IMHO, we are going into shades of 'gray area' and interp by the AHJs.
A J-box that was 'accessable' thru the 6-7" recess can hole was acceptable by some, frowned upon by others, although 'it's not an Article I have right now'. The reasoning leaned toward access to the J-box on the recess frame.
That's what has been 'on the streets' here IMHO.
A side note....anyone thrilled with having to 'work' on a J-box, or the recess frame mounted boxes???
