In case your brain is struggling alanl...here you are;
433.3.1 General
A device for protection against overload need not be provided:
(i) For a conductor situated on the load side of the point where a reduction occurs in the value of current carrying capacity, where the conductor is effectively protected against overload by a protective device installed on the supply side of that point.
(ii) For a conductor which, because of the characteristics of the load or supply, is not likely to carry overload current, provided that the conductor is effectively protected against fault current is accordance with the requirements of section 434
(iii) At the origin of an installation where the distributor provides an overload device and agrees that it affords protection to the part of the installation between the origin and the main distribution point of the installation where further overload protection is provided.
433.2.2
Except where regulation 433.2.2 or 433.3 applies, a device for protection against overload shall be installed at the point where a reduction occurs in the value of the current carrying capacity of the conductors of the installation.
Note: A reduction in the current carrying capacity may be due to a change in the cross sectional area, method of installation, type of cable or conductor, or in environmental conditions.
434.2 as mentioned above in 433.2.1(ii) deals with the correct positioning of devices detailed with providing protection against fault currents and follows;
433.2 Position of devices for the protection against fault currents
A device for providing protection against fault currents shall be installed at the point where a reduction in the cross sectional area or other change causes a reduction in the current carrying capacity of the conductors, except where Regulation 434.2.1, 434.2.2 or 434.3 applies.
Now under definitions BS7671 states the following;
Residual Current Device (RCD). A mechanical device or association of devices intended to cause the opening of contacts when the residual current attains a given value under specified conditions.
Overcurrent: A current exceeding the rated value. For conductors the rated value is the current carrying capacity.
Overload Current. An overcurrent occurring in a circuit which is otherwise sound.
Now whilst the resistance of a shower element(s) may be fixed, it is possible for them to overcurrent due to influences that have so far not introduced an fault current, such an occurrence can occur when the shower is installed in a hard water area and they become heavily scaled, causing the element to overheat due to the lack of convection of the heat generated, this increase in heat will alter the electrical properties of the resistive load and can cause it to draw more energy from the supply causing an overload, this is a fault that will eventually cause a failure of the element(s) and would cause an RCD to operate, however this is not what an RCD is there to provide, they are for additional or secondary electrical safety where a fault condition occurs that is insufficient to operate an over current device but may present a danger to users.
Now I would like you to please explain to this gaggle of highly qualified, experienced and knowledgeable Electricians and Engineers why you now believe you are still correct, and if your going to quote Regs, please do not snip them, but quote the whole sections and then attempt to argue your case.