EMERGENCY ACTION PLAN
POLICY & PURPOSE
It is Zoetis Union City policy to comply with State & Federal laws regarding having a plan to deal with emergency situations appropriately.
This plan is designed to comply with: California Code of Regulations Fire Prevention Plan (FPP) Title 8, General Industry Safety Orders, §3221; 29 CFR 1910.38 and 29 CFR 1910.39 Fire Prevention Plan Requirements; as well as OSHA & Cal-OSHA requirements regarding bio-hazardous spills, hazardous chemical spills, & releases.
This document discusses the types of emergencies that may occur and provides instructions and guidance on responding to each.
Sections of this program include: (click on each button for more detail or use switch to open/close all)
MEDICAL EMERGENCIES
An emergency is any medical problem that could cause death or permanent injury if not treated quickly. Severe pain in some instances can also be a medical emergency, such as the pain associated with kidney stones or appendicitis.
Some examples of medical emergencies are:
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Chest pain accompanied by sweating, nausea, vomiting, shortness of breath, radiating pain that moves to the arm or neck, dizziness, or feeling that your heart is beating irregularly or too fast
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Choking
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Severe bleeding that doesn't stop after 15 minutes of direct pressure
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Fainting
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Broken or displaced bones
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Swallowing poison
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Burns
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Suddenly not being able to walk, speak, or move a portion of your body
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Shortness of breath or difficulty in breathing
ABAXIS ERT (Emergency Response Team)
Zoetis Union City (Abaxis) has an Emergency Response Team (ERT) that is regularly trained and certified on first aid, CPR, AED, and more. The ERT assists with medical emergencies, emergency evacuations, and other emergency situations.
Contact ERT by dialing 999 from any site landline (phone). The first ERT member to pick up the call collects relevant information and dispatches other team members via radio. They may also make the determination to contact outside emergency responders based on the nature of the situation.
Minor Illnesses/Injuries
Zoetis Union City provides stocked first-aid cabinets in designated locations throughout our campus. Some examples of non-emergencies which can be treated with self-care are:
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Cold or flu symptoms
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Sore throat
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Earache
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A fever that is relieved with over-the-counter medication
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Toothache
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Minor cuts, scrapes and abrasions
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Muscle sprains
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Sunburn
EVACUATION PROCEDURES
Zoetis Union City has established procedures for safe evacuation of our facilities in the event of an emergency situation.
Situations which may require evacuation from the building include:
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Fire
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Flood
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Earthquake
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Storm
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Hazardous materials release
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Power Outage
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Bomb Threat
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Terrorism
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Civil Disturbance
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Other structural damage to the building
Preparedness for evacuations includes drills and voluntary role assignment/training.
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Evacuation drills are conducted at least annually. Drills are designed to familiarize workers with the proper procedures for evacuating the building and with the location of the Evacuation Assembly Zones.
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Voluntary roles have been assigned to several Union City team members to assist in orderly evacuations they include:
Each colleague is authorized to activate a pull-alarm in the event of a fire. Pull-alarms are located near the exits. This will initiate an alert including the sounding of alarms and the flashing of fire strobe lights.
For other events the receptionist may announce an evacuation alert through our paging system.
Once notified of an evacuation alert:
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Exit promptly through the nearest safe doorway.
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In the event of an earthquake, fire or other structural building damage, be aware of falling debris, downed power lines, burning embers and smoke.
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Assemble in the designated assembly zone as indicated on the evacuation maps.
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Evacuation maps are posted in various locations around the buildings primarily in the lunch rooms and by the main exit doors. Click to view maps for [Bldg 1] [ Bldg 2] [Bldg 3] [Bldg 4]
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Check in with the Zone Leader for roll call and assist your Zone Leader in accounting for all people in your zone.
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ERT members report to Incident Commander (IC) after the roll call.
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Report any first-hand knowledge of the cause for the evacuation or of hazardous conditions or operations left behind to your Zone Leader. This information is then conveyed to the IC, who then tells emergency responders what to expect when they enter the building.
