Originally posted by hmspe:
For what it's worth, I require single receptacles for all dedicated circuits for refrigerators and freezers in my specifications. I base this on 210-8 (quoting 1999 NEC since it's still prevalent in this area). If it's a refrigerator or freezer in a garage 210-8(a)(2) Exception 2 does not allow a duplex receptacle for one appliance unless the receptacle is GFI protected. For a refrigerator in a kitchen, the second receptacle in a duplex receptacle could essentially only serve the counter top. It might even be within 6' of a sink or basin. That means, for me, that the choices for in kitchen are either (1) a single receptacle on a dedicated circuit, or (2) a GFI protected receptacle/circuit. Since many refrigerators don't play well with GFI, option (1) makes the most sense.
Based on the amount of discussion here I think this would be a good issue to try to get clarified in the 2008 NEC.
Martin