We never got an exploit or chain-of-trust break that can be triggered early enough for something like that. CBHC boots the console basically all the way up to just before the home menu, which is why it isn't very good brick protection (though it can save you in a few specific cases). So, your boot1, IOSU, PowerPC kernel, loader, userspace libraries, root.rpx, boot logos, DS VC and of course, the exploit code, all have to test OK. That's way too many sensitive components to consider CBHC to be brick protection. Sadly, it's also the earliest we've been able to run homebrew code on an average system.
It'd be very nice to find a crack somewhere earlier in that chain, ideally boot1 but early IOSU would also be pretty good. Then maybe we could develop something more akin to a real brick protection.