In article ,
says...
So we can see there are definitely different rules in different areas.

Here in a kitchen all (new)counter outlets MUST be split with two branch
circuits, and only 2 outlets total on any (kitchen) circuit.
So GFI outlets are not even possible.

Why aren't GFCI outlets possible?

BTW, the refrigerator is a kitchen outlet and must be on a (another) separate
circuit with *no* GFCI.

GFI's are only required within 3 feet of a sink/tub/shower, or outdoor
outlets.

Unless a refrigerator is plugged in on an "outdoor" (or garage) circuit.

And ALL GFI outlets MUST be grounded.

That's not true. All *new* circuits must be grounded. Older homes may have
ungrounded circuits and it is preferred that they are protected by GFCIs.

And remember that "new construction" and "repairs" are governed by different
rules.

Sure, as well as "existing".

Personally I still think GFI's are over-rated by many, and are not only
unnecessary in many places, but simply don't work.

They simply *do* work. It's not only your life you're playing with here.

Appliances with motors often fry them.
e.g. Refrigerators, Washers, Freezers, Sump Pumps, etc.

They are not required nor suggested for refrigerators, freezers, or quite
likely sump pumps (dunno about the latter, but the same reasoning applies).

--
Keith