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.
I have had tons of problems with dishwashers & garbage disposal units in the past. Motor loads eat these "protection devices" regularly. My state has exempted from protection because of this issue. Make sure to check local code and if required replace the AFCI / GFCI unit and complain to the state electrical board! This is the only way the rules will be changed or manufacturers be held to standards that "normal motor loads or mandated CFL lighting can handle without tripping"!
Best Answer
Kitchen counter receptacles need to be GFCI protected. Refrigerators do not, and should not.
A refrigerator is simply not what GFCIs are for, like manassehkatz says. All the electrical bits are in the bottom back, and you're not likely to knock a refrigerator into the sink!
The fridge circuit definitely does not require GFCI, however if the fridge is on a shared circuit with other outlets which need GFCI, then that does not give you a right to remove GFCI from those outlets! Your inspector is teling you the fridge needs GFCI because it's on a shared circuit with countertop receptacles, and those need GFCI. The fridge does not unless there is a local amendment to code, but it would be an awful amendment!
So the fridge should be removed from the GFCI, either by
The inspector has no "right" in the electrical code to compel you to use GFCI breakers particularly, though they do provide better protection.
The fridge circuit may require AFCI, but that's a different thing than GFCI and the refrigerator is less likely to have a problem with it.
The ideal setup
The ideal setup is a dedicated circuit for just the fridge, with a one-eye receptacle (not the usual twin) behind the fridge where nothing else can reach it, a breaker that exactly matches the receptacle amps (a requirement on 1-socket circuits), and a labelmaker sticker on the receptacle saying "Refrigerator only".
Even more ideal, I would also run it in EMT conduit and metal boxes, and make the case to the AHJ that the AFCI protection is not needed due to the EMT.
The nuclear option
If it is infeasible to remove the refrigerator from GFCI protection, you can remove the GFCI protection from the refrigerator! Use a Kill-a-Watt to measure how many VA the fridge uses when running (not starting), double it, and obtain an isolation transformer of that many VA.
All the GFCI will see is the primary winding of the transformer. What happens past the secondary winding, stays in Vegas. Ground is passed straight through the isolation transformer, so the fridge is still safely grounded. If the fridge has a hot-ground fault, that will do nothing at all.
Since the isolation transformer is a plug-in consumer appliance like a power strip, it is out of the inspector's jurisdiction. He can't say a thing about it.
Alternately you could use a component isolation transformer and build it into the refrigerator. Altering an appliance is not an Electrical Code matter, so again, outside his jurisdiction.