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[DanWJohnson]

I have a situation I hope someone else has experience with.  I manage several warehouses and one of those ware houses is not FDA registered, nor does it have a HACCP or prerequisite programs in place.  I want to be able to house food grade product, which has been downgraded to technical grade, as this is what the customer is using it as.  But I don't want this product sitting in my warehouse as is.  I have thought about whether I could downgrade it to technical grade, at an FDA registered warehouse and transfer it to the other warehouse, but I find little information on what to do with original labels, or additions to the packaging, i.e. Technical grade use only, or something similar.  Anybody out there that can help?  And no the manufacturer won't sell us a tech grade of the specific product we need.  

[SQFconsultant]

Hi Dan

Look up a food scientist that either specializes in technical grade or offers same.

You'll need a certified food scientist to do the analysis and paperwork.

They will also provide instructions for labeling or actually provide the labels that you are required to use.

As to the FDA, the warehouse with technical grade will be under FDA oversight, thus it will need to be registered.

This is the information I have on the subject.