Some might say that violates the working clearances required around electrical equipment, or that the disconnect is not readily accessible. But I believe there is an exception that the disconnect doesn't have to be readily accessible if the equipment it serves is not readily accessible.
So I would give it a thumbs up.
I believe a permeant locking device at the branch panel circuit breaker would also be permitted in lieu of the disconnect at the heater. But I haven't looked in the book to confirm either of these rules.