Last week we discussed eating dairy products after eating meat; this week we deal with the reverse scenario: How long must one wait to consume meat after eating dairy?

Kinuach, Hadachah, and Netilas Yadayim
The Gemara (Chullin 105a) states that after eating dairy, one is immediately permitted to eat meat. However, the Gemara (Chullin 104b-105a) does mention doing Kinuach and Hadachah in between milk and meat.

There are a number of ambiguities in this Gemara, which are discussed by the Rishonim. First, it is not clear what exactly Hadachah entails. Rashi (105a s.v. vlo madeach) and Tosafos (105a s.v. ilema) both define Hadachah as washing out one’s mouth with water, while Rambam (Maachalos Asuros 9:26) defines Hadachah as washing one’s hands.

Second, it is also unclear which scenario the Gemara is referring to. Rambam writes that one must perform Kinuach and Hadachah after finishing a dairy meal and before eating meat. R’Tam, on the other hand, (cited in Tosafos 104b s.v. Ohf) claims that Kinuach and Hadachah are only required when one wishes to eat dairy after completing a meat meal, but are not necessary for eating meat after a dairy meal. Thus, R’Tam interprets the statement of the Gemara that one need not wait between dairy and meat to mean that even Kinuach and Hadachah are unnecessary.

Third, it is unclear whether one must do both Kinuach and Hadachah together or whether the Gemara means that either alone suffices. Rashi (105a s.v. af madeach) and Tosafos (105a s.v. mekaneach) contend that both actions are required, while Rashba (Toras HaBayis p.87b) opines that either of these alone is sufficient.

Finally, the Gemara does not provide the precise rationale for these actions. Meiri (Chullin 105a) posits that Kinuach removes the pieces of cheese that might remain in the mouth or between the teeth (he does not discuss Hadachah). Rashi (104b s.v. blo kinuach) appears to agree when he says that Kinuach ensures that the first food, the dairy, doesn’t remain stuck inside the mouth. However, Levush holds that Kinuach removes the Taam, or taste, of the dairy from one’s mouth, and Hadachah rinses one’s mouth from any remaining pieces.

Halachah
These are the rulings accepted by the Shulchan Aruch (Yoreh Deah 89:2):

Kinuach is defined as chewing solid foods (Acharonim debate whether one must swallow it or not- see Pischei Teshuvah (89:5) and Pri Megadim in Sifsei Daas 89:12), except for dates, raw flour, and greens, which the Gemara does not allow. Hadachah is defined as rinsing the mouth with any water or wine (Acharonim also debate if other liquids can be used instead- see Shach (89:10) and Darchei Teshuvah (89:26)).

Kinuach and Hadachah are required in order to eat meat after eating dairy.

Kinuach and Hadachah are both required, and Shach (89:11) holds that the order does not matter, though Darchei Teshuvah (89:28) cites some opinions that argue that Kinuach should precede Hadachah.

Netilas Yadayim is also required, as seen from another passage earlier in the Gemara (Chullin 104b) requiring hand washing for meat. However, the Shulchan Aruch states, based on that Gemara, that washing is only necessary when there is not enough light to inspect the hands. Nonetheless, Shach (89:9) records an opinion requiring hand washing irrespective of how much light there is. Furthermore, Pri Megadim (Sifsei Daas 89:20) and Aruch HaShulchan (89:8) cite the Pri Chadash (89:20) who suggests that there is no obligation to check one’s hands when using silverware, since we assume that the hands did not get dirty, but Pri Megadim still recommends hand washing, saying it is a good idea.

There is no clear ruling on the precise purpose of these actions.

Based on the sources cited above, it appears that one need not wait between milk and meat if Kinuach, Hadachah, and Netilas Yadayim are performed. According to Magen Avraham (Orach Chaim 494:6) and Mishnah Berurah (Orach Chaim 494:16), one does not even need to recite Birkas HaMazon before eating meat. However, there are a few other possible factors that might limit the application of these rules.

Milk
According to Meiri’s opinion that Kinuach removes pieces of dairy remaining in one’s mouth, Kinuach may not be required for milk since it is entirely liquid. This approach is embraced by the Rashash (Chullin 103 s.v. b’mishneh), Darchei Teshuvah (89:31), R.Ovadia Yosef (Yabia Omer 6:Y.D. 7), and R.Binyamin Forst (The Laws of Kashrus, p.208). But according to Levush, who holds that Kinuach removes the taste of the dairy food, perhaps Kinuach is required for milk as well, and Badei HaShulchan (89:50 and Beurim there) recommends being stringent for this reason.

