With regard to the step potential...
I can't recall ever seeing a self contained Hot Tub installed below grade. The ones I have seen set-up so you can step in at grade level have a non-conductive wooden deck built around them with the tub resting on grade below usually accessible from an existing deck already raised 3-4 feet above grade. It is foolish to install a perimeter bond underneath a wooden deck.

I'm not convinced about the comments in the TIA that the person would jump back away from the tub if they were getting a jolt from putting their hand in the water with their feet on the ground and this is not a hazard.

Okay...what if this person were an adult with a newborn in one arm and places her hand in the water with the other and receives a jolt? Will she jump back and drop the infant...probably...and most likely drop the child causing serious injury or even death.

Hopefully common sense will prevail and not the almighty dollar and they will trash this ridiculous TIA.

shortcircuit