Yes, I think it can be racist, but that doesn't necessarily mean the people who designed it were racist or were trying to be racist. I don't think many people think that Bill Clinton, in his heart of hearts is a racist, but obviously, some of the laws he came up with, led the charge on, or otherwise signed into law had serious consequences for the black community in particular. But was his "tough on crime" stance, in his mind, supposed to be exclusively "tougher" on blacks? I don't think so.
On the other hand, as I've already stated, I think the present-day Republicans crafting laws to make it tougher for blacks and other minorities to vote know exactly what they are doing and are doing so specifically to limit how many of them turn out.