Thanks for the answers, EricH. And I hope I don't appear stubborn about this (we're not even planning to use Great Stuff anyway, that was just the OP's idea). I am trying to understand the rules, and I think our discussion may be useful for other readers as well.
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Try the part about "must be constructed as follows (See Figure 4-4)" from the very top of the rule (though I'm 99% certain they meant Figure 4-5).
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I just read thru that section again, and looked at figures 4-4 and 4-5, and I still don't see many limitations on what we can use. I see a bunch of "optional", "etc.", and "e.g.", which looks to me like the rule makers were deliberately giving us quite a bit of discretion in what we use for much of the bumper. We must use plywood, noodles, and "rugged, smooth cloth", and we can't use velcro for attaching to the frame, but otherwise we have lots of options (as I read it).
Your advice about making sure we can pass inspection is sound, and I've said the same thing to my team and others. Arguing with inspectors is rarely a win-win scenario.