Every breaker sold has been tested and tripped at least once already, as evidenced by the "tripped" position out of the box.
I will not debate if every breaker is "trip tested". However, they can come out of the box tripped due to bouncing during shipment. Take any standard 1 pole breaker an give it a sharp smack with you hand, it will probably trip.
edit: quote
[This message has been edited by JBD (edited 11-09-2006).]
