XR250, i say that for simplicity. Please forgive me - On one hand, i answered you as though i was speaking with the client. I often like to establish simple "rules of thumb" to keep designs and construction consistent and simple. I understand this is not always possible. But, in general, i still believe that it was not the original intent that CFS track was intended to be a load-bearing, flexural element. Without the lip of the Cee, acting as a flange, i consider the vertical element of the horizontal track to be unstable.
I DO agree with you (XR250), if the track is heavy enough and the load is light enough, it WILL work and i accept that. As options, in the distant past, i've used hot-rolled channel and even angle in place of the CFS track. Both of these were unique situations of which i do not recall the details of why.
I typically deal with equipment and light storage mezzanines of 125 PSF. These often do not allow for horizontal track alone, without a stud immediately below. In my case, several years ago, similar to my above statement, i felt i had to establish a standard of simplicity with my typical general contractor client, to make all of our lives simpler when i have to deal with a half-dozen different expediters and thus personalities and opinions. For the past two decades, with the same GC, i've been able to keep THIS venue "simple".