I have nad a number of "design pros" insist upon lights directly above tubs and pools... untill I ask them just how would they change a bulb? Where would the ladder go?

Amazingly enough, they see the point, and find another solution.

As for low voltage..... you're right, the NEC is a bit confused on the issue. I will try to put this issue in context.

Before there were GFI's, there was a major move started toward using low voltage for risk-prone aplications. Now, this wasn't just any "low voltage," as if you've ever watched someone arc-weld, you're seeing low voltage at work! No, the low voltage in these applications came from transformers that limited the amount of current available- low power, as well as low voltage.

Examples of where this is still used are sprinkler controls, outdoor garden lights, and your telephone. Some of you may have also seen homes where the light switches controlled relays concealed in the ceiling; same idea.

The advent of the GFI.... which was much contested, not least of all by the low voltage crowd... pulled the rug out from the low voltage industry.