Within reason, that is true: Google released stats a year or so ago about their failure rates, which found little correlations at all between failure and anything environmental.
The only thing that was found was that the time between the first sector going bad and the drive dying was short. The rest of the SMART figures were practically useless.
http://labs.google.com/papers/disk_failures.pdf
That Said, if a drive runs hotter than another, equivalent model, then that drive is wasting energy.