I simply do not share your optimism about response time
and whether that's fast enough to save the converter.
So I still recommend you dig until you find a threat model
for load dumb that some of these "authorities" have seen
fit to bless. They want compliance, to something. Bet on
that, and find it. Then you can set about proof.
What I see in a casual Googling is all about "typical"
pulses and says 5mS risetime. That ought to not tax
your comparator & saturated NPN too badly. But the
open literature doesn't assert anything for the min
rise time, which is your speed challenge.You might
find a few microseconds by making the "scram" path
use transistors turning on, rather than off. Like a
passive PMOS gate turnon (res to Gnd) and a fast
PNP shunt G-S, driven by a turning-on NPN from the
comparator (or just a dumb series zener of 18V or so).
In that searching, several purpose-specific load dump
protection ICs turned up, including from LTC. These
might be suitable and easier to "sell off" to reviewers
as they are made for the job, no surprises, probably
familiar to whoever.