The fact of the matter is, you can be "legal" and still serve nasty food. It all depends on the individual(s) doing the cooking and serving. There are safe ways to cook off-site and reheat on-site. If someone is taking the necessary precautions to keep their food safe and their equipment sanitary, I say more power to them - by the "rules" or not. I don't think people set out to "beat the system," necessarily. People try to earn a little extra money to make ends meet in a tough economy by the only means they know how, or is available to them. It doesn't make them bad people, or criminals. And I'm not defending myself here, because I don't vend. But I've read the regs many, many times, and some are ridiculous given the very nature and technique of cooking BBQ - especially.
The Cosmic Pig BBQ
Smokey Joe Silver