ssh doesn't need to be restarted. As you said, OpenSSH never uses the vulnerable part of OpenSSL code. When the ssh service was started, libcrypto (which isn't

ssh doesn't need to be restarted. As you said, OpenSSH never uses the vulnerable part of OpenSSL code. When the ssh service was started, libcrypto (which isn't vulnerable) was loaded into memory and made available to OpenSSH code. That memory isn't going to be invalidated if libcrypto's on-disk copy changes.