Not if the standards set forth in the NEC are adhered to. It is not enough to simply disconnect the DC modules from each other and the home runs back to the inverter; the residual voltage left after the disconnection must be bled off in order for the voltage to be less than 30VDC in 30 seconds outside the array and 80V inside the array. I don't know if the SunSpec protocol stipulates whether the inverters or the RSD boxes on the modules perform this function, but earlier SolarEdge inverters used to have to have resistors added to them across the + and - terminals to meet this requirement.
SunSpec is only for control of the RSD MLPE. It does not specifically address RSD and how it should work.
Prior to RSD there was no requirement for how long the DC stage caps in the inverter would keep the DC terminals energized after being disconnected from the PV array. Most instruction manuals recommended that people wait for a specified period after disconnecting the PV array from the inverter before doing any work on the inverters. Some of the bleed-down systems took 5 or 10 minutes to bleed the caps down. After RSD came out it took a while for inverter manufacturers to catch up and modify the inverters to bleed-down faster to comply with RSD. During the intermediate period, there were a lot of interesting things that were tried to make RSD work without the inverters playing along. But now UL-listed string inverters all play nice with RSD and bleed down the DC caps within the allotted time.
The future looks to be murky though with 3741 listed systems being fielded. The assumption that every system with RSD reduces the array voltage to 80V or less will quickly not be as common as 3741 systems that leave the array at full voltage. The results could be shocking.