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Does the NL panic hardware trim function satisfy ADA standards?

ICC section A117.1 exempts locks used only for security purposes and so do the ADA standards; but in addition, keys are not covered by the accessibility standards because they are not attached to the door so they are not considered an operable part.  It is generally acceptable to use an NL trim if it is unlocked at the beginning of the day (or when the facility is opened) and the door becomes push/pull by dogging the panic hardware.  Here is a link to some information: Keys and the ADA

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