This is from the electrical safety council best practice guide. Using plug in RCD's will clearly not stop some one getting a nasty shock if they drill into a cable concealed in a wall, but in real terms the only case where lack of RCD should be a fail is with 701.415.2 Supplementary equipotential bonding were at the end of the regulation it says
Where the location containing a bath or shower is in a building with a protective equipotential bonding system in accordance with Regulation 411.3.1.2, supplementary equipotential bonding may be omitted where all of the following conditions are met:
(i) All final circuits of the location comply with the requirements for automatic disconnection according to Regulation 411.3.2
(ii) All final circuits of the location have additional protection by means of an RCD in accordance with Regulation 701.411.3.3
(iii) All extraneous-conductive-parts of the location are effectively connected to the protective equipotential bonding according to Regulation 411.3.1.2.
NOTE: The effectiveness of the connection of extraneous-conductive-parts in the location to the main earthing terminal may be assessed. where necessary. by the application of Regulation 415.2.2.
Can't have both missing, either it needs bonding or it needs RCD protection if both are missing it is a fail.
The other is where a manufacturer recommends RCD protection, one has to assume the manufacturer has good reason to say this shower/boiler or other item, must have RCD protection. Where that protection can be given by the use of a plug in RCD then hard to justify a consumer unit change, as to if you can rely on people using plug in devices can't really see that is for the inspector to decide. The MOT inspector does not know if the people using the car actually wear the seat belts, as long as they are there it's a pass. OK today the seat belts which could be unhooked are no longer used, but you can see my point I am sure.
The inspector can award a code C2 or a code C3 to many items, the idea is if everything gets a C3 the owner does not know which items to correct first, so having a C2 and C3 allowed the owner to prioritise his upgrades, yes we gave the label of "potentially dangerous" to code C2, but 230 volt is always potentially dangerous, I have asked in another post, if an inspector decided he would not award and C2 codes could he really be brought to task over it? Code C1 dangerous, and code C3 recommend improvement could be used for all faults.
So maybe the codes should be renamed.
C1 = dangerous
C2 = something which is wrong and I fancy fixing
C3 = something which is wrong but I don't fancy fixing
I do question even awarding a C1, as if dangerous the inspector should make it safe before leaving, and if made safe i.e. isolated, then no longer dangerous.