The original question appears to refer specifically to the TCG Jade(Enterprise)/Opal/Ruby authentication system (PIN only, no username). I am working on FIPS 140-3 qualification of a TCG Opal SSD so my answer is specifically for this use case. From FIPS:
AS04.57: (Operator authentication — Level 2) A cryptographic module shall at a minimum employ role-based authentication to control access to the module.
AS04.58: (Operator authentication — Levels 3 and 4) A cryptographic module shall employ identity-based authentication mechanisms to control access to the module.
I believe that the TCG authentication system can be considered either role-based or identity-based. So, if you are attempting Level 2 certification, call it role-based and then all the identity-based FIPS requirements become NA. If you are attempting Level 3 certification then call it identity-based in order to qualify for level 3 certification.
This may sound glib but the difference appears to boil down to how many individuals get the PIN. If only one individual gets each PIN then you can claim that the PIN gives you the identity of the individual. If multiple individuals get a PIN then the PIN is a role that is being performed by multiple individuals and the PIN is for the role.
So, if you are attempting Level 3 certification of your Opal SSD you would need to put the restriction of one individual per PIN in your security policy in order to claim the Opal PIN authentication system is "identity-based".
However, as far as level 3 certification goes, I believe there is a sticky issue with the MSID and the PSID since these are obviously NOT identity-based. This you would have to take up with your lab.
The most recent FIPS 140-3 IG appears to indicate the TCG Opal SSD can only be certified to level 3 if you can prove that the "role-based" authorities (MSID and PSID in this case) do not call any services that affect the module’s security. See IG 4.1.A for the definition of such services.