GPUs have always been squarely in the "get stuff to consumers ASAP" camp, rather than NASA-like engineering that can withstand cosmic rays and such.
I also presume an EM simulation would be able to spot it, but prior to rowhammer it is also possible no-one ever thought to check for it (or more likely that they'd check the simulation with random or typical data inputs, not a hitherto-unthought-of attack vector, but that doesn't explain more modern hardware).