450.14 Disconnecting Means. Transformers, other than
Class 2 or Class 3 transformers, shall have a disconnecting
means located either in sight of the transformer or in
a remote location. Where located in a remote location,
the disconnecting means shall be lockable, and the location
shall be field marked on the transformer.
For all practical purposes this new 2011 rule only requires the addition of a label on the transformer. It would be a rare case where the primary OCPD was not also a disconnect. That is assuming that the primary OCPD is remote from the transformer. If the OCPD is within sight, then there is no change.