Andrew,
well finally a fix reveals itself. a bit sloppy but it works.

CLOSE DATA ALL
USE dbname.DBC
LOCATE FOR objecttype = "Database" AND objectname = "StoredProceduresSource"
IF FOUND()
APPEND MEMO CODE FROM procedurefile
ENDIF
USE
COMPILE DATABASE dbname

same as what append procedure does, just in a roundabout way. hope this works for you too.

Jordan