I agree as far as Art 422.31 is concerned, but in 424 where the Fixed Electric Space Heating is specifically addressed the wording seems to call for "lockable" regardless.(A '14 Code change)
III. Control and Protection of Fixed Electric
Space-Heating Equipment
424.19 Disconnecting Means. Means shall be provided to simultaneously disconnect the heater, motor controller(s),and supplementary overcurrent protective device(s) of all fixed electric space-heating equipment from all ungrounded conductors. Where heating equipment is supplied by more than one source, feeder, or branch circuit, the disconnecting
means shall be grouped and marked. The disconnecting means specified in 424.19(A) and (B) shall have an ampere rating not less than 125 percent of the total load of the motors and the heaters and shall be lockable in accordance with 110.25.