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Under NCAA rules this would be BBW. We've called (at least once or twice) a similar block on scrimmage kick plays (where BBW is prohibited) when blockers turn almost sideways, go down to one knee, and lay their helmet on the backside of the adjacent lineman. The resulting "block" has the contact actually initiated by the oncoming defensive lineman, with the initial contact below the waist of the defender.
By design and intent (similar to the "shoeshine block" described here) the blocker has placed himself in a position where the initial contact with the opponent will be below the waist. If it occurs at a time or place where BBW is illegal, I'd throw the flag.
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