Insert is a script step dependent on the layout, much like cut/copy/paste, and unlike Set Field. You can always put the container field in the non-visible area of the layout, or use a utility layout.
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This is true of any script step that starts with "insert" as the first word. Copy, Paste and Clear are also like this. Not only do they not work if not on the layout, but when the step executes, the focus is put into the specified field (if the step can specify a field). This can also trip a long list of script triggers.
This is why I characterize these steps as "inherently brittle".
Thus, when possible, (and it is not possible for Insert File), these steps should be avoided in most cases.
Like philmodjunk described, this is part of a family of script steps that are designed to automate or simulate the user's interaction on the current layout. Notice that specifying the field name is optional on Insert File. If not already specified, the script step will Insert into the user's active field.