The graphs on a datasheet show only "typical" devices. The text in the datasheet says the guaranteed minimum and maximum values.
The package for a device does not affect the hFE, it affects only the amount of allowed heating.
If the transistor is saturated the hFE number is not used. The base current should be 1/10th the collector current for most transistors. An old 2N3055 power transistor datasheet says for a collector current of 10A (its maximum allowed collector current is 15A) then a 3.3A base current allows it to saturate (poorly). It needs more base current for less saturation voltage loss.