Sure, although the proper way to test it would be to write a lot of data to the drive, issue an fsync, and cut power in the middle of the operation. Rinse and repeat a (few) hundred times for each drive.
There's a guy on btrfs' LKML (also the author of [0]) who is diligent enough to do these tests on much of the hardware he gets, and his experience does not sound good for consumer drives.