It could be, generally the burning position limitation comes from the way, how the lamp is optimized:
The hotter gasses are lighter, so tend to rise. That makes the arc bow up and all the upper parts becoming hotter than the lower, when otherwise equivalent. That could mean rather high temperature differences, e.g. the upper part of the arctube is attacking the upper temperature limit, but the lower remains rather cold, so prevents from the salts evaporating as you would like and in that way limit the lamp performance (efficacy, color quality,...). As with universal burn you do not know which part would be upper or lower, you have to keep all parts at safe distance, so they stay within the safe temperature limits in any burning position.
By restricting the burning position you know, which part would be upper and which lower (or which would never become the highest nor lowest), so you may shape the arc tube and thermal profile so, the differences become way smaller, so when you size it all so it still operates close to the upper limit (it could be even further than before, so usually that means longer life), the coldest spot becomes way warmer, hence the improved performance. You may see this in rather extreme form with the
this example, where they were able to reach practically todays pulse-MH performance by the 70's probe start MH technology, just by reducing the temperature difference between the coldest and hottest point by making the arctube wall in constant disctance from the arc center.