My reading of 422 and 210.8(B), and your specification of a 208V 3Φ circuit more than 60A for a commercial dishwasher, I would agree that GFCI protection is not mandated, yet... but you didn't mention what code cycle your operating under. There is differences between editions
But to qualify, you need to be hard wired (no receptacle), and over 60A, 150V or less to ground. I recently did a feeder for one of these and was also interested in this subject matter
2020NEC
210.8 (B) Other Than Dwelling Units. All 125-volt through 250-volt receptacles supplied 'by single-phase branch circuits rated 150 volts or less to ground, 50 amperes or less, and all receptacles supplied by three-phase branch circuits rated 150 volts or less to· ground, 100 amperes or less, installed in the locations specified in.210.8(B) (1) through (B) (12) shall have ground fault
circuit-interrupter protection for personnel.
(1) Bathrooms
(2) Kitchens or areas with a sink and permanent provisions for either food preparation or cooking
(3) Rooftops
Exception: Receptacles on rooftops shall not be required to be readily accessible other than from the rooftop.
(4) Outdoors
Exception No. 1 to ( 3) and ( 4 ): Receptacles that are not readily accessible and are supplied by a branch circuit dedicated to electric snow melting, deicing, or pipeline and vessel heating equipment shall be permitted to be installed in accordance with 426.28 or 427.22, as
applicable.
2023 NEC
B) Other Than Dwelling Units. All 125-volt through 250-volt receptacles supplied by single-phase branch circuits rated
150 volt or less. to ground, 50 amperes or less and all receptacles supplied by three phase branch circuit rated 150 volt or
less to ground, 100 amperes or less. installed in the following locations shall be provided with GFCI protection:
(1) Bathrooms
(2) Kitchens
(3) Areas with sinks and permanent provisions for food preparation, beverage preparation, or cooking
(4) Buffet serving areas with permanent provisions for food serving, beverage serving, or cooking
(5) Rooftops
(6) Outdoors
(7) Sinks where receptacles or cord and-plug connected fixed or stationary appliances are installed within 1.8 m (6 ft) from the top inside edge of the bowl of the sink
(8) Indoor damp or wet locations
(9) Locker rooms with associated showering facilities
(10) Garages, accessory buildings, service bays, and similar areas other than vehicle exhibition halls and showrooms
(11) Crawl spaces at or below grade level
(12) unfinished areas of basements
(13) Aquariums, bait wells, and similar open aquatic vessels or containers, such as tanks or bowls, where receptacles
are installed within 1.8 m (6 ft.) from the top inside edge or rim or from the conductive support framing of the vessel or container
14)Laundry areas
(15) Bathtubs and shower stalls where receptacles are installed within 1.8 m (6 ft) of the outside edge of the bathtub or shower stall
Exception No. 1: Receptacles that are not readily accessible and are supplied by a branch circuit dedicated to electric snow melting, deicing,
or pipeline heating equipment shall be permitted to be installed in accordance with 426.28 or 427.22, as applicable.
(C) Crawl Space Lighting Outlets. GFCI protection shall be provided for lighting outlets not exceeding 120 volt installed in crawl spaces.
(D) Specific Appliances. GFCI protection shall be provided for the branch circuit or outlet supplying the following appliances
rated 150 volt or less to ground and 60 amperes or less, single or 3-phase
(1) Automotive vacuum machines
(2) Drinking water coolers and bottle fill stations
(3) High-pressure spray washing machines
(4) Tire inflation machines
(5) Vending machines
(6) Sump pumps
(7) Dishwashers
(8) Electric ranges
(9) Wall-mounted ovens
( 10) Counter-mounted cooking units
( 11) Clothes dryers
(12) Microwave· ovens
(E) Equipment Requiring Servicing. GFCI protection shall be provided for the receptacles required by 210.63.
(F) Outdoor Outlets. For dwellings, all outdoor outlets, other than those covered in 210.8(A), Exception No.1, including outlets installed in the following locations, and supplied by single phase branch circuits rated 150 volts or less to ground, 50 amperes or less, shall be provided with GFCI protection
( 1) Garages that have floors located at or below grade level
(2) Accessory buildings
(3) Boathouses If equipment supplied by an outlet covered under the requirements of this section is replaced, the outlet shall be
supplied with GFCI protection.
