Same applies anywhere...if you are in the kitchen and a load of hot glass drops into your hair....dinner(!!) or any where else it's just as bad. I understand where you are coming from but IMO the only consideration as far as an EICR is concerned is does it comply with regulations. Bringing personal opinions into EICR's is why two experienced electricians carrying out a report on the same installation may end up with two different reports. If the only consideration is compliance with regulations that would be less likely.
I've seen more than once 50W halogen GU10s above the side of a bath, but just out of zone 2, slightly higher than 2.25m above FFL. To my mind they are not suitable for the location - when stepping out of the bath, you might well touch a hot lamp, if waving bare arms about (as one does, with a towel). In theory they just comply with regs, but to my mind they present a risk for this reason. Plus there is a risk of splashing the hot glass with water from a shower, causing the hot glass to shatter.
I think this is different to other rooms, and the main reason why I'd give them a code in this case.