Prevent Sales Order Approval during Batch Approval

For our Sales Orders, we have a checkbox labeled Hold that is used to keep the SO from transitioning through our SO Approval workflow. Essentially, if Hold is checked, the Submit for Approval button goes away, so it remains in its current state until the field is unchecked. This works well in all but the case where a user is batch approving Sales Orders via Transactions -> Sales -> Approve Sales Orders. The only option here is to create a Filter on the Hold field, which works, but is not nearly foolproof enough (it is very easy