Most national codes only require a stand when flammable vapors may be present such as a garage where automotive gas vapors hang around the floor. Also paint storage counts. So if Jay stores his paint by the water heater, he should move it or get a stand.
I've heard of strapping being required in earthquake areas but I believe it may also be required because of the stand. Jim is out there on the left coast and close to california where they legislate, red tape, code, and proposition everything to death. One uncle said he spent countless thousands of dollars just getting all the permits before he built his house in LA.