I've always seen enforcement of that switch height provision for all main circuit breakers. I don't think there is any justification for interpreting "switch" in a technical sense equivalent to "SWD". I'm curious about what sort of circuit breaker CAN'T be used as a switch. Aren't they ALL usable as isolating switches?
This discussion brings to mind another related 'hair to split': When 230.70(A)(1) talks about the service disconnection means "installed at a readily accessible location", it seems to be addressing the issue of whether the ROOM the disconnect is in is easy to get into (by qualified and responsible personnel), and not the issue of elevation. Do you all agree?