Hi frodo, welcome!
I see by your profile your an EE, so i am outranked , but i will try and comment.
Art 100, definitions, has 3 different descriptions of accessable.
(as applied to wiring methods)
( as applied to equipment)
are what would be pertinent.
as these are definitions, and the NEC is known to have some definitional difficulty, the call would most likley be interpertational, by the AHJ.
My own gut is that if there is no OCPD's that 110-16 does not apply, after all, how many jb's do you see behind obstructions.
hope i've been useful....