevant factor is whether the food being cooked is wet or dry. In a situation where one is baking or cooking dry matter, the Pri Megadim, Hakdama,, Hanhagos ha-Shoel 2:37 writes that the zeya of solid foods is not prohibited and that there is a side to permit even the zeya of fats that have melted during cooking (this heter is based upon the Rambam, Hilkhot Tumas Ochlin 7:4). Yet, this opinion is written only as a possibility. The Pische Teshuva, in quoting the Pri Megadim, also states this heter only as a possibility[7]. However, by a totally dry food there is no doubt that zeya is not an issue.
So, it appears, based upon the Pri Megadim, that baking or cooking dry foods one-after-the-other may be permitted even if we see zeya. Practically speaking, though, when we see zeya it is proper to be strict. However, one does not need to worry initially about zeya by dry foods and may assume that dry foods will not produce zeya. Therefore one may cook dry foods one-after-the-other and zeya only becomes problematic if one actually sees it.
Reb Moshe’s concludes that one may not cook food containing liquid uncovered, one-after-the-other, in the same oven. However, one may cook very dry foods, such as bread, in such a matter and we do not need to worry about zeya. Yet, if you see actually steam shooting out of the food, then zeya is a problem. In a case of covered foods, then there is certainly no issue because there is no problem of zaia.
[1] To Y.D. 92:8. Some, the Yad Yehuda 92:55 in particular, do not agree with this idea.
[2] Since reicha is of less significance than zeya, we can say that if a small vent is ineffective by reicha then kol she-keyn it should be ineffective by zeya.
[3] After all, steam rises.
[4] There is some disagreement amongst the poskim as to when the concern for condensation applies. Some (i.e. Pri Megadim M.Z. 92:29, Yad Yehuda 92:52) hold that condensation is only an issue when we know for a fact that it fell into the food. Others (i.e. Dagul Mervava 92:8) maintain that one must assume that condensation fell into the food even if no one actually saw this occur.
[5] Similarly, see the Minchas Yitzchok 5:20;13 quoting the Shu”t Beis ha-Yotzer
[6] An additional leniency is that many authorities consider zeya itself to be only a Rabbinic prohibition. See the Minchas Yitzchok 5:20;10.
[7] Many poskim, most notably the Minchas Yitzchok and the Darke Teshuvah, disagree with and reject the possibility that zeya is only applicable to liquids. However, it appears they would agree that the amount of steam produced by solid foods is miniscule enough as to not be a significant factor. See Toras Chatas 35:6 and the Minchas Yaacov 35:21. This appears to be the general consensus as I have found it.
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GREAT JOB
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