Based on what the vast majority have posted here, I guess I stand corrected. I haven't done too much in the area of new residential construction in years - mostly remodel. To date I have not failed an inspection because I didn't put the refer on a GFCI protected circuit. That doesn't mean I did the right thing or maybe that the EI didn't pick up on it.
As many others have voiced their disapproving opinions regarding AFCI's in this Forum let me state mine on this subject. I think it's a bad idea to put a refer on a GFCI protected circuit. We now have to put DW's on GFCI circuits but if the DW fails the dishes didn't get washed - NO BIG DEAL. But if the refer fails due to a GFCI problem you lose your food. I can state, without a doubt, that HO's are not going to put up with this. If one of us EI's don't change out the GFCI protection they'll get Joe Handyman to make the change or do it themselves. I think the CMP's need to revisit this requirement or force the manufacturers to improve their products. Just my 2 cents worth.