Do you typically install a GFCI for a garbage disposal receptacle?
Are you asking if it is required?
Depends, commercial kitchen or dwelling unit kitchen?
In a dwelling unit kitchen only 15 and 20 amp receptacles that serve counter tops must be GFCI protected.
So a disposal outlet under the counter is not required to be GFCI protected.
In a commercial kitchen if you did have a cord connected disposal connected to any 15 or 20 amp 120 volt receptacles it would be required to be GFCI protected.ALL
15 & 20 amp 120 volt receptacles in commercial kitchens must have GFCI protections...no exceptions.