Diverting non-conforming product for non-food use

I'm with a company that's new to food. We've developed a business in refining a protein that we primarily sell as a food ingredient/processing aid (RTE). However it also has non-food applications, and our business development group is actively trying to expand the market for other uses of this protein (mainly textiles). If the food product is unfit for use, it still has value to be sold in small spot quantities for research use in other industries. Therefore we would like to avoid destroying it, instead diverting it to non-food use.

There is a lot written in these forums about the need to destroy product that has been determine non-food safe, but does anyone have a process for converting a product that started as food to a non-food use? Is documenting the conversion, and destroying our label sufficient?

TIA!

A) you need a letter of guarantee from the purchaser that it will not be used in food

B) destruction log for lot # and quantity (include photos) as well as it's removal from your system (if your using one)

C) a label for the units

D) dedicated storage space for the non conforming product 

E) copies of the pick list or invoice that show the newly created (i.e. the nonconforming product) was shipped to the purchasers for whom you have an LOG

Hi LostInTheWoods,

Obviously clear identification and supply chain control is required.

I remember in the good old days a red dye/colour was put in waste milk designated for pig feed. A simple answer that made the product a clearly distinguishable pink colour (unless you were manufacturing strawberry shakes J). Might be something to consider.

Kind regards,

Tony