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If the Fire Department is summoned, colleagues may not re-enter the building until after the building has been assessed, the Fire Department gives permission, and the IC announces “All-Clear.”
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Re-enter the building only after IC announces “All-Clear.”
FIRE SAFETY
Fires can occur for a variety of reasons, particularly where flammable materials are stored and handled. Therefore, systems have been installed in each building to alert colleagues to a fire in the building. The fire sprinkler system becomes activated when smoke or a rapid rise in temperature is detected, which then sets off fire alarms throughout the building. The Plan is intended to prevent personal injuries and loss of life and property, and to avoid business interruptions that could result from fires.
Cal/OSHA mandates a Fire Prevention Plan (FPP) under California Code of Regulations, Title 8, General Industry Safety Orders, §3221.
Facilities and EH&S are responsible for the interpreting and applying fire protection codes and regulations and are authorized to enforce applicable fire and life-safety codes, laws, and regulations in our facilities.
FIRE SAFETY EQUIPMENT
Building and fire codes specify requirements for the installation and maintenance of some fire equipment, such as fire extinguishers and fire detection systems in our buildings.
Required equipment includes:
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Automatic sprinkler systems - Ceiling sprinklers are typically activated when room temperature reaches a critical point. Fires may start before sprinklers are activated.
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Fire alarm pull stations - Located near each exit.
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Smoke detectors - are connected to the alarm system as an additional protective measure.
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Fire Extinguishers - Multi-purpose, A-B-C rated extinguishers are located throughout the facility and are appropriate for most fires. Some locations, such as server rooms or areas with sensitive equipment, may also have carbon dioxide extinguishers or Halon extinguishers. Fire extinguishers are required to be inspected monthly and recharged or replaced annually.
FIRE ALARMS
In the event a colleague discovers a fire, he/she is expected to pull the alarm and activate the alarm system while exiting the building, thus alerting all other colleagues to the danger. Fire alarm pull stations are located on the wall near each primary exit.
When an alarm sounds, follow standard evacuation procedures as described earlier. When alarms are activated they produce a loud sound and a strobe light that flashes. Bathroom and some conference rooms may only have strobe lights. Colleagues are taught to recognize Fire Strobes as alarms and to follow the same evacuation procedures..
Once the alarm is activated the Fire Department is notified by our alarm monitoring vendor. There are alarm panels in the lobby of each building which display the location, or zone, that went into alarm first. This is helpful in pinpointing the problem and helps responders when they assess the reason for the alarm. The fire alarm panel monitors the smoke and heat detectors and must not be tampered with for any reason.
Once the Fire Department is on scene they are in charge of the incident and will determine when it is appropriate to silence the alarm panel.
IF TRAPPED IN A BURNING BUILDING
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Look for lighted EXIT signs that are located at each exit.
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Crawl low to the floor if the air is smoky.
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Cover your mouth with a shirt or damp cloth to help filter out smoke.
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If you can’t see, get to a wall and follow it to an exit.
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Before opening any door, put the back of your hand against the door to see if it feels warm. If it does do not open it, find another exit.
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If you become disoriented and can’t find an exit, get to a window. You may be able to open it or break it.
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If your clothes catch on fire the rule is: STOP, DROP and ROLL.
USING A FIRE EXTINGUISHER
WARNING - Use a fire extinguisher only if you are trained and comfortable with its proper operation.
If you choose to attempt to control a fire with an extinguisher, follow this procedures:
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Ask another colleague to activate the alarm pull station.
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Ask a another colleague to stand by in case you need help. If the fire gets out of control or you have misgivings, then leave the building and ensure that the alarm sounds before exiting.
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Discharge the entire contents of the fire extinguisher. If the fire is not out quickly, leave the building.
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Assemble in the Evacuation Assembly Area with your department.
Remember: You should NEVER attempt to use a fire extinguisher unless you have been properly trained and another trained colleague is standing by to assist in controlling the risk of injury from a fire.
