Yes, merely reading from swap doesn't imply that your RAM is full. What is true is that _when_ your RAM is full (notice that I don't say "if") it _may_ imply a write to swap, depending in how dirty the page cache is. The problem is, tmpfs is a factor that contributes a lot to pollute the page cache. Temporary files are created to be written and then re-read in short, so all pages used by tmpfs are expected to be dirty.
All of this is of no consequence on system startup, when the page cache is mostly clean. Once the system has been up for a while, though... I think a few tests have to be done.