A number of licenses and permits may be required from warehouses in the food sector, depending on the location and nature of the products being held within the facility.
For instance, the Secretary of Agriculture licenses operators who hold agricultural products within their facilities under the United States Warehouse Act (USWA).
Some products that fall under the USWA are grains, sugar, nuts, export food aid commodities (EFAC), and dry edible beans. Regardless of the product type, applicants have to comply with the USDA standards. Applying to the USWA body, however, is voluntary.
At the state level, local authorities generally require special permits for facilities that house and handle perishables or regulated items.
In California, the Division of Food and Drug Safety within the CDPH oversees the Processed Food Registration (PFR) program. And the PFR certificates cover warehousing activities along with manufacturing, repacking, salvaging, and labeling.
But Florida-based warehouses have to register with the Florida Department of Agriculture and Consumer Services (FDACS).
In Texas, the Department of State Health Services (DSHS) is the regulatory authority responsible for food manufacturers, wholesalers, and warehousing facilities. Meanwhile, Tennessee’s Department of Agriculture permits and inspects food warehouses.
Facilities that store and distribute food for commercial purposes need state-level warehouse permits.
As for permits on the Federal level, all facilities that hold food for consumption in the US have to register with the FDA. And the FDA considers “holding” to mean even more than just storing food.
The definition extends to cover “activities performed for the safe or effective storage of that food” and “activities performed as a practical necessity for the distribution of that food.” Think fumigation, dehydration, blending, and breaking down pallets.
Under this broad definition, traditional warehouses, silos, grain elevators, and cold storage areas would all be considered holding facilities subject to inspection and licensing.
Exceptions vary from one region to another.
For example, warehouses in New York City may be exempt from licensing if the operator already has a permit from the state’s Department of Agriculture and Markets. New-York-based Warehouses checked by the USDA also don’t need a food warehouse permit.
In California, however, warehouses are exempt from PFRs if their warehousing activities fall under other licenses issued by the FDB, such as a Shellfish Handling & Marketing Certificate.
Warehouses holding agricultural products in their “raw” state also don’t need a PFR.
Let’s check out four common types of warehouses.
Dry food warehouses hold non-perishables, such as grains. Maintaining the right humidity and airflow is a requirement by most health inspection bodies.
According to California Health and Safety Code Section 112355, a “cold storage” facility is an area artificially refrigerated to less than 45°F. All cold storage warehouses in the state are regulated directly by the FDB.
A food distribution center is a type of warehouse designed to receive, store, and ship food products to multiple destinations. They’re usually one link in a larger supply chain.
The PFR program in California acknowledges that some warehouses are hybrid. That’s why operators are allowed to mark down multiple activities when applying for licenses. So, a warehouse operator might both process and store dried beans, for instance.
The PFR issued by California’s Food and Drug Branch (FDB) is the state’s basic health permit that allows operators to manufacture products not specifically covered by other FDB licences.
However, it’s also mandated for general food warehouses. The keyword here is “general” because storing certain food products requires specific permits. Take molluscan shellfish, for instance.
General warehouses in Los Angeles, Orange, and San Bernardino counties are required to fill out CDPH 8611 registration forms. The CDPH 8610 form, on the other hand, can be used by general warehouses elsewhere in the state.