I didn't see any mention of having the keys expire by date (and upon
use).  Unused keys may get left in logs or mail folders so you can
mitigate some risk here.  More importantly, if an unexpired key is
pending use and another is requested you should send the same key
again so you don't risk confusing the user with keys that don't work.

Also, instead of locking down the recovery mechanism why not use
something external?  Refusing to email a key for a privileged account
requires another admin to generate the hash and send it via a trusted
mechanism.

-david
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