The term "EPO" does not tell me anything about the function of the device. It does not tell me that it has anything to do with the prime mover. Without seeing the drawings or the manual from the manufacturer, I have no idea of what the "EPO" actually does.
I'm not even sure what the OP is using his EPO for. He did not say. I only said if an EPO is connected to a generator and it renders it incapable of starting, it meets the requirement of 445.18(B)...and I further said if the EPO that shuts down the prime mover were lockable per 110.25, it will satisfy the requirement for the disconnecting means in 445.18(A).
I think I understand where your concern is. But the new rule, 445.18(B) as written does not give the detail to support your concern.
The rule does not say the means for the shutdown of the prime mover has to be part of the generator package, or that it has to be listed and labeled as part of the generator, or that it has to be in any drawings or manual from the manufacturer. The rule does not even say where the means for the shutdown of the prime mover needs to be located except that for over 15KW units there has to be an additional means outside the room or enclosure.
This new generator rule reminds me of the new Code rule in 2014 for Rapid Shutdown for Solar PV Systems in 690.12 and 690.12(1) said it had to be within 10 feet of the Array. So installers here in Mass were putting DC disconnects on the roof or high on the wall within 10 feet of the array to comply with the new 690.12. Obviously this is not what was intended.
Well here in Massachusetts when we adopt the new Code on January 1st of the Code cycle (First in the USA) we have to sort out the new rules and do our best to interpret the new Code rules as written. I/we are trying to sort this new rule out here in Massachusetts also. Any input from the members here on the new 445.18(B) will be conducive for a better understanding of the rule for all of us.
So chime in on what you think 445.18(B) of the 2017 Code is saying.