GFCI protection needed?

[Jeff Eastman]

...............

[Jerry Peck]

Not required.

That receptacle outlet does not 'serve the countertop surfaces', thus no GFCI protection is needed.

[wayne soper]

Had a garage refrig once hooked up to a GFCI. Behind a bunch of storage. Tripped an accessible outlet. Couldn't get to the GFCI to reset. Didn't know the refrig was plugged into it. Homeowner was PO'ed until they realized they had blocked access. Live and learn