During line servicing, they can't really account for oil level as this is a shop thing, so will measure extension and pressurize accordingly.
It isn't a shop thing. A full strut fluid servicing or level check can easily be performed during a overnight RON. Heck, a full strut repack can be done on an overnight visit.
I checked the IPC for two 900ER's, one two weeks old, the other four years old. Both have the same strut assy. part numbers.