RECORDKEEPING
Records of scheduled and periodic inspections will be maintained for three (3) years.
FIRE PREVENTION
Each year, fire erupts at some 70,000 U.S. workplaces, killing 200 employees, injuring thousands, and causing billions of dollars in property damage. Most workplace fires are the result of human behavior rather than equipment failure, which means they can be prevented with a proactive program reinforced by training.
Fire risks are everywhere—from chemicals and electricity to flammable liquids, combustible materials, compressed gases, smoking, and poor housekeeping. No workplace is completely safe. Below are some steps that you can take to make sure that you understand what causes fires, and how they can be prevented.
UNDERSTANDING THE NATURE OF FIRE
Fire requires three components in order to exist:
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heat,
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fuel &
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oxygen
If any of the components are removed, the fire is extinguished.
PREVENTING FIRE RISK IN THE WORKPLACE
For more information on flammable & combustible chemicals please see our Chemical Hygiene Plan.
EARTHQUAKE SAFETY
Earthquakes are a fact of life in the Bay Area and Union City colleagues are encouraged to prepare for safe refuge in the event of a major one happening. Earthquakes are unpredictable and can pose a host of problems, depending on the magnitude of the quake and the number and force of aftershocks.
EARTHQUAKE PREPAREDNESS
As earthquakes are a natural phenomenon there is nothing we can do to prevent earthquakes. We can, however, prepare for the inevitability that they will happen. Some things we can do at Zoetis Union City to prepare include:
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Seismically brace equipment and materials that are over 48 inches (4 feet)high and/or weigh over 400 pounds.
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Ensure that storage cabinets, shelving and storage surfaces have been integrally anchored and secured and provided with restraints that will prevent stored items from creeping under vibration and falling out of shelves or off surfaces. Stacks of items can only be allowed if these stacks are held or bound to prevent their collapse. Keep all breakable and heavy items in low, secured cabinets.
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Secure and brace compressed gases and liquid nitrogen dewars and freezers. Connecting lines should have sufficient slack and flexibility to withstand vibrations and displacements.
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Know the location of flashlights and portable battery-operated radios (with extra batteries).
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Keep exit routes clear. Do not block, or partially block, doors or hallways.
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Practice Drop, Cover & Hold On exercises on at least an annual basis.
HOW COLLEAGUES CAN PREPARE
All colleague should:
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establish a family communication plan
Colleagues who must cross a bridge in order to get home or who may have to travel over long distances should consider:
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purchasing an earthquake survival kit to keep in their car
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establishing a contingency plan in case they cannot get home for several days
EARTHQUAKE RESPONSE WHILE IN A BUILDING
FEMA now recommends the following response when an earthquake occurs where you are:
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DROP to the ground;
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take COVER by getting under a sturdy table or other piece of furniture;
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and HOLD ON until the shaking stops. If there isn't a table or desk near you, cover your face and head with your arms and crouch in an inside corner of the building.
EARTHQUAKE RESPONSE UNDER OTHER CONDITIONS
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OUTSIDE - If you are outside the building at the time of an earthquake, stay outside and move away from buildings and power lines to the Assembly Area. Most earthquake injuries occur as people enter or leave buildings.
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DRIVING - If you are in a moving vehicle, stop if it is safe. Move your car as far out of the normal traffic pattern as possible. Do not stop on or under a bridge, overpass or tunnel, or under trees, light poles, electrical power lines or signs.
EVACUATION RESPONSE
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Be prepared for aftershocks. Although most aftershocks are smaller than the main shock, some may be large enough to cause additional damage or bring weakened structures down.
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Follow standard evacuation procedures and assemble with your department in the Evacuation Assembly Area.
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The first priority is your own life safety. Provide assistance with evacuation when needed only if it is safe for you to do so.
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Do not attempt to move anyone who may be seriously injured without a trained first aid provider. Immediately after exiting the building let the Zone Leader know that you made it safely to the evacuation zone, and about the injury and location of the injured person. The Zone Leader will pass this information to the IC and a trained first aid provider or ERT member will be notified.
