It is labeled a "storage mezzanine" on the plans. Not rated. Will people walk on it? Absolutely, but you can walk on a plant shelf too. Is it a raised walking surface? Yes, IMHO. Is it a mezzanine? Not too sure if it has no MOE. OSHA is not under my purview. I guess the real base question here is if it is considered an elevated walking surface if you can't walk to it. Since they call it a mezzanine, and I think it is an elevated walking surface by virtue of the fact that you can't get to most it without walking on it, and the intent is very clear, I'll make the comment and hear their argument.
IBC 1015 offers only two relevant exceptions to guard opening limitations, for MEP equipment access and for areas not open to the public in an I-3, F, H, or S occupancy. This is neither. So I think it must have a 42" gate, with max. 4" opening limitations. Seems silly but I don't see another route.