This rule implies you can have more than two circuits in a box:
NEC 2011
210.7 Multiple Branch Circuits. Where two or more
branch circuits supply devices or equipment on the same
yoke, a means to simultaneously disconnect the ungrounded
conductors supplying those devices shall be provided
at the point at which the branch circuits originate.
Actually, it limits what you can have on one yoke. So a two-gang box could have four circuits.
In the OP's case, the SABC receptacle(s) would be on one yoke, the switch for the garbage disposal would be on the other, and the pre-wire to the dishwasher would not connect to either yoke, so it could be on a third dedicated circuit if desired.
It looks to me as if the primary application of that rule is for an MWBC wired to a split receptacle so that one side of the MWBC supplies each of the two receptacles.
It could also deal with the safety problem of a yoke with a switch on one branch circuit and an outlet on the other, or two switches on different branches. The hazard in the first case is that someone might think that the yoke was touch-safe for removal when only the receptacle circuit was de-energized.
The conservative approach would be to de-energize all circuits passing through the box, but that may be hard to verify without removing one or more yokes to get your non-contact tester near the wires at the back of the box.