I would expect something stupid like that from nintendo, but not from sony. If you look at the Wii, you can see that nintendo fails at every single update to block homebrew, sometimes they need months and then block only the half of stuff. And the blocked stuff is only blocked partly and can be updated to work again(within 24 hours!). If you look at ps3 homebrew, i wouldn't be surprised if the used exploit is fixed for good in the 3.42 update already.
I don't have a ps3, but i expect the ps3 to have the firmware on some kind of internal memory and it won't reset if your reset your ps3 with any method. Also i wouldn't be surprised that if you have a firmware installer, that you can 1. only install valid firmwares that are not modified and 2. that you can't downgrade. Well downgrade might be possible with such an installer, but i would expect that to brick the ps3 on the next reboot.
In short, i don't say it's totally impossible to downgrade a ps3, but i expect that you need to find a special exploit for this. (and on newer firmwares an exploit to run code at all on top of that)