I believe that this is an example of where the code panel was deliberately vague - trying to accept a common, even inevetable, practice. In doing so, they offered to AHJ's a philosophy as ailen to them as garlic is to a vampire: Let the customer use his own common sense!
It's quite common for such boxes to get covered by a 'sweeping' of gravel, or bark, or whatever by the gardener. It's also little difficulty to sweep this stuff aside, or to even find the box- since the box is usually at the base of a pole or some other structure.
If the section introduced anything novel, it was the mention of using a 'listed' box. Not all such handholes are required to be listed. Heck, I don't think any - even the Quartzite brand - were listed even ten years ago.
Now, if your box in in the middle of an unmarked gravel lot at the livestock events center, buried under two feet of compacted dirt and gravel, you just might have a violation. Write all the reports you want; nothing will remedy that situation as effectively as the expense and effort needed to find it the first time! (Gee, maybe 'market forces' do work!)
