I agree with the concern you’re raising, but most of the time I ran into it, I was using bluetooth to a radio that had its own volume control. The phone was just reacting to the volume setting, not listening and knowing it was too loud.

I haven’t seen that happen in a long time, though. I saw elsewhere in the thread there was a way to disable it, so I might have done that, but I don’t recall seeing it at all on the newer Samsung S24 I got early this year.