No, that is not a valid assumption. If pixels go off the top, then the histogram chart itself is not tall enough, and that is all it means. This happens when an image has low contrast (overall channel), or is strong in one color (such as mostly sky with no clouds, would be very high in a narrow band on the blue channel).
Think of the height of the parts of the histogram as a count of pixels, because that is all it is.
Tom