Personal Opinion -
Yes, ,the working space requirement will indeed apply to this piece of electrical equipment per NEC 110.26(A)
2011- 110.26(A)
(A) Working Space. Working space for equipment operating
at 600 volts, nominal, or less to ground and likely to
require examination, adjustment, servicing, or maintenance
while energized shall comply with the dimensions of
110.26(A)(1), (A)(2), and (A)(3) or as required or permitted
elsewhere in this Code.
Now, if you can convince your local AHJ that the equipment is not likely to require examination, adjustment, servicing, or maintenance while energized then half your battle is won. However, based on all the panels and boards I have served on in various electrical capacities....they always required the working space for what it is worth.
P.S. For those that may not believe that switch is equipment...Here ya Go
Equipment. A general term, including fittings, devices, appliances,
luminaires, apparatus, machinery, and the like used as a
part of, or in connection with, an electrical installation.
Enjoy !