Although the ADA standards address operable parts of locks – like thumbturns, keypads, turn-buttons, and of course, knobs and levers, keys are not covered by ADA. ADA requires door and gate hardware (including “handles, pulls, latches, and locks and other operable parts”) to be mounted between 34 inches and 48 inches maximum above the floor or ground, and to comply with section 309.4:
309.4 Operation. Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
While there are some key blanks with extended bows which can be easier to use and some local codes or standards that may require them, this type of key does not meet the operational requirements of no tight grasping, pinching, or twisting. The question of keys is answered in the US Access Board’s online guide to the ADA. Are turn-key locks prohibited by the standards?
Key locks or key cards are not prohibited by the standards which apply only to the fixed portions of operable parts. Similarly, items dispensed by ATMs and fare machines, such as receipts, cash, fare cards, and vending machine products are not covered by the standards.
So only permanently-attached parts of the hardware are covered by the ADA standards, and devices which are not permanently attached are not covered, which brings up a very interesting issue with regard to classroom barricade devices. The code change approved in Ohio to allow classroom barricade devices specifically requires temporary door locking devices which are not permanently mounted to the door (with an exception for “individual parts of the temporary door locking device assembly such as bolts, stops, brackets, pins, etc. that do not prevent normal ingress and egress through the door may be permanently mounted…”).