2009 IRC E3902.2 Garage and accessory building receptacles. All
125-volt, single-phase, 15- or 20-ampere receptacles installed
in garages and grade-level portions of unfinished accessory
buildings used for storage or work areas shall have groundfault
circuit-interrupter protection for personnel.
A receptacle in an accessory building, an implement
shed or even a storage shed also requires GFCI protection. Sometimes an appliance such as a food
freezer or refrigerator is located in a garage, and
where such an appliance is plugged into a GFCI receptacle,
nuisance tripping of the GFCI device could
cause food to spoil. Therefore, in the past, it was common
to have some appliances supplied by non-GFCI
protected circuits where the appliances and the receptacles
that supplied them were in a space dedicated
for the cord- and plug-connected appliances and such
appliances were “not easily moved,” however, this
practice is no longer allowed. The concern for nuisance
tripping is not valid for modern appliances that
have far less leakage currents than their predecessors.
If an appliance such as older model refrigerator
trips a GFCI device, it proves that the appliance has
high leakage current and should be retired and recycled.
The code believes that there is no valid excuse
for not having GFCI protection in any location where
the occupants could be at risk of electrical shock.
There are no exceptions to this section’s requirements.
Note that electric utility companies often claim that it
is energy wasteful to relocate old inefficient freezers
and refrigerators to the garage where they will continue
to waste energy in their new location and also labor
under extreme temperature conditions.
Joe, Thanks for that. I know Electricians that never put a motor on a GFCI for that reason. It was standard practice here in Nevada at least for the building boom to GFCI the garage but the exception was if it was a single dedicated outlet you didn’t need a GFCI. So there were usually 3 in each garage. One for a freezer, Irrigation, and water softener. Do it looks like that’s not going to be allowed now.