Coatings mean conformal coating (UL/CSA/EN/BS approved) to keep dust and moisture off the PCB and allows you closer spacings. PC board solder-mask is not a suitable insulator towards safety, as the coating thickness, application method, curing etc. is not controlled and the solder mask's properties are not (safety standard) tested. They have no UL certification if you do research on it.
A TO-220 package does not meet the HV spacing requirements in two ways- between pins and sometimes also the tab insulator and bushing. Most fullpack insulated TO-220 parts are rated for SMPS voltages.
If you don't meet a safety-standard's spacings requirements, they will consider it shorted and proceed to do their single fault injections to try make the product unsafe.
If there are shorts between TO-220 pins, it is not an electrocution hazard. Just an arc starts and the fuse would protect against fire. This failure is acceptable.
If the TO-220 tab (drain) shorts to the heatsink, there could be an electrocution hazard. Not if the heatsink is PE grounded and this is the product's method of protection against electrocution.
Your insulator and bushing need to be considered. Otherwise consider the heatsink as hazardous live and see if electrocution is possible, does the heatsink and enclosure have proper spacings for that.