Opening a disconnect in the closed position

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That is not in the NEC. It may be in the product standard, but I am not sure.

As Don said it's not in the code forbidding it.
I know at one time you could open them in the closed position by turning a screw on the side that over rode the door locks and would let you open it in the closed position.
I don't think you can do that now. May be a UL thing or OSHA thing.
 
NFPA 79 (the standard for industrial machine controls) requires that doors be interlocked with a disconnecting device so that you cannot enter an enclosure without first killing power and any defeater mechanism requires a tool to operate, implying that whomever defeats it is a "qualified worker" in a facility.

The NEC has few requirements for this in Low Voltage, hence the existence of fused pull-outs as disconnect devices. But there are a few exceptions; bus duct disconnects (368.239), and Medium Voltage equipment MUST be interlocked.
 
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