Ultimately, it comes down to the halting problem: If there's a mechanism that can be used to alter the measured behaviour, then the system can change behaviour to take into account the mechanism.
In other words, unless you keep the poisoning attack strictly inaccessible to the public, the mechanism used to poison will also be possible to use to train models to be resistant to it, or train filters to filter out poisoned data.
At least unless the poisoning attack destroys information to a degree that it would render the poisoned system worthless to humans as well, in which case it'd be unusable.
So either such systems would be insignificant enough to matter, or they will only work for long enough to be noticed, incorporated into training, and fail.
I agree it's an interesting CS challenge, though, as it will certainly expose rough edges where the models and training processes works sufficiently different to humans to allow unobtrusive poisoning for a short while. Then it'll just help us refine and harden the training processes.