Based on our wiki definition it is.
But just assume it would be as well about suitability… climbing=*, highway=via_ferrata and highway=scramble would have a access=no since an ordinary pedestrian can’t use them. Then OSM would be kind of useless for mtb-riders, hikers,… since the router would need to ignore access completely in order to route them through their trails. Which at the same time will bring them in situations, where they are not allowed to be in.
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