No. That's what they are, warning shots. As long as they use tracers as they should and don't hit you directly, you cannot consider that any level of quality RP.
You should always aim for high quality RP before shooting someone or else you run the risk of it being RDM and isn't much fun for anyone.
I agree with TomTheDoge, to refer to the rules directly it would fall under:
(2.2) RDM - Random Death Match Definition: Shooting at someone without engaging in any form of quality role play (eg. Giving enough time for them to comply with your order) is considered RDM. (Punishment is a ban)
AND
(3.9) Baiting - Baiting for the sake of a gunfight is not roleplay. (e.g Flying over someone with a chopper waiting for warning shots to instantly shoot them back)