He is referring only to Sinopoly cells. It best to check with the manufacturer if using a configuration other than upright, which he also says.These guys seem to have a very good grasp of Prismatics, scroll down to Mechanical Installations, they say "Installing them flat on their side is out of the question in all cases".
Assembling a Lithium Iron Phosphate Marine House Bank | Nordkyn Design
This article describes the process of designing, assembling and balancing a lithium battery bank for use on a yacht.nordkyndesign.com