CDA & GBH...I think my distance from the code book is appropriate, and I have no doubts about the sun, nor tomorrow, I was just hoping that there was a clear and concise code path from which I could site for the RDP, indicating the device is compliant.
Thank you for your comments, or reinforcement of each others comments. The question came up for an existing shell building, in which the proposed egress doors had existing dead-latch key-locks on the egress side of the door. This is prohibited with exception for the main entrance door. The Door Scheduled referenced the Spec book for hardware set description, and indicated both a key operated dead latch and paddle. When I asked for clarification on the hardware for the egress side, they initially indicated the key lock/latch was to remain. This caused some confusion, and in the process I vaguely remembered a similar discussion where it was thought that paddles were no longer permitted. As CDA stated, and I agree, as long as panic hardware is not a requirement, the paddle release is permitted as long as it meets the accessibility reach ranges. I also spoke with the manufacturer, and they do not market it as a panic release device.
I have my doubts that if the paddle is mounted at the maximum 48" height that it will offer consistent accessibility, especially on doors that do not swing out, but that is only my opinion.