Hyperbolic argument. Food poisonings account for more deaths by a factor of 1000s VS electrocutions in an household and one that occurs behind a fridge is a stretch IMO.
The irony of an industry that advocates so much for safety in the home, even going beyond code requirements, and then saying there is no way I want my refrigerator on a GFI.
Yes, if that receptacle is 6’ or less from the sink. And that GFCI protection cannot be from a receptacle behind the frig.
I’d like to build off of the OP’s question for a slightly different scenario. I am a new home inspector as of this past Oct and I also remodel/rent my own properties. I want to remodel my houses I sell with my Inspector hat. The last inspector dinged me on GFCI’s not resetting on the last house and almost made me loose the deal all because he couldn’t reset an outlet because it tripped another GFCI in another part of the house (I don’t blame him, If I cant find the offending GFCI in 5 mins, im not tracking it down either)
However:
Say my circuit is set up like this: Panel > GFCI > (sink between) > GFCI > Reg outlet > fridge ( reg outlet behind fridge)
I know I can wire both GFCI’s to each line side, but if I don’t want the GFCI protection to the outlet I can’t easily get too for the fridge, can I connect the first downstream reg outlet to the line side of the second GFCI? Or should I just suck it up, spend the extra money and replace the other two outlets with GFCI’s and wire them all up to line side so that second GFCI doesnt trip them all? This is a small kitchen in older town home. I understand what the NEC says, but older homes have weird wiring sometime.
Where are you from Brandon? Click control panel above and fill out your profile. It helps if we know where your from
Around here (SW Ohio) you’re “supposed to” get permits to remodel anything and therefore everything “should be” brought up to current code, which would be 2ea GFCI 20 amp circuits for for counter appliance outlets, the fridge, garbage disposal, DW and MW each on 20 amp dedicated circuits.
Im in Corpus Christi, TX. We don’t need a permit for “basic” electrical work.
I have called out lack of GFCI outlets to all kitchen counter tops since I started as a defect. Gonna upgrade my narrative by deleting the words counter tops.
Wall receptacles in the kitchen , not over the counter, not within 6 foot of the sink and more than 20 inches above the counter still do not require gfi protection…
And those are very rare. Few kitchen have walls without counters or cabinets.
Write your narrative any old way want. 
I guess eat in kitchens are not common where you are.
I can see Jim’s point, if it’s not required then why have a narrative that recommends it?
Correct. Very rare.
Correct, none of your examples would be considered an outlet serving a Kitchen countertop, and would not be mentioned by me.
(you forgot under the counter and to the side of the counter by the way)
Some under the counter are now requiring gfi protection .