Dan,
You are correct. (Edit: – I didn't read James M.'s post before I responded to Dan's question. I defer to James's very well-reasoned analysis)
There is an old forum thread explaining how Franco made one by setting up an opaque vertical PVC pipe 50mm wide and 3m long pipe in his yard. See: http://www.backpackinglight.com/cgi-bin/backpackinglight/forums/thread_display.html?forum_thread_id=34234&skip_to_post=292139#292139
A simple DIY unit, like Franco’s, should provide similar test results to any commercial unit if you just test to initial failure (defined as 3 visible drops). The standard procedure also requires that water be added no faster than the prescribed rate. For a low pressure tester like Franco’s it is 600mm pressure rise/minute.
My commercial unit automatically adds water as it leaks out of a fabric sample (electric pump and control valves) in order to maintain an exact pressure for any period of time regardless of the leakage rate. For that type of test, you would need to periodically refill your water column to the prescribed test level and I would expect significant variance for this scenario only.

