You have certainly done your homework before posting your question. Well done! You are on the right track! The guideline do encourage the use of graphics in early grades so that a student has the opportunity to explore and learn how to read graphics. Having said that, they must be simplified and only used under specific circumstances.
Examples where you would use tactile graphics are counting exercies in math. In these situations you would substitute the print shape (such as a car, dog, or apple), which would "utilize visual discrimination or visual perception" for a simple shape, such as a circle, thus allowing the reader to explore the shape and texture of the circle, and count how many of them are shown.
The example that you have included in your question falls under the following catagory (which you have cited).
Unit 11.1.2 instructs the transcriber to not create graphics.
Activities that require the reader to perform the tasks below should not be produced as tactile graphics:
- match pictures to sounds, letters, words, or sentences (e.g., phonics activities)
None of the pictures in your example should be done as tactile graphics, nor should words be substituted. You will need to insert a transcriber's note instead.
Hope this helps to clarify the thought process of when it is appropriate to include a tactile graphic for early grades.