I believe the document Teguci is referring to is ACI 360 "Design of Slabs on Ground." The only guidance given for placement of reinforcing within the slab is as follows:
For Crack-Width Control - At or above mid-depth, typically 1.5" to 2" cover below the top surface of the slab.
For Moment Capacity - At the centroid of the tensile area of the uncracked concrete section.
If the slab is taking vertical or lateral loads from the structure then it is covered by ACI-318, and as you had mentioned you are considering it to be a structural element. I would imagine you would take the 3" value for cast against earth, as a slab covered by ACI-318 would be acting almost like a footing in some regards. However I am not entirely sure what the typical value would be as the slabs on grade I have encountered, as Taguci mentioned, are not covered by ACI-318. My guess is that since the steel reinforcement is not as critical for a SOG (in many cases its sole purpose is crack control) that the cover requirements are not as stringent.
frv-
I hate to nit pick, but the commentary to 7.7 reads "Slab or thin shell soffits..." (slab not slabs) which I take to apply only to soffits, as would appear consistent with the remainder of the sentence.
Teguci-
2" does seem to be a common minimum cover for slabs on grade. As you mentioned slabs on grade that do not take loads from the structure are exempt from ACI-318. I have not read anything that specifies a minimum cover for these slabs.