The way the game is now, injuries are fairly rare. They do happen, but as long as you have a deep team to begin with, you're usually fine if a guy goes down for a few games.
Because of that, I don't even consider durability at all during recruiting, especially at D3. Honestly the guy could have a durability rating of 1 with no potential to increase and if he has whatever else I'm looking for, I'm going after him.