Okay, let's break this down based on NEC 2008 and the considerations you've raised.

NEC 2008 Requirements



Kitchen Receptacles

NEC 2008 did not require GFCI protection for standard kitchen receptacles serving refrigerators. This is a major difference from later code cycles.

Outdoor Receptacles

NEC 2008 Section 210.8(A)(3) did require GFCI protection for 125-volt, single-phase, 15- and 20-ampere receptacles installed in outdoor locations.

Exception for Snow Removal Equipment Some jurisdictions may have adopted an exception allowing non-GFCI receptacles for snow removal equipment where it was deemed a safety hazard to have the equipment shut off unexpectedly in harsh conditions. It is very unlikely that this would apply to refrigeration.

Analysis for Your Gazebo Situation (Using NEC 2008)


Location, Location, Location

The key question is whether the gazebo is considered an "outdoor location" in the eyes of the NEC. NEC 2008 Article 100 defines "Location, Damp." "A location subject to moderate degrees of moisture, such as some basements, some barns, and some cold-storage warehouses and portions of barns, greenhouses, stables, and similar locations." NEC 2008 Article 100 defines "Location, Wet." "An installation in an underground vault; a location subject to saturation with water or other liquids, such as vehicle washing areas; and unprotected locations exposed to weather."2.

Is the Gazebo an "Outdoor Location" Requiring GFCI? This is the crucial point. If the gazebo is truly enclosed such that rain and weather cannot directly reach the receptacles, it might not be considered an outdoor location if the authority having jurisdiction (AHJ) agrees. However, if it is open enough to be exposed to rain, splashing, or dampness, it probably would be considered an outdoor location.3. Refrigerators and Potential Tripping

You're correct that the concern about nuisance tripping and food spoilage with GFCI protection is valid. This is why later NEC editions have included specific provisions for refrigerators. However, NEC 2008 did not offer a general exception for refrigerators if the receptacle was in a location requiring GFCI.

Ice Maker

The ice maker, like the refrigerators, would be subject to the same GFCI requirements based on the location of the receptacle.

Important Considerations



AHJ is King

The Authority Having Jurisdiction (AHJ) – your local electrical inspector – has the final say in interpreting and enforcing the NEC. You must consult with them. They may have local amendments or interpretations that affect your situation. Document their decision.

Manufacturer's Instructions

Check the installation instructions for the refrigerators and ice maker. Some manufacturers may have specific GFCI requirements.

Grounding

Ensure proper grounding throughout the entire circuit. A properly grounded system can help minimize nuisance tripping.

Consider Upgrading (Maybe)

While you're bound by NEC 2008 for existing wiring, you could consider upgrading the receptacles to GFCI protection anyway, especially if there are safety concerns about moisture. Modern GFCIs are more reliable than older ones, and the peace of mind might be worth it. However, do this only after consulting with the AHJ.

In summary, based on NEC 2008, if the receptacles are in a location that is considered an "outdoor location", then they would need to be GFCI protected. Your key is to determine if the gazebo counts as such. Consult with your local electrical inspector (AHJ) to get their determination and ensure compliance with local codes. Flag for review