Re: court
Bennie
You refer to 90.4. That section is not there for the AHJ to change the code. it is there for unforseen areas and materials and changes that may occur during a code cycle.
To make a change in code requirements requires a signature. Any AHJ who is willing to sign off on changing a 'life safety' requirement is taking a very big risk.
Refering to 90.1 Purpose.
(A)The purpose if this Code is the practical safeguarding of persons and property from hazards arising from the use of electriciy.
(B) ... will result in an installation that is essentially free from hazard but not necessarily efficient, convenient, or adequate for good service ...
In a nutshell, the safety of personnel, not the spoilage of food is the concern here.
Take a visit to any restaurant after dinner and watch the help clean up the kitchen, and you will see the need for this requirement.
I highly doubt that the leakage current in a refrigerator is enough to cause the GFCI to trip. If the GFCI is not faulty, I would have some concerns if I plug in a refrigerator and it trips. I have had a fridge plugged into a GFCI and had no tripping occur.
Pierre