Right now I have such configurations and have been using smpatch
without any problems so far.

I thought I read somewhere (zones guide?) that putting the zone root fs
on zfs was unsupported.

You've missed the earlier part of this thread.  Yes, it's
unsupported, but the question was asked "Does it work anyway?"
and the short answer is "yes, it mostly does, but there
are enough complications and known problems with the
patching and upgrade of this configuration that it
is currently unsupported."

Lori
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