I was wrong! Just read the NEC This is Article 210.8(A)(2) where it talks about GFCI in garages. There appears to be two exceptions....
(A) All Occupancies. All 125-volt, single -phase, 15
and 20-ampere receptacles installed in the
locations specified in (1) through (9) shall have
ground-fault circuit-interrupter protection for
(2) Garages, and also accessory building that have a
floor located at or below grade level not intended
as habitable rooms and limited to storage area,
work areas, and areas of similar use
Exception No. 1 to (2): Receptacles that are not
Exception No.2 to (2): A single receptacle or a
duplex receptacle for two appliances located within
dedicated for each appliance that, in normal use, is
not easily moved from one place to another and that
is cord-and-plug connected in accordance with
400.7(A)(6), (A)(7), OR (A)(8).
So if you put your fridge on a dedicated circuit, only one receptacle for that breaker and nothing else, you don't have to have it on a GFCI.
Edited by MicaBay, 28 September 2014 - 10:43 AM.