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Fires are caused by electrical shorts or leaking refrigerant that drops onto a hot surface like the fridge burner or something else very hot. The recalls put shielding so that if a leak occurs the liquid would be diverted from any heat sources. (They didn't fix the chance of the leak, they just fixed where the leak goes, go figure.)
Being off level means that the refrigerant settles off center and cannot be circulated correctly, therefore will not cool. How this would cause a fire I do not know. Plus the fridge has to be very unlevel to be off level. I've read as much as 6%! Most of us owners can't stand being off level by two degrees, so the chances of the rig being off level enough for the fridge to be off level are slim, except...
I tow about 1 degree off level (higher at the pin). I have towed up and down as much as 7 degree hills with my fridge on. I believe if this was a concern NO ONE would be traveling with their fridge turned on when driving. Hill driving is temporary and with all the movement going on, I think the refrigerant will do fine. If the fridge has been on, the contents are cold and the fridge might not even be running most of the time anyway and this is when the refrigerant is needed.
Maybe if you tow with your fridge on and a leak occurs and you are way off level so that the refrigerant bypasses the diverter shielding then falls onto something hot.... naw... that's a stretch and even then this is a fault of a leak, not being off level.
I finally started traveling with my fridge on because many reknown RV experts admitted they traveled with their fridge on and how to maintain safety (turn off propane prior to fuel stations and tunnels) so I doubt being unlevel will be the cause. I was shocked to hear them doing this at first, but after hearing from experts what the concerns are, how to overcome them or prevent them then I don't worry any more and try to pass on what I've learned.
A bit of knowledge can go a long way. A little bit of wrong information will go even further.
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