Not really. To be really sure, set ! as a password in /etc/shadow. That's what most distributions do. PAM has another security measure, if user's shell is not in /etc/shells, it's also considered a locked account and will not allow login.
For example, running "deluser" later could end up performing a "remove home" cleanup operation, and you certainly don't want to remove the /dev/null file.
It's not incompatible with the other measures you described.
FWIW I also log, for every "user" on the system, anything from a user that's not supposed to access the net.