Yikes, that is a little scary.. When I order in bulk I usually get them in the foam container they shipped in from the manufacture or if I order one or two they come bubble wrapped with packing peanuts.
Hard Drives are "a little" resilient when their not powered on in that the drive heads are parked in a cradle to prevent damage to the platters, not sure how much of an impact they can withstand but if it turns on and runs I'm optimistic there is no problem.
That being said I'm sure we've all gotten DOA hard drives, not sure if that's due to shipping of manufacturing.
Generally I've found if the customer knows what a hard drive is and how to install it they don't generally care about packaging when they save money. Most retail box drives don't even include cables or a manual anymore, your lucky if you get some screws.