Common sense would tell you that the top is not welded overhead, the backing bar goes in through the access hole and you weld in the downhand/flat position.
Why, pray tell, would you even consider doing that joint overhead? And, very seldom is the backing bar requested to be removed on that joint whereas the bottom on occasion must be removed and backwelded with a 5/16" fillet weld.
Thus, not only was it accomplished through the weld access hole but then had a weld done in the overhead position.
Also, more details are available about the research supporting this in the Commentary for that Clause of D1.8.
Your training on these joints is apparently lacking somewhere along the line.
Brent