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Be aware of dangerous locations and exit routes as you evacuate. These may include glass doors, hanging objects, tree limbs, debris falling from buildings, or downed electrical lines.
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POST-EVACUATION RESPONSE
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Once in your assigned Evacuation Zone, wait for roll call. Remain in the assembly area until the "All Clear" order is issued by the Incident Commander.
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A strong earthquake may make the building unstable or dangerous. It may also damage roadways and other infrastructure. Cell service may go down or be impacted by high call volume.
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Management will work with facilities to determine building safety, emergency safety measures, and whether or not releasing workers to go home would be the best plan, or if arrange need to be made to stay on-site.
BUILDING SAFETY MEASURES
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Facilities will check for building structural damage, if safe to do so.
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Facilities will check the immediate area for hazardous materials spills, if safe to do so.
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Facilities will shut off any gas or electrical service to the building, if safe to do so.
EMERGENCY SAFETY MEASURES
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ERT will check for injuries to colleagues and provide emergency first aid.
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ERT may provide search and rescue operations, if safe to do so.
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Under the immediate direction of the Incident Commander or ERT, other workers may be organized to assist in fire watch, hazardous spill watch, or other low risk activities.
DISASTER RECOVERY
Zoetis Union City has established a disaster recovery team made up of members of executive management, facilities and IT. This team is responsible for developing a plan to ensure the businesses continuity.
HAZARDOUS MATERIALS EXPOSURE
In this section we discuss exposure to hazardous materials. By exposure we mean that the material got on you or inside of you while performing your job duties.
HAZARDOUS CHEMICALS
Chemical exposures can be severe and should be handled quickly. In all cases, medical attention must be provided. The following are guidelines in case you or a co-worker are exposed to a hazardous chemical:
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Call 9-1-1# if a worker has been exposed to a particularly harmful chemical, or is suffering from an exposure. Always assist injured workers to get medical treatment first.
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Dial 9-9-9 to call ERT to assist the exposed colleague.
Colleagues who are exposed to hazardous chemicals and not injured must proceed quickly to a shower.
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Use an eye wash fountain for exposures to the eyes or face. Assist co-workers to the shower and eyewash fountain. Flush the exposed area with running water for at least 15 minutes.
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Assist colleagues who suffer from exposure to the eyes by holding their head under the eyewash fountain. If they are wearing contact lenses you may have to remove them while assisting.
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Colleagues whose clothing has become contaminated from hazardous chemicals or hazardous waste must quickly proceed to a bathroom or locker room to remove the clothing and put it in a plastic bag until it can be decontaminated.
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If needed, call ahead to the occupational health clinic or the hospital to inform them that an exposed colleague is being transported to their facility, and provide a SDS for the material(s) to which the colleague was exposed.
The supervisor and colleague must complete an Workplace Incident Report and submit it to Human Resources or EH&S at the earliest possible convenience.
HAZ-MAT SPILLS & RELEASES
Colleagues who are not trained in spill clean-up procedures must contact the ERT (999) to help assess the clean-up strategy and call for additional help, if necessary.
For spills which pose a risk of exposure to people, a risk to the environment or in volumes that are too great (> 1 liter) to be handled with spill clean-up materials available:
CALL CLEAN HARBORS AT 8-1-800-OILSPILL
ASSESS, ISOLATE, REPORT, PROTECT
Click here for a slide show with the steps to clean up a biological or chemical spill
Take the following steps to prepare for a biological or chemical spill clean-up:
BIOLOGICAL SPILLS
Biological spills commonly involve liquids that contain potentially pathogenic materials. The following procedure should be used after a spill:
NOTE: One-size-fits-all scrub pants are available in the HWAR, if your street pants become contaminated with blood due to a spill. Your supervisor should have access.
The highest hazard biological agent handled at Zoetis Union City is human blood tainted with unknown pathogens. Colleagues must assume that human blood can contain human disease-causing agents; therefore, care must be taken to protect open wounds, mucous membranes and the eyes.
