I wonder if I might throw an SPD-shaped spanner in the works here?
If the guidance in the On-Site Guide (section 3.6.4, page 41 of the little brown book) is that dual RCD metal boards are not suitable on TT systems due to the risk of the single-insulated L feeds to the RCCBs making contact with the metal box, presumably the same argument could be made for situations where the L feed to an SPD inside the metal DB is in the form of a single-insulated cable? In which case a time-delayed RCCB acting as a main switch might be a good idea. 534.4.6 (concerning fault protection of SPDs), and figures 16A2 and 16A3 of Appendix 16 refer. Of course, your SPD will not protect your upstream RCCB in this case.
If your SPD is fed directly from the bus bar - such as the single module Wylex SPDs - then this is equivalent to having all RCBOs, a situation that the OSG says an upfront RCD would not be required (though of course it may be needed, or desired, for other reasons).