8.1.2.5 says the safety must be on while the firearm is loaded in the holster. And it is a DQ-able offense under 10.5.11
App A3 glossary defines “draw” as the point where the handgun is removed or disengaged from the holster so as to allow access to the trigger.
So the gun does not need to be all the way out before the safety can be flicked off, just maybe an inch or so to clear the trigger.
Reality is that’s a hard thing for an RO to see, plus it tends to happen pretty fast, so even harder to call. IME the few people that have run afoul of 8.1.2.5 and 10.5.11 are those that forget to put the thumb safety on (or lower the hammer in DA) when they holster.