5786/2026
Malca Jachter warms up chicken for Shabbat afternoon in a way that it cannot reach Yad Soledet Bo. However, there is still a potential for the sauce and chicken fat to turn to liquid when warming.
Squeezing Water from Ice
The question depends on a Gemara, Shabbat 51b. The Gemara forbids squeezing water out of ice. The Rishonim debate why Chazal forbade it.
Rashi
Rashi explains that one is creating, Molid, something new, resembling Melachah.
Rambam and Rashba
The Rambam (Hilchot Shabbat 21:13) and Rashba believe it resembles squeezing fruits (Sechitat Peirot), which is forbidden on Shabbat and Yom Tov.
Sefer HaTerumah
The Sefer HaTerumah (234-235) offers a surprising explanation: he focuses on the resultant entity in a new form, Nolad. In other words, when squeezing water out of ice, a new item is created, known as Nolad, which is forbidden on Shabbat and Yom Tov.
A Nafka Mina - Warming Fat
A Nafkah Minah between these explanations is when one warms congealed fat, transforming it from a solid to a liquid. Rashi and the Rambam/Rashba permit this since one is not actively generating a new form, unlike the Gemara’s case of squeezing water out of ice. However, it is forbidden, according to the Sefer HaTerumah, which focuses on the resultant new form.
Shulchan Aruch vs. The Rama
The Shulchan Aruch (Orach Chaim 318:16) permits warming congealed fat on Shabbat, clearly rejecting the Sefer HaTeruma.
However, the Rama records the Ashkenazic custom to consider the Sefer HaTeruma. Nonetheless, the Rama writes that we may be lenient in case of need.
Significantly, the Rama does not limit the exception to a place of great need (Tzorech Gadol). Instead, an ordinary need (Tzorech) justifies leniency.
One important clarification: The Sefer HaTerumah's stringency applies even when Bishul is not a concern, when Yad Soledet Bo will not be reached.
Heating Chicken
Accordingly, Sepharadim do not follow the Sefer HaTerumah as noted by Rav Ben Zion Abba Shaul (Teshuvot Or L'Tziyon 2:32:3) and Rav Yitzchak Yosef (Yalkut Yosef, Orach Chaim 318:62). However, unless there is a need, Ashkenazim heed the Sefer HaTerumah.
Thus, warming chicken seems to pose a problem for Ashkenazic Jews, as the congealed fat and sauce will liquify after being placed on the fire.
Rav Rimon's Solution
Rav Yosef Tzvi Rimon cleverly suggests placing rice at the bottom of the pan to absorb the melting fat and sauce. He notes that the Gemara and Shulchan Aruch permit putting ice in a liquid, as the water that emerges from the ice will not be noticeable in the liquid into which it was placed. Similarly, the liquified fat and sauce will not be evident in the rice into which it is absorbed.
Malca Jachter's Solution
The chicken my wife prepares does not generate much liquid when warmed. Malca places only a little sauce on the chicken to limit the amount of liquid it generates. She also limits the amount of chicken she places in a pan to further reduce liquid generation. A tiny amount of liquid does form, but the Mishnah Berurah (318:105) codifies the Taz (Orach Chaim 318:21), who rules that the Sefer HaTerumah's Chumrah does not apply to an insignificant amount of liquid.
Psik Reisha D'lo Nicha Lei?
Perhaps we may permit liquifying fat or sauce, as it is a Psik Reish D'lo Nicha Lei (a side result about which one does not care), regarding a rabbinic prohibition. However, the classic Poskim do not seem to consider this point as a lenient consideration. Perhaps it is because Ashkenazic tradition is to be strict regarding a Psik Reish D'lo Nicha Lei, even in a rabbinic matter, absent need.
Postscript - Making ice on Shabbat
Twentieth-century Poskim debate whether the Sefer HaTerumah's Chumrah applies to making ice.
Sepharadim
Rav Ovadia Yosef (Halichot Olam 4:93) permits Sephardic Jews to make ice on Shabbat in all situations, as Sepharadim do not follow the Sefer HaTeruma's approach.
Rashi, Rambam, and the Rashba's concern do not apply since one is not actively generating the ice. In the Gemara’s case, one actively squeezes water from the ice. Making ice, by contrast, involves placing water in the freezer, without directly turning the water into ice. However, it does pose a problem according to the Sefer HaTeruma, who focuses on the result.
However, since Sepharadim follow the Shulchan Aruch, they are not concerned for the Sefer HaTeruma.
Ashkenazim - Shemirat Shabbat Kehilchata vs. Teshuvot Tzitz Eliezer
On the other hand, the Shemirat Shabbat Kehilchata (10:4 and footnote note 14) writes that Ashkenazim should avoid making ice unless there is a significant need. He believes that the Nolad concern applies to transforming water into ice as to transforming ice into water.
By contrast, Rav Eliezer Waldenburg (Teshuvot Tzitz Eliezer 6:34 and 8:12) even permits Ashkenazim to make ice on Shabbat. He rejects the analogy between changing water to ice and changing ice to water. The resultant water is in a permanent state at room temperature, unlike ice. Thus, Rav Waldenburg reasons that the consequent ice is not Nolad.
Since the Sefer HaTerumah is regarded as a Chumrah about a rabbinic prohibition, it would seem to be permitted in case of doubt. Rav Hershel Schachter told me (in 1988) that he agrees that making ice is allowed on Shabbat. Surprisingly, Rav Yosef Dov Soloveitchik forbids making ice on Shabbat (as reported by Rav Schachter in his MiPeninei HaRav, page 79) because it is considered Boneh, or building. This ruling seems to be based on the Gemara (Shabbat 95a) forbidding making cheese on Shabbat because it is Boneh. Rav Ovadia Yosef rejects the analogy, noting that making cheese involves combining several ingredients to make a new product, cheese. However, making ice cubes does not include combining different items.
Conclusion
Sepharadim may undoubtedly make ice on Shabbat, and Ashkenazim may rely on the opinions that permit them to do so.