No!

If your state has adopted ASME A18.1a 2001 or newer versions the requirement for key operation is no longer a rule. It is not prohibited either, so key operation is optional.

The reason for dropping this requirement was restricting access to the operating controls did not in fact add to the safety or reliability of the equipment. What it did however was to make it more difficult for the very folks the lifts were meant to serve.

For years the industry tried to make it easier for the riding public by all using the same key with a wide distribution. Of course that distribution extended to the delivery person and the night watchman and anyone else in the building thus it really didn’t restrict use to those with mobility impairments or protect the equipment from abuse as a material lift.

Platform lifts are not designed to move freight and should be maintained at the ready for those who need them but key operation did not accomplish that goal so the requirement was dropped.

It is up to the building owner to maintain the means of accessibility. In buildings open to the public key operation makes that difficult. The building owner may however have security concerns or concerns about abuse of the equipment so it is up to the building owner to protect their investment and make sure the lift is available to people with mobility impairments at all times.

Key operation may be the best method and thus making the key available to anyone needing the lift entering the building would need to be addressed. Proximity Devices or Card Readers may be preferred in some cases. Remote control with camera surveillance is an option in high security environments or isolated lift locations such outdoor lifts on college campuses.

A master key system could be employed similar to ones used on commercial elevators. In an elementary school for example during the day to prevent kids from playing on the lift, key operation would be desired but at night when the parents are in the school for a program keyless operation would be preferred. In that case a means to switch from key operation to keyless could be provided.