Can anyone tell me if a water heater pan is required to meet FHA requirements. I have on that is in a cabinet above a washer in a garage. The home is 30 years old and has never had one.
A pan is required when a leak can cause damage to the dwelling.
I do not believe FHA has this requirement but like Jim said if it needs one, it needs one.
What about the TPR? Is it plumbed to within 6" of the floor, or to the exterior?
The TP is plummed to a drain, no problem there.
with air gap?
If the water heater is in the garage and is not at living space floor level, a pan is not required.
I wasn’t gonna push it 
A pan is required if a leaking water heater can cause damage, where ever it is. Also listed in many manufacturers installation manuals
Chuck