Muscle length could play a role in this.
The long head of the triceps comes under stretch/is in extended position when the arm is in an overhead position.
This position seems to lead to significantly more muscle development of the entire triceps on the cable pulley – compared to a hanging arm.
The study compared triceps extensions on the cable pulley in two shoulder positions.
The overhead triceps extensions with dumbbells are a biomechanically disadvantaged variant of the cable pulley.
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Source:
Maeo, S., Wu, Y., Huang, M., Sakurai, H., Kusagawa, Y., Sugiyama, T., Kanehisa, H., & Isaka, T. (2022). Triceps brachii hypertrophy is substantially greater after elbow extension training performed in the overhead versus neutral arm position. European journal of sport science, 1-11. Advance online publication. https://doi.org/10.1080/17461391.2022.2100279
