OSHA whom references the NFPA 70E for electrical safe work practices considers testing voltage energized work. And opening/closing a breaker and/or switch is technically work that requires PPE even at Cat 0 energy levels.
I don't agree with the NEC that working space is only needed for equipment worked on "while enrgized". I agree with you that nothing should ever be worked on while energied, period. But, energized or not, the working space should be provided anyway. IMO.
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Bryan P. Holland, MCP