Glen,
the issue isn't clearance but the spray foam itself. Things like the foam trapping J-box covers closed, expanding into the fixture or J-box, etc. More and more LED fixtures are getting approved for direct contact with foam, probably the testing is the hardest part. There is some opinion that just wrapping plastic over the fixture is enough, because most manufacturers just say 'No direct contact' and don't specify a 3" gap, which is a leftover cleance from another application.?
In reply to:
I thought you did not need the clearance on led fixtures. I know they make cans that are zero clearance because thats what I put in my house when I built it .