My guess is that there probably is a wireway above these panels.
Not only would you have the violation(s) you can see here, but the wireway above would probably have more than 100 conductors in a cross-section, not derated.
This is a "pet peeve" of mine, and I see it too often.
"Elektrition" will put as many 3/4" or 1" conduits across the top of the panel as will fit, so they don't have to figure anything out. (Note the empty conduits) [Linked Image]