Guenter,
I disagree.  I think you can clean under BGAs (or any other low standoff
device) and clean effectively.  It is an issue of surface tension, pressures
and flow rates.  If you said straight water alone, I would agree.  The
surface tension of water makes it difficult to get under low standoff parts.
 If however, you add a suitable surfactant agent, so that your cleaning
solvent gets under the parts, then it becomes an issue of how much fluid
delivered how fast.  There are cleaning agents that will work for low
standoff devices, without destroying the materials of construction.

Doug Pauls
CSL

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