Don't agree with that observation unless you're worried about worms being blinded. The beams are very low where foglights belong.
the beam is projected low, yes. However, the glare being casted north of the beam is over powered because of 2 reasons; 1: the blub is too powerful, and 2: the bulb is not designed for the reflector housing. Not sure what you mean by "worms", but on coming drivers will be blinded by that glare. I have seen many 4th gen Rams with HID's or LED's in their fogs and the glare over powers their headlights, almost like they have high beams on the bumper.
the problem with halogen reflectors is they allow glare to escape the intended beam pastern, theres no sharp cutoff. This is acceptable by DOT since halogens dont get much over 1800 lumens in low beams and especially fog light applications. Factory HID's, or HID/LED designed reflectors have sharp cut offs to prevent glare since the light is so bright, and the tolerances are much tighter. if there were glare in those applications they would blind other drivers, thus case in point..