For what its worth, here is what a manufacturer of GFCI receptacles provided to me:
"Per the NEMA (National Electrical Manufacturers Association) 'Application Guide For Ground Fault Circuit Interrupters', refrigerators and freezers should be effectively grounded. These types of appliances may have high electrical leakage caused by moisture. When these appliances are on a GFCI protected circuit, the leakage currents could exceed the GFCI trip threshold and cause the GFCI to trip. (NEMA 280-2002, para. 5.20) Please note, this applies to GFCI receptacles (Class A)"
NEMA recognizes this as a problem related to refrigerators and freezers. Thanks again.