210.8 Informational Note No. 2.  For the purposes of this section, when determining distance from receptacles the distance shall be measured as the shortest path the cord of an appliance connected to the receptacle would follow without piercing a floor, wall, ceiling, or fixed barrier, or passing through a door, doorway, or window.

Comment:  A new Informational Note No. 2 now provides clarification on the measurement technique to be utilized when measuring receptacles requiring GFCI protection.

The measurement should be the shortest path a cord of and appliance connected to a receptacle would take without piercing a floor, wall, ceiling, or fixed barrier, or passing through a door, doorway, or window.  The new text would alleviate the need for GFCI protection for receptacles located behind cabinet doors such as a receptacle for a garbage disposal.