I think the bigger thing to worry about is the fact your refrigeration must maintain 41 degrees instead of 45.
Heck. I'm certain there are plenty of establishments where the door to the reach-ins or walk-in is opened frequently, probably have a hard enough time staying 45 much less 41. Of course they gave everyone five years to upgrade equipment.
I like to know if Fetzer, Chef Supply or Dine had an in at the Health Dept. when they came up with that.