All depends on how you want to define facing the batter. Is it his body that needs to be facing? His face?
Frankly, I'm not taking that end of the stick. Its most certainly not a balk as he is not doing anything to violate 8.05. No penalty set forth in 8.01 so if its anything its simply a "don't do that" but in reality, I don't really see a problem with what is described in the OP.
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