It's just also the case that RSA in popular use is virtually never OAEP or PSS, and that this isn't a problem you have with ECC constructions, even if you're not using the most misuse-resistant of them.
It's also kind of a dead letter at this point. The ship has sailed: new designs all use curves, and have for something like a decade now.
(I didn't write a paper on this, but I do believe myself to be the proprietor of the Internet's single largest collection of Bleichenbacher padding oracle exploits, in every conceivable language, so there's my bona fides.)