My recollection of doing the charpy test in college does give me the experience to argue that. In a charpy test a precisely sized and prepared standard specimen is hit by a large hammer swung from the same height going the same speed with the same energy every time. The measurement you make is how far the pendulum/hammer swings up after breaking the specimen (end result is total energy absorbed by the specimen = toughness). The other observations that are part of the test is to observe the fracture mode and measure specimen temperature. The specimens used have dimensional and finish tolerances comparable to high quality knives.
From the tests I did years ago, the measurements we got for toughness from this ASTM caliber testing machine varied wildly. So wildly we could not even come up with any reliable measure of toughness from 7 or 8 test runs of these meticulously prepared specimens. The lab Professor didn't even reduce our grade due to our failure to achieve any good toughness data, because our results were typical. The only thing we could determine was a rough idea of the transitional temperature (the temperature a steel goes from ductile to brittle mode fracture), which was determined by observing the fracture mode at different specimen temperatures.
If anyone else here has done any charpy testing, maybe they can offer an opinion of how difficult it is to get consistent and good toughness testing results using any of the standard tests. There is also much disagreement about how useful toughness as a measurement is.
So from remembering the results of my Charpy testing, which is probably a little

more precise and consistent than Noss's test, I will say that yes I can argue your point.