I think that is a bit harsh.
Sandy has kept out of the limelight completely over the last few months and I'm sure he wouldn't have been there last night if it hadn't been his escape that was up for an award.
I would imagine that he would think it was wonderfully ironic that the show was up for an award for him trying to get out of the house rather than for any of the antics of the other housemates who stayed the full course.
I think if I had been Sandy I would have gone as well because if the clip had won he would definintely have had the last laugh.