This discussion is a bit far fetched, (going for safety's sake). If by upside down you mean the 'business end' of the utensil is down and the handle up, this comes to mind:
If there is a drop of contaminated water (from hands or a splash) it'll work its way to the very tip. The tip also is the last place to dry.
the tip of the utensil (nearly guaranteed to touch food and likely lips and mouth) is touching a surface that many other utensils hit (bottom of the basket). A parallel issue to ground meat from multiple animals here where if one piece is carrying something, then it's spreading.
A clever thing I saw a banquet hall staff do, was to bring the utensils with the bucket to the table which was covered with clean (disinfected) table cloth and tipped it over. That way she didn't have to pull them out by the business end and could grab the handles once they rested on the table.