My guess is that there is a tradeoff between keeping the final RMS output the same as that of an individual signal (1/RMS-sum) vs an absolute guarantee that there is zero chance of clipping (1/sum-of-peak-amplitudes).
Assuming our n-input-signals have amplitude constrained to [-1, 1],
max(RMS) = 1 => max(RMS-sum) = n
So 1/RMS-sum >= 1/Peak-sum.
1/Peak-sum is guarenteed to never clip... but at the cost of very low amplitude for single voices.
RMS is computed with a moving average which means it dynamically adjusts with the signal. However this implies latency which means that clipping is still possible.
You can calculate exactly how much error there will be by analyzing the input signals (e.g. distribution type or by sinusoidal components).
andy