Al, et al ,
You have it right absolutely. Remember where we start from : Set an objective (be it patient safety (as here) or other worthy objective) and then the standard must comply with NFPA's firm determination that if a method can acheive the desired result, it must be permitted.
In this case, our desired result is no liquid water. Can a refrigerant dryer acheive that? Of course - but only with some caveats. Therefore, the standard cannot be written to exclude refrigerant dryers. However, it can be written to deal with the caveats.
First Caveat: a 'frige dryer can only get to 35 degrees pDp (pressure dew point). This is because at 32 degrees, they ice up. The 3 degrees allows for the vagaries of the refrigerant cycle. So, the published pDp from a 'fridge dryer at compressor pressure is expected to be 35 degrees. Note the standard says design dewpoint of 32 degrees. That is the Dalton's law effect already accounted for (well, almost - at the 100 psi at which dryers are rated the Dalton's law effect can in theory get you to about 29-30 degrees. At the more usual pressure that compressors are operated, 80-90 psi, 32 is about as good as you can expect).
Second Caveat : Experience shows 'fridge dryers have difficulties delivering a consistent dew point across the full flow range, but some manufacturers insist this is not true for their units. Fine, so the standard says "at any level of demand".
So the standard also has the alarm set point at 35 degrees (which is as far as the dew point should ever go "off spec" in a properly functioning system using a 'fridge dryer), but a design dew point of "32 degrees", which accounts for the Dalton's Law effect using a 'properly designed system using a 'fridge dryer.
There is also a small thermodyamic benefit in being below frost point. Ice requires extra heat to melt to water, and this can help hold water out of the system too. In our systems, you probably will never see this at work, but it is the reason for the requirement being expressed as "below frost point" instead of a simple "dew point point of...."