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You need to consider the area. I work at a range that has concrete in the parking lot as well as on the range - muzzle down is out as Jang pointed out. Also, (from personal observation) people consider anything less than horizontal as down - that wouldn't cut it. Pointing the muzzle downrange all the time will result in sweeping the shooters on the line while in the parking lot or checking in and we do have people bring deer rifles still loaded from last years season. Up is all that's left. Up is also easier for RSO's to verify and more comfortable for shooters. While bullets can travel 5+ miles, that is when fired at a 45 deg angle and we are miles from the nearest town. Any ND's, if the muzzle is up will most likely land in the woods or in a field. Sometimes it's a least of all evils thing.
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