My opinion, no.
D1.4 should be used, or how will you determine the smallest bar size the welder is qualified for. At the very least, the welder should qualify on an indirect butt w/macroetch.
That will do for fillet welding qual. Of course, T-joint or direct butt CJP will qualify for fillet too. 6.3.3.2
deckerfaw. as I understand the code, you are correct in the governing code. section 1.1(2) settles that issue. In section 6.1.2.1, it says that fillet welds are considered pre qualified and not subject to the testing requirements of that section. But, the other requirements for welding rods, such as preheat and stuff will need to be adhered to. Welder qualification is pretty basic. To keep it official, any welder certed in D1.4 stick, with a 2F or better can weld it up, (oops, I mean horizontal) You'll have to settle the filler metal strength brewhaha, which to use, 7018 or 8018, and you'll be good to go.