Hi Kilnguy,
The others may have much better comments than I, but I would look at these things:
1. Ask for the reference research and materials that drives this 4-hour, 165F "bug-kill" phase, and then study those for potential alternative strategies to achieve the same results.
2. Characterize your actual typical temp/time profile and see how it compares with their requirement; perhaps it is close enough for them to give you some leeway/waiver?
3. Ask them if there is any other alternative post processing treatment method that may be applied to achieve the fundamental requirement.
Sorry, but that's about all I got.
Good luck in finding a solution to this, and please do let us know how it goes.
Tim