I can't say about other failures of this type, but the one time I installed the o-ring "incorrectly" (in my case, getting it pinched), I had quite a oil spill going on from the cover when I started the engine.
I would say, as long as there were no errant small o-rings at the far end of the filter housing, and you were careful and put the large o-ring on the cover, before putting the cover on the block (watching it all the time...), you should be o.k. - Then check for leaks, of course!