IMO, it falls back to "installed to serve the countertop".. If the receptacle is not accessible to serve the countertop (blocked by the refrigerator) then no GFCI.
I don't see any exception for a refrigerator that hides the receptacle.(6) Kitchens — where the receptacles are installed to serve
the countertop surfaces
(7) Sinks — where receptacles are installed within 1.8 m
(6 ft) from the top inside edge of the bowl of the sink
Personally I think keeping food preservation devices on a GFCI falls just short of stupid..More information, The refrigerator is not accessible from the countertop as of the refrigerator fits inside cabinets. I will have to check the 6 foot measurement.
I questioned the inspector and he said if it had water running to it it needed to be GFCI and didn’t reference any code section.
I have fought with this inspector, On the plumbing code in the past, so it was easier for me just to change out the receptacle to the GFCI rather than make a stand on this. This is a small one horse town and the chief building inspector will side with this particular inspector.
It's not to protect the refrigerator. It's to protect some other device that might be plugged in the receptacle and fall into the sink.It is interesting to me that if the receptacle, not the refrigerator, is within 6' of the sink then the receptacle must be gfci protected. I guess in older homes someone will run a cord from the refrigerator. Seems a bit odd to me...
The 2020 removed door & doorway.Personally I think keeping food preservation devices on a GFCI falls just short of stupid..
Nuisance trips during a lightning storm while your on vacation, come home to a smelly mess that’s easily avoided by putting the receptacle at least 6 ft away behind a cabinet setting like you mentioned.
2017 nec says
The distance shall be measured as the shortest path the cord of an appliance connected to the receptacle would follow without piercing a floor, wall, ceiling, or fixed barrier, or passing through a door, doorway, or window”.
A cabinet door is... a door.
So for the receptacles under the sink...
I agree but It's the way code written. If receptacle outlet its within 6ft of edge of sink. In the 2017 was added to the beginning of 210.8:It is interesting to me that if the receptacle, not the refrigerator, is within 6' of the sink then the receptacle must be gfci protected. I guess in older homes someone will run a cord from the refrigerator. Seems a bit odd to me...
Did it remove “fixed barrier” for the fridge?The 2020 removed door & doorway.
If the refrigerator was not installed at time of final inspection & if the distance from outlet to sink was 6' or less, the outlet would have to be GFCI protected.
My guess is at that time, the cabinet barriers may not have been an issue. Does that matter?