Hmm...unlike the rest of the post, he just asserts this without support.
His sources seem to disagree, certainly with that kind of blanket statement. For example:
Our study takes a pessimistic view of file-system behavior; for example, we even consider the case where renames are not atomic on a system crash.
So this is clearly considered an outlier/unusual.
(e.g., a single 512-byte write or file rename operation are guaranteed to be atomic by many current file systems when running on a hard-disk drive)
[https://www.usenix.org/system/files/conference/osdi14/osdi14...]
I remember reading quite a bit about the (performance reducing) lengths filesystems go to in order to ensure consistency of directory entries even in case of a crash, and for example how "soft updates" were introduced to accomplish the same consistency with less of a performance degradation.
Looking at it from another angle, if you are running on top of a filesystem that cannot keep itself consistent, then you are SOL, there really isn't anything you can do to mitigate.
Just like we can't guarantee that we will be able to persist data that's in memory to disk if the OS is free to kill us at any time. "Best effort" it is, which means getting the data to disk as quickly as possible and not corrupting what is there.