Meat before dairy requires a substantial wait. Dairy before meat is normally much lighter — clean the mouth, eat something, move on.
Hard cheese is the exception, and it is treated more strictly, with many waiting the full period afterwards as they would after meat.
The two conditions that exempt it
The Rema addresses a related case: food cooked in a meat pot but containing no actual meat may be followed by cheese, and there is no custom to be stringent about it. Likewise, it is the practice to eat meat after a dish containing cheese or milk — though one washes the hands in between.
Working from that, the accepted ruling is that one need not wait after hard cheese where two things are both true:
- The cheese was softened by cooking, and
- it is somewhat mixed into other food — even if some of it is still discernible in substance.
Both conditions. Cooked into a dish is not enough on its own, and mixed in while still firm is not enough either.
Why Caesar salad is the awkward case
This follows directly, and it is the example the ruling itself reaches for.
A Caesar salad made with parmesan is hard cheese that is mixed into other food — so it satisfies the second condition. But the cheese was never softened by cooking. It fails the first.
So on this analysis one would wait the full period after a Caesar salad, where one would not after a cooked dish containing the same cheese.
That is a good illustration of why "is there cheese in it" is the wrong question. What the cheese has been through is what the conditions turn on.
A note on stringency
Worth including, because it cuts the other way from what people expect. Rav Schachter observed of this practice that one should not go looking for extra stringencies in it.
That is a real piece of guidance. This is a custom with defined contours, and the contours include the conditions above. Treating every trace of any cheese as requiring a full wait is not a more careful version of the practice; it is a different practice.
What is "hard cheese"
Which cheeses fall into this category is itself discussed, and practice varies — it generally turns on ageing rather than on texture alone, so a cheese that feels firm is not automatically included.
Which cheeses your household treats this way, and how long you wait, is a question for your rav. See also cheese and gevinas yisroel.
Where this comes from
- Rema, Yoreh De'ah 89:3
- Yad Yehudah, Yoreh De'ah 89:30; Darchei Teshuva 89:43
- Tosfos, Rosh and Tur; Toras Chatas; Minchas Yaakov
- Rulings of Rav Belsky and Rav Schachter