CHEMICAL SPILLS
Chemical spills can sometimes pose a greater risk of exposure than actually working with chemicals. Therefore it is important that colleagues make personal safety a primary consideration when responding to a chemical spill. NEVER try to clean up a spill if you are untrained, do not have the necessary equipment, or are afraid to do so.
The following spill clean-up procedure is intended for spills that can reasonably be cleaned up in the immediate work area:
Report all spills to your supervisor as soon as possible after the incident. After the spill is cleaned up and under control, supervisors of colleagues who are involved with the spill are required to submit an Workplace Incident Report to EH&S and HR.
CHEMICAL RELEASES
Chemicals that are purchased in bulk quantities, such as reagents and solvents, could potentially be spilled or released from a delivery truck or as a result of hazardous waste spill outside the building. In these circumstances, the most important response is to protect materials from entering storm drains in the parking lot to prevent environmental contamination. If you are the first to observe the spill or are directly involved, the following procedures apply:
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Ensure personal safety and avoid direct contact that may result in an exposure or contamination.
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If the spilled material threatens to enter a storm drain, get a spill kit from the Waste Room and surround the storm drain with absorbent booms. Absorbent booms are long fabric-filled tubes that can absorb liquids and prevent them from migrating beyond the spill area.
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Contact Clean Harbors to provide emergency spill response for situations which are beyond the capabilities of the colleagues available.
STATE OES REPORTING REQUIREMENTS
Zoetis Union City is required to call 9-1-1 if spilled hazardous materials come in contact with the bay, soil, or landscaping on the grounds outside the facility. The spill must also be reported to the State Office of Emergency Services within 24 hours.
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Call 9-1-1 to report the spill to the local authorities.
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Call the State Department of Emergency Services Spill Reporting Hotline at 8-1-800-852-7550.
Note: An Zoetis Union City representative must remain at the scene of a spill or release until the appropriate agencies are alerted and respond.
POWER OUTAGES
A power outage is not a major cause of concern, but is an inconvenience. For colleagues in bead production or R&D special precautions should be implemented:
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Colleagues working in Bead production will need to evacuate immediately to fresh air or alternate location if the power goes out because an active ventilation system is a requirement for working in a room with nitrogen as part of the process. Nitrogen added into a room without adequate ventilation can rapidly become an oxygen deficient environment which is dangerous to the health and safety of our colleagues.
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Colleagues working in R&D Lab with Bio-cabinets or Fume Hoods should immediately cease experiments and if possible cap or cover any containers of harmful chemicals or pathogens when the power drops. If this is not possible, all colleagues in the lab may need to evacuate to fresh air depending upon the nature of the pathogens or chemicals being used.
For other areas of operations and administration, If the power goes out emergency generators will turn on to provide power to critical operations only. Rotor production, equipment production and repair will be put on hold until power returns. Site management will determine whether or not operations will be suspended for the shift based on information received from the power provider regarding reason for the outage and expected resolution time.
BOMB THREAT
Bomb Threats across the U.S.
A total of 1,536 bomb threat incidents were reported in 2016
The Bomb/Arson Tracking System (BATS) is the national repository for arson and explosive related incidents reported to the United States Bomb Data Center (USBDC) from law enforcement/ public safety agencies.
States reporting the most bomb threats in BATS are Illinois (170), Texas (112), Ohio (109), and Maryland (88).
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529 bomb threats made to schools.
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254 bomb threats to businesses.
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186 bomb threats made to residences.
Since 2014, there has been an 33% increase in threats to schools.
Bomb threats to residences have decreased 35% between 2014 and 2016.
The USBDC captures critical information reported in BATS, including bomb threats, bombings, arson and explosive incidents, hoaxes, suspicious packages, theft and recoveries.
Bomb Threat Received By Phone
If you are the recipient of a bomb threat by phone while working at the site, take the following actions:
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Write down the exact time the call was received.
