Honestly, now that I think about it, If you try and use it against someone whether they actually be Black it still comes off as you're trying to deem being a black woman (Because that's the usually association with the word bitch) as a bad thing.
According to ATRL if it's a black girl saying it then yes.
If it's considered racist across the board than I can agree with it. I think a lot of times the person just means to be an asshole and not necessarily racists. But it could be either