Where should permanently installed ceiling heat lamp be installed in a bathroom?

This is old school technology and hasn't been done for years in construction. What used to happen, the bathroom being a small room didn't have much ceiling area. Centrally locating the heat lamp fixture to a good position sometimes positioned the fixture in the radius of the in-swinging bathroom door. On many occasions the door was left under the heat lamp with the lamp on and the door caught fire from the build up of heat from the lamp. The electrical code made a revision to keep the fixture out of the arc radius of the door and this made for some strange locations of the fixture. The installing of heat lamp fixtures has just gone out of favour. It has been replaced with in floor heating in bathrooms.