Welcome to my hot dog cart! Would you like to try our stewed hamburger today!

What!? Think about it. A commercially produced fully cooked hamburger patty sold from a hot dog cart. There are a few sellers out there bending or completely breaking their state rules by selling these products.
One NJ seller is heating them up in the same “dirty water” as they heat their hot dogs (I hate that term! It is such a negative anti-sanitation term, yet vendors bandy about the term proudly like a badge of honor). Then once they feel the patty is hot enough, they transfer it to a dry holding pan using aluminum foil to “keep the pans clean”.
OK, it is precooked right just like a hot dog, so what is the big deal? First, using the same water for hot dogs and hamburgers muddies the flavor of both products. Both meat products leach out fats, seasonings and flavors into the water. That is what gives the water that name – “dirty water”. Meaning the busier the vendor the more alike the hot dog and hamburger will taste. Would you like to eat a hot dog flavored hamburger? Seasoning the water in an attempt to control the taste will have vastly different impact on a hamburger than a hot dog. Remember hot dogs are encased which shields the internal meat from the added water seasoning. While a hamburger is “unprotected” and will absorb more of those seasonings and all the leached hot dog flavor.
Most state allow hot dog vendors to operate under extremely specific rules. Those rules often limit what they can cook with wording in their food code similar to this from Kentucky:

“Section 4. Restricted Concessions. (1) Restricted concessions may include:
… (h) Pre-cooked, commercially processed hotdogs, frankfurters, or similar meats (such as bratwurst or Italian sausage) that are grilled, steamed, or boiled on-site”

Note that is very a specific description. That section describes the only allowed foods a restricted concessions (hot dog cart) can sell.
Letters (a) through (g) and (i) thru (m) list other common road side foods such as flavored & shaved ice, snow cones, pork rinds, peanuts & other shelled nuts, nacho cheese & chips, cotton candy, pre-packaged sandwiches, pre-packaged ice cream and other commercially packaged snacks and finally shelf stable baked goods. Hmmm, no mention of hamburgers. Even trying to weasel around the wording “pre-cooked, commercially processed” and apply it those pre-cooked hamburgers won’t work because of the specific description and shape of the allowed meat. So clearly Kentucky is out. But what about New Jersey?
Here is a Salem county handout for mobile vendors:

“5. Cooking: You must have a food thermometer onsite and monitor food temperature. A thermocouple is required for all thin foods. The following chart will tell you the minimum temperatures required for cooking:
· Hamburgers or other ground beef: 155º F
· All poultry products (chicken, etc.) 165º F
· Pork or any food containing pork 145º F
· Other meats (including seafood) 145º F
 If you will be holding potentially hazardous foods hot, a minimum of 135º F is required in all parts of the food at all times. Heat lamps and sterno are not recommended as they rarely work. The temperatures are based on known risks and must be followed.
6. Reheating: If you must reheat a potentially hazardous food for hot holding, the food must be reheated quickly to an internal temperature of at least 165º F. Do not reheat foods in crock pots, steam tables or over sterno.”

Key points - a hamburger must be cooked to at least 155° (actually the full code reads must maintain that temperature for 15 seconds) or if you consider the fully cooked hamburger patty as a simple reheat, it must reach 165°. Except what does it specifically say? Do not reheat foods in crock pots, steam tables or over sterno. What is a hot dog cart? A rolling steamtable.
Another vendor is considering adding this hamburger to their menu in Michigan. He plans on not telling his health department about the addition. No big deal, right? It is a big deal. Michigan food code requires mobile vendors to report ANY additions to their menu and seek approval before adding the item.

1.  Food (Note: Any changes to the menu must be submitted and approved by the regulatory authority (LHD or MDARD) prior to their service, you may be required to show approval during inspections.)

I would not want to add something and then prove the approval during an inspection. If adding a product requires Health Department approval, then that rule must be followed. Otherwise the ethics of the vendor comes into question. Once ethics can be questioned then other important qualities of success start to fail as well. In fact, ignoring government rules is one of the top three ethics violations a failing business commits.
It’s only food what is the big deal? Food laws and health codes are written to protect the weakest members of the public at large from sickness or even death from eating improperly cooked food. Those rules are written so specifically and so strictly in order to prevent an under-educated vendor from selling food that could make someone sick or even kill them.

Oh yeah, insurance won’t cover illegal acts, guess who foots the bills if you add an unapproved item to your menu that someone gets sick? That LLC “personal asset protection” evaporates too.

Yes, I grew up eating raw cookie dough, and licking the bowl of egg laden cake batter and I survived BUT there are many, many people that could not survive eating an improperly reheated hamburger that has been stewed in dirty hot dog water.  Playing Russian Roulette with some else’s health is simply not good business.                         
 

---