Sorry no one has responded.
I do on-site catering with an FEC 100 in the Cities. Health department is so different even in the same state. I would check with them.
I know a place down here (Qfanatic) asked about doing outdoor pits (even NSF approved) and the HD wouldn't let them.
Either way sounds like I need to bring the MN BBQ tour up to visit.
We just started the tour in the cities here, and getting great responses.
2 - WSM 18.5, 1 - WSM 22.5, and 1 - ECB Smoke n Pit.