Residential Kitchen
In a dwelling unit (residential), GFCI protection is only required for kitchen receptacles that serve the countertop surfaces. There's no requirement to GFCI protect receptacles that serve a refrigerator. Unless the fridge is plugged into a countertop receptacle.
National Electrical Code 2014
Chapter 2 Wiring and Protection
Article 210 Branch Circuits
I. General Provisions
210.8 Ground-Fault Circuit-Interrupter Protection for Personnel. Ground-fault circuit-interrupter protection for personnel shall be provided as required in 210.8(A) through (C). The ground-fault circuit-interrupter shall be installed in a readily accessible location.
(A) Dwelling Units. All 125-volt, single-phase, 15- and
20-ampere receptacles installed in the locations specified in
210.8(A)(1) through (10) shall have ground-fault circuit interrupter protection for personnel.
(6) Kitchens— where the receptacles are installed to serve the countertop surfaces.
Garages, Unfinished Basement, and Other Locations
If the refrigerator is in a garage, boathouse, or unfinished basement. All the receptacles are required to be GFCI protected, so the fridge will have to be plugged into a GFCI protected receptacle.
Why does the fridge trip the GFCI?
Any inductive load when switched off, can produce electromagnetic interference (EMI). This interference can, and often does, trip GFCI devices. Most vapor compression refrigerators have a few inductive loads, any of which could cause the trip.
Is there anything that can be done?
There are devices called snubbers that can be used to reduce, or eliminate the effects of EMI. Installing one between the fridge and the GFCI device, could prevent nuisance trips. The best solution though, is to connect the fridge to a non-GFCI protected circuit.
If that's all it takes, why isn't there already one built in?
While most (all) manufacturers are aware that refrigerators can cause nuisance tripping of GFCI devices, most (none) seem willing to provide a solution. It would be complete speculation for me to try and tell you why they don't care, so of course I'll go through a few possibilities.
- Cost.
Plain and simple, it costs money to implement a solution.
- Warranties and Operating Conditions.
Most refrigerators are designed to operate in a kitchen. Running them in dusty, dirty garages and basements could lead to more warranty covered repairs.
As well it should.
Normally, loads are connected between hot and neutral. Appliances are not supposed to connect hot or neutral to ground; ground is only a shield.
The GFCI compares current on the hot and neutral wires. They should be the same. If they are not, current has found another route, possibly through the grounding system (which isn't supposed to happen) and potentially through some poor human.
Circuit testers are trying to test whether ground is connected... cheaply. They mis-use "hot" as a power source, by connecting a light bulb between hot and ground. If ground is connected correctly, this will light.
In other words, it intentionally creates a hot-ground fault (by sticking a light bulb there). This is exactly the condition GFCIs are designed to detect.
I'm not talking about any ground-fault-test the tester may also have.
So why do testers often work? With a perfect GFCI, they wouldn't work. I suspect it is because GFCI's have detection thresholds above zero, and that is often enough for these testers to "get away with it". I even think there may be a tacit agreement among manufacturers for this, but obviously, lower sensitivity impinges safety. Remember a shock which only stuns you can kill you with secondary effects like falling or drowning.
So either your GFCI is pretty good, or your tester is pretty bad.
Best Answer
GFCIs don't kill refrigerators. A certain percentage of refrigerators will develop leakage currents over time whether they are plugged into a GFCI protected circuit or not.
All of the refrigerators with this defect that are plugged into GFCI protected circuits will eventually start tripping the GFCI, but the ones that are not on protected circuits will show no sign of trouble -- possibly for many years -- until they either give you a nasty tingle or fail to a dead short and blow the breaker.
So to a refrigerator repairman, it seems like most of the refrigerators with "compressors shorting out" are plugged into GFCI circuits because those are the ones that give an early warning of leakage current and are amenable to repair before total failure. As JimmyJames points out in comments, I'm suggesting that the repairman's belief is an example of "survivorship bias".
In the best of all worlds, a refrigerator should be on its own GFCI outlet so that nuisance trips from other outlets will not cause the refrigerator to lose power.