I checked e2fsprogs, and from the source code, it doesn't look like they are 
doing something to prevent the race.
(And I don't see how it could prevent it, maybe use /dev/disk/by-uuid/ and rely 
on devfs/udev ?)

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checkfs fails at startup while trying to check /dev/.tmp-XXX
https://bugs.launchpad.net/bugs/118397
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