From a practical sense how would you ever police this? The fridge is probably not going to be there when they get the final anyway.
I think we sometimes get into far too much arguing about what the homeowner might do after we leave. The only sure thing is, they will do whatever they want to do. At a certain point we have to trust 240.4(D) to keep things safe and move on to the next job. If they have nuisance tripping we will be back installing another circuit. We all have to eat. The reality is the fridge and washer will peacefully coexist.
