Thanks for the link. I think that 10^14 figure is the likelyhood of the disk error correction failing to produce a valid result from the underlying media, returning a read error and adding the block to pending bad sectors. A typical read error that is caught by the OS and prompts the user to replace drives.

What I understand by bit flip is a corruption that gets past that check (ie the "flips balance themselves" and produce a valid ECC) and returns bad data to the OS without producing any errors. Only a few filesystems that make their own checksums (like ZFS) would catch this failure mode.

It's one reason I still use ZFS despite the downsides, so I wonder if I'm being too cautious about something that essentially can't happen.