It really depends on the dynamic range of the scene. In an extreme contrast scene - eg
The highlights are going to blow anyway (to a lesser or greater degree), so in essence in situations like this you "expose for the mid-tones" and the histogram will have a spike at the end (if you expose for the highlights in a scene like this then the midtones will be down around the noise floor).
Conversely, if you have a very flat scene (ie a low dynamic range scene) then exposing to the right can make it difficult to get the mid-tones right (I know that that doesn't sound right, but that's just the way it is) - however it's not a big big big issue, and it's still better to err on the side of over-exposure than under-exposure for those types of scene.
For a medium dynamic range scene exposing to the right is good (which is probably the most common type of scene anyway).
Another thing you can do to reduce noise is to stack multiple exposures. If you have a base ISO of 200 and you want to shoot at 3200 then if you stack 16 3200 ISO shots and average them then the resultant will be similar to what you would have got at ISO 200.