The bread, ham, and cheese are all separately regulated.
The nuance between open faced sandwich vs closed sandwich comes down to a final product, So think producing prepackaged food for sale as a federally regulated facility, more than making a sandwich in your kitchen.
And at any rate on any functional level it will be your local health jurisdiction that’s really going to get involved if a regulator ever had to.
Thankfully as we’re all breaking into our 40s, we have finally reached a point our society expected of us by 25. All it took was the slow deaths of our families.
But our kids are gonna be fucked! Thanks boomer for telling us that should make us feel better like it apparently did your generation.