I would like to believe that -- indeed that is exactly the sort of holistic risk management that I would like to see promoted by aviation safety regulation. While I don't have any reason to doubt that that is policy, it would be reassuring to have confirmation in black-and-white that the authorities' attitude mirrors yours.
In the event of an accident resulting from an icing encounter, the fact that you flew your inappropriately certificated aircraft into ice will be a matter of record. To that extent, the pilot will start on the backfoot. Any conversation relating to whether the icing encounter might reasonably have been predicted will necessarily be by way of mitigation.
The bigger question, which nobody here can answer, is whether as a matter of policy, our regulator is inclined to push enforcement action in cases of accidents induced by icing encounters. I am unaware of any high-profile examples, so I am inclined to conclude either:
a) That most accidents following icing encounters are fatal; or
b) That the CAA tends not to pursue action in such cases.
We agree though, that clarity would be a good thing. The same applies to much of the CAA's enforcement strategy. The problem is that such clarity might encourage those who seem to actively seek ways of arbitraging the rules. We see plenty of them on Pprune.
2D