I can't speak for 'we' - but, for myself, I'm sticking with my original intuitive viewpoint, now somewhat supported by the new Note in the regs.
Do the new regulations relate to
isolation?
Of course, the chances are that you could probably get way with manually switching an MCB several times a day for decades without doing any harm to it - but it just doesn't seem/feel particularly 'right' to me (particularly given that I can't test MCBs).
Wouldn't that be functional switching?
Isolation would not be required several times a day for decades.
I understand your point. As you imply, the new note to Table 53.4 relates only to functional switching, not to off-load isolation. Mind you, as I explained to stillp, that Table effectively does not distinguish between off-load isolation and on-load isolation - since, apart from fuses, the other 25 devices said to be suitable for isolation are also indicated as suitable for on-load isolation. As you are perhaps implying, the only real difference between 'on-load isolation' (which some would not even call 'isolation') and 'functional switching' is in relation to the perceived probable frequency of operation.
The terminology is obviously a bit messy - are you perhaps saying that you are advocating/supporting the use of MCBs for manual 'off-load isolation' (which is what many mean when they say 'isolation') but not for 'on-load isolation' (which is effectively 'functional switching')?
My intuitive position is simply based on the fact that an MCB switching mechanism is presumably designed primarily to be operated by its 'trip' mechanism, and manual operation really represents a 'brute force over-riding' of that primary intended method of operation. Hence, whether the circuit is broken on-load or off-load, I still feel that it's not a great idea to use that manual 'over-riding' too frequently (whatever that means) whether it is (or one calls it) 'isolation' or 'functional switching'. Whilst I realise that the new note in the regs is in relation to 'functional switching' ('not isolation') I said that it "somewhat supports" my view, since it seems to me that there are at least partially concerned about frequent manual operation (over-riding), whether one calls what one is doing 'switching' or isolation'.
Having said all that, as I have acknowledged, one could probably usually 'get away with' frequent use of an MCB for manual 'functional switching', let alone 'isolation' (however one defines it), for years or decades without any harm coming to the MCB. As I've implied, if I could test MCBs, I'd be far less concerned. However, since I can't, I prefer to leave the 'automatic safety device' just to do what it was primarily designed to do (plus very occasional use for true, off-load, 'isolation').
Kind Regards, John