It's just best practice. This is what the FreeBSD-Documentation has to say about that topic:
"It is recommended that the root user's default shell remain unchanged since shells which are not included in the base distribution are installed to /usr/local/bin. In the event of a problem, the file system where /usr/local/bin is located may not be mounted. In this case, root would not have access to its default shell, preventing root from logging in and fixing the problem."
I guess there is nothing wrong with changing the default root shell to /bin/sh, but I don't know why anyone would like to do that.
Posix requires a bourne shell of some sort, not (t)csh, with a binary name of sh. Freebsd provides this through Ash. BSDs have traditionally provided a C-shell, with FreeBSD being one of the few that's kept csh as the default. OpenBSD uses pdksh, and NetBSD asks.