From the
Pass and Seymour FAQs in their knowledge center.
Q: Should receptacles be mounted with the ground pin up or the ground pin down?
A: This is one of the most common questions the technical group is asked. There is no code or any other requirement that mandates the orientation of a receptacle in regard to ground pin up or ground pin down. It is a recommendation to install it with the ground pin up. The reason for this is if a metal object, such as a tape measure or kitchen utensil, should fall and strike a grounded plug the ground pin is the first to come in contact with the object. If the ground pin is installed down the first blades the object would strike would be the hot and the neutral. Preference of the ground pin orientation seems to be in many areas, a cosmetic decision. The GFCI receptacle is manufactured with reversible markings on the test and reset buttons to allow installation for either preference.
Even if the manufacturer's instructions say to install with the ground up, it would not be a code violation to install with the ground down. 110.3(B) only applies to instructions that are part of the listing and labeling.
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