I generally use -6 as a top limit for most of what I do. This covers general corporate, government presentation and testimonial type of stuff.
Some audio will have extreme varying levels, such as outdoor events, sporting activities, racing, etc. making it more difficult to find the average level. For these type of projects, I still use -6 as my baseline, but realize some portions may jump over a bit. If necessary, I keyframe these over -6 levels down so they don't exceed -3 or -4.
For Indie Films and projects that you desire to have a high dynamic range, -12 is very common for dialog and leaves sufficient headroom for the rest.