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I was looking at an apartment I'm thinking of moving into and I noticed the refrigerator was plugged into a GFCI outlet. I know compressors can trip GFCIS when they start up and make the food spoil but I want to know if this is a code issue so I can bring it to the managements attention

Thanks
No real issue. The code does not prohibit nor require a regrigerator located in a dwelling kitchen to be gfci protected. See 210.52 and 210.8 of the NEC.

In the event the refrigerator trips the gfci repeatedly, it is an indication the refrigerator is not operating properly. The leakage current permitted on appliances should not exceed the threshold of Class A gfci devices (5mA).
The fridge in my tiki bar out by the pool has always been on a GFCI. So far so good.
Fridge and chest freezer in the garage are plugged into one, thing has never tripped. (Except tests, of course.)

Ian A.
They are not required per code but I would avoid it at all possible which is difficult in unfinished garages.

A funny thing happen a couple of years ago. In one on our employee's housing units, the tentants lost a whole freezer full of food because, it turned out that the GFCI was wired wrong for quite a few years. The irony of it was previous occupants did not trip it. The GFCI circuit was part of a multi-wire circuit in which the neutral and one leg fed through the GFCI. It never tripped because they other circuit was never used, there the GFCI circuit was always balanced. When the new occupants were moving in, they used the other circuit creating an unbalance whiched tripped the GFCI. They did not question or even realized the other circuit was not working right (open neutral).
Another issue with gfci protection is that many times, installers will place several receptacle outlets on the load side of the gfci device, be it a breaker or outlet type. Under this configuration, any one appliance may not exceed the 5mA trip setting of the gfci device. However, several appliances operating together may.

This will likely always be a design consideration, but leads one to believe the gfci is malfunctioning, nusiance tripping, or wired incorrectly.
Originally Posted by BPHgravity
Under this configuration, any one appliance may not exceed the 5mA trip setting of the gfci device. However, several appliances operating together may.

I am not disagreeing with you on this. In my years of experiences, I have never had an issue with GFCI's tripping because of this. I have heard dozens of claims of what causes nescience tripping. I would say 0.1% of claims are truly nescience tripping. The rest on the time, they did thier job. This is providing that the circuit is wired properly.

Do not quote me on this but I do not think that household appliances are allowed a certain current leaking (with the exception of surge protectors). I do not think capacitors are allowed an x amount of leakage. They do in time leak due to age. If a GFCI is tripping, it is 99.9% chance there is a pending problem that should be addressed before it comes a real problem.

Number 1 complaint I get about so called defective GFCI's is, "I plugged my hair dryer in and the GFCI trips. I plug it in a regular outlet and it works fine. The GFCI is broken."

I live in a very wet environment. When installed and used properly, we get many good years of service out of them providing the poor power quality dosen't kill the circuit board first.
Not requiring a fridge/freezer to be on GFCI is not because the fridge/freezer will trip it, but because a GFCI trip elsewhere on the circuit could lead to food spoilage. If any household motor is leaking more than 6ma to ground, it's a problem that should be fixed.
I think old fridges trip GFCIs because of internal compressor shorts. (I know there are spikes on the EGC but my scope pictures didn't come out) That is why the freon always smells "burnt" and why energy usage goes up. A bet an AFCI, even without GF protection, is going to trip too so the 2008 code is going to get a lot of these old appliances into the landfill. I believe the same is going to be true of old washing machines (also notorious GFCI trippers). Buy stock in Whirlpool/GE when this hits.
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