Any of the boot sector viruses have the potential for placing an HD in a state where common format utilities will fail to do their job. In fact,
anything that writes to the boot sector (including Windows) can, conceivably, by purpose or accident, make a drive "unformatable". The key lies in the Boot Record Signature (the last two bytes of the boot record). If this field fails to contain the value 55AAh, neither FORMAT nor FDISK nor most third-party format applications can do their jobs properly.
The Boot Record Signature acts as a sort of EOF (End Of File) marker for the boot sector. FORMAT will fail because, finding no EOF, it assumes that the drive media has not been prepared for formatting. At this point, one might be tempted to restore the boot record by running the "undocumented" FDISK /MBR... which would be an unfortunated choice since, without a Boot Record Signature for reference, FDISK will overwrite the boot sector with zeros, destroying all drive partition information.
I advocate the use of disk editor utilities. I also recommend that all techs have at least the basic understanding of disk structures required for the proper use of said utilities. I'm not saying that everybody should be able to view a boot record in a hex editor and say, "Offset 15h contains F8h, therefore, this is not a floppy disk." I'm just saying that anybody licensed to drive a motorvehicle should be able to pop the hood and,
at least, be able to point at the approximate location of the battery.
BTW: There are thousands of ways to corrupt FAT32, but only a few of them are capable of preventing a reformat.