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If caller id shows a phone number, write that down also
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Write down the exact first words of the caller
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Try to remain calm, courteous, and attentive to the caller. Do not interrupt!
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Get attention of someone else in the room. Give the person a note saying, "Call the police - bomb threat!"
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Write down the exact words of the caller and the threat
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Don't hang up. Leave the line open
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Notify a supervisor
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Try to keep the caller on the line by asking the following questions:
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When will it explode? What time?
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Where is it located? What building? What room?
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What does it look like?
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What kind of bomb is it?
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What will set it off?
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Why are you doing this?
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Who are you?
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Are you aware that you could kill or injure innocent people in addition to the ones you intend to hurt?
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Immediately after the call complete this form to assist the authorities in identifying the caller.
Suspicious Packages
If a suspicious package is received and you suspect it may be a bomb:
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Do not open — lay it down gently and keep it level.
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Isolate it and clear out the area at least 200 feet.
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Do not put it in water.
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Do not put or lock it in a cabinet or drawer.
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If you have windows, open them.
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Contact police.
If a suspicious package or envelope is received and you suspect it may be a biochemical agent and is unopened:
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Previous steps except do not open windows.
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Do not attempt to open article.
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Place it in a clear bag and seal it.
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Record the return address, addressee, and postal information found on the article.
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Isolate the article so it won’t be handled again.
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Instruct those who had contact with it to wash their hands with soap and water for at least three minutes and rinse for at least one minute.
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Shut off the ventilation system to the area where the suspicious mailing is.
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Shut off the photocopying machine and other equipment containing fans in the area where the suspicious mailing is.
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Contact the sender and addressee to determine the contents.
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If unsuccessful and the article still seems suspicious, evacuate the area and contact the police.
OTHER EMERGENCY SITUATIONS
Click on each of the following for specific information about how to prepare, respond and recover from the following emergency situations:
REFERENCES/RESOURCES
DOCUMENTS/LINKS
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Disaster Recovery
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Earthquake Preparedness & Response
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Fire Safety
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29 CFR 1910.38 and 29 CFR 1910.39 Fire Prevention Plan Requirements
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Evacuation
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Fire Safety
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Supervisor Safety Tip - Flammable Liquid Storage
eLEARNING
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Fire Safety
SUPERVISOR & SAFETY LEADER DEEPER DIVES
GLOSSARY
Balcony, Exterior Exit
STF, Emergency Response
A landing or porch projecting from the wall of a building, and which serves as a required means of egress. The long side shall be at least 50 percent open, and the open area above the guardrail shall be so distributed as to prevent the accumulation of smoke or toxic gases.
Stair Railing
STF, Emergency Response
A vertical barrier constructed along the open side or sides of stairways and as intermediate stair rails where required on wide stairways.
Grade (Adjacent Ground Elevation)
STF, Emergency Response
The lowest point of elevation of the finished surface of the ground, paving or sidewalk, within the area between the building and the property line, or when the property line is more than 5 feet from the building, between the building and a line 5 feet from the building.
Doors
STF, Emergency Response
(A) Automatic-Closing Doors are those which are normally open but will close at the time of fire. A door may be made automatic closing by the installation of a closing device and a separate, labeled, fail-safe door-holder/release device or a hold-open mechanism which may be an integral part of the basic closing device, provided the hold-open mechanism is released by one or a combination of automatic fire detectors acceptable to the authority having jurisdiction.
(B) Power-Operated Fire Doors are those which are normally opened and closed by power. They shall be equipped with a releasing device which will automatically disconnect the power operator at the time of fire, allowing a self-closing or automatic device to close the door irrespective of power failure or manual operation.
(C) Self-Closing Doors are those which, when opened, return to the closed position. The door shall swing easily and freely and shall be equipped with a closing device to cause the door to close and latch each time it is opened. The closing mechanism shall not have a hold-open feature.
Compressed Gas
HazCom, Fire, Emergency Response
1) (a) A gas or mixture of gases having a pressure exceeding 40 psia at 70F in a container, or (b) A gas or mixture of