Section 1.3.4 has a L2 control that states:
The backup must be protected by access controls that prevent unauthorized parties from accessing it. Examples of this include safes, safe deposit boxes, or locked drawers where only the operator holds the key/combination for the lock.
This control should be moved to L1 alongside "Backup key exists."
Access controls for the backup key are an obvious requirement for L1.
A counterexample showing why this is necessary: it seems possible to have a backup key sitting on a desk and become L1 certified.