Thanks for the pics. You're right the allowable number of them, or combined surface area, per zone, are for visible blems. I don't know the exact conditions they are measured at, so if they still are visible at some light levels it could be they are counted as blems (assuming they are such). My knowledge stops here as whatever these are, they look nothing I have direct experience of.
Blems I've seen stay visible, and dust / debris also tend to stay more visible than in your examples. Not disappear almost totally given how large they are when the tube is powered off.
It looks to me as the direction of your flash makes them look either black, or look like little bumps that produce shadows slight. If you look where the flash is shining back at you there is distinct bump looking things. Maybe that's just an optical illusion, can't tell. The fiber optics do react to light direction, but if they were shut off fiber tubes then like said they would remain black (or dim at least).
I don't know that much of the manufacturing process if it could be possible to leave those kinds of "bumps" under the final coating on the surface. But if they are there, whether they are considered blems in regards of the allowable limits I don't know.
I wouldn't count debris off yet. It's a pity a one true expert was banned from the forums (though maybe there was good reasons, depends who you ask I guess). I bet he would know. Will send you an IM with his contact info.