It seems that this is a judgment call.However, the majority seem to agree to omit GFCI on refrig where possible. As far as theory v. empirical data, what one chooses to believe is their own personal right aftre all, even scientific observations are often skewed by the personal expectations and beliefs of the observer(can you say creation v.evolution?). And,just because someone hasn't experienced something it doesn't mean it doesn't exist. The question seems to have been answered. Next topic, please. (Boy, I used to enjoy this site!).