I'm in total agreement. Their reasoning is that a HO will store various cleaners, pots, towels, etc in the cabinet thereby rendering that receptacle "not readily accessible". I still think it's a crock.
While we're on the subject, how many disposals and DW's come with their own power cords ? I haven't seen a disposal yet that came with its own cord and I've come across one DW in all my years doing electrical work that came with its own cord. Why can't the manufacturers be mandated to install a label right on the unit stating "If not wiring direct and installing a cord and plug use only X or Y type of cord and plug to connect this unit" ? That way an EC doesn't have to go rummaging around to find a manual if an EI requests it.
Just something to add to my wish list.
One other factor comes into play here - appliances that are fastened in place. Most dishwashers are fastened in place. Only those that are truly portable are not intended to be fastened in place. Those type already have a power cord, supply and drain hoses and a finished top and sides. Refrigerators and ranges are not fastened in place appliances as a general rule. Cooktops and ovens usually are fastened in place though.
For a refrigerator the receptacle (disconnecting means) can be behind it because it is essentially considered a portable appliance. Quite frankly I think a GFCI receptacle should be allowed behind the refrigerator for same reason, it is not a fastened in place appliance and no tools are normally necessary to gain access to the receptacle. Doesn't mean I think it is a good design to place it there but NEC isn't a design manual right??
