That's a good point. So it must only matter if your clearance is to hold on a fix off a radial. The radial will always be 090 however your fix is 20 miles out and you can hold on either side of that fix.
In the event you are to hold at a VOR, the hold side is irrelevant since ATC will always tell you to hold on the desired radial with either left/right turns - which determine the side. For example, it's impossible to hold southwest of the 090 radial with standard (right) turns. The only place to hold would be northeast. Right?