Never but that donít mean that the device shouldnít be protected by one. If it is behind the frig then it wonít get tested
so we're protecting against a risk that never happens? sounds reasonable to me...

the law requires that any receptacle that is being used for temporary power during construction be GFCI protected
this is because those temporary construction outlets are almost always in an exterior condition, where a GFI is rightly required.

This is exactly what is being said. If a GFCI device trips it is because there was a fault somewhere between the appliance and the power source.
yep, that would be right between those 2, inside the GFCI more often than not