Without knowing the PSU make and model, i can't say which fan and in turn, which fan bearing is used. Though, out of 4x common fan bearings: sleeve, ball, fluid-dynamic and mag-lev; only sleeve bearing has issues depending on the fan orientation.
Sleeve bearings last the most when fan is in vertical position (about 40.000 hours). If the sleeve bearing fan is horizontal, it's lifespan is easily cut in half (about 20.000 hours) and after some time, fan does start making bearing noises.
I once had PSU with sleeve bearing fan (old Codegen unit) and since fan was sitting horizontally, it started to make noises quite randomly. Tilting the PC/PSU or slowing down the fan (i put a finger at fan center to slow it down) did fix the noise issue short term. But noise always came back.
Fan bearing lifespan is as follows:
sleeve bearing: 20.000 - 40.000 hours
ball bearing: 60.000 - 75.000 hours
fluid-dynamic bearing: 100.000 - 300.000 hours
mag-lev bearing: 300.000+ hours
The Seasonic PSUs all 3x of my PCs use (Skylake, Haswell and AMD, full specs with pics in my sig), have fluid-dynamic bearing fans in them. Making the fan very long lasting and quiet as well. While the case fans that i have, are using either fluid-dynamic bearing (NZXT AER140 RGB fans) or mag-lev bearing (Corsair ML Pro LED series).