The Zohar and Maharam Rotenberg
There are some individuals who have the custom to wait either a half hour or an hour after eating dairy before eating meat. Although the source for the hour custom may be based on the Zohar (Mishpatim 125a, cited in Shach 89:17) that says one should not eat dairy either in the same meal as meat or within the same hour, there is no strong basis for the half hour custom (though see R.Shaul Weiss’ Sefer Otzar Divrei HaPoskim, p.170 who quotes a number of approaches to defend this custom).

Another possible source of stringency is based on the Maharam Rotenberg. Hagahos Ashri (Chullin 8:5) and Mordechai (Chullin 867) record that Maharam initially got upset at people who waited six hours between dairy and meat, because the Gemara doesn’t require any waiting. However, he later changed his mind when on one occasion he discovered cheese in his mouth after beginning to eat meat. At that point, he decided that the fact that one Amora in the Gemara (105a) waited an entire day between meat and dairy demonstrates that one is in fact permitted to be more stringent than the letter of the law on this issue.

Although Maharam adopted this only as a personal custom, it grew into a broader custom, which Rama later codified as halachah. Nevertheless, a major difference exists between the two opinions. Maharam appears to have employed this stringency to all types of cheese, but Rama (based on Issur V’heter 40:8) limits it to consumption of hard cheese, presumably both because for hard cheese there is a greater concern that pieces may get stuck in the mouth and because the taste of hard cheese is more likely to remain in the mouth (see Issur V’Heter 40:10 who mentions both of these explicitly). However, Rama, as opposed to Maharam, permits eating soft cheese immediately after meat, so long as Kinuach, Hadachah, and Netilas Yadayim are performed (it is also noteworthy that Rama is stringent regarding eating chicken after hard cheese while Maharam himself was lenient in this regard).

Hard Cheese Today
Shach (89:15) holds that cheese that has aged for 6 months generally qualifies as hard cheese. Taz (89:4) notes that “Swiss” cheese is also included in this rule. But poskim debate the status of other cheeses produced today, such as American cheese or yellow cheese sold in Israel.

Some poskim hold that we treat these as hard cheese, since some of them do indeed age for more than six months, and it is often difficult for the consumer to determine which have and which have not. Another reason to treat these cheese as hard cheeses is because they have certain characteristics of hard cheese even when they are aged for less than six months.

This is the position taken by R.Y.S. Eliashiv who even required six hours for melted pizza cheese, (cited in R. Feufer’s Kitzur Shulchan Aruch al Basar B’chalav, Kuntres HaBeurim p.138), R.Shmuel Vozner (cited in Peninei HaMaor on Hilchos Shabbos, p.427; see also Shevet HaLevi 2:Y.D. 35), R.Shlomo Zalman Auerbach (cited in Peninei HaMaor, ibid., though this may have been only his personal practice- see Moriah 5757 “Piskei Halachos MeRav Shlomo Zalman Auerbach” for a discussion of his position), and R.Moshe Vaya.

Other poskim, including many American authorities, argue that the great majority of cheeses do not qualify as hard cheese, since they have not aged for six months, nor do they fulfill the criteria of having a strong, lasting taste or getting stuck in the mouth. This more lenient approach is adopted by R.Aharon Kotler (cited in Kitzur Shulchan Aruch al Basar B’chalav quoted above), R.Moshe Stern (author of Shut Beer Moshe, quoted in R.Binyamin Forst’s Pischei Halachah L’hilchos Kashrus, p.108), and others quoted in R.Shaul Weiss’ Sefer Otzar Divrei HaPoskim (p.179).

R.Avraham Gordimer reports (“The Halachot of Waiting Between Meals” in Jewish Action, Fall 2006) that the O.U. rules stringently for cheese which is “endowed with a unique texture or lingering taste similar to the texture or taste acquired via aging qualifies as hard cheese, regardless of the precise aging period.” This includes Parmesan cheese, Swiss cheese, and aged cheddar, among others. The majority of cheeses sold in the U.S. do not qualify as hard cheese though. He also notes that the O.U. is lenient for melted cheese because it loses some of its texture and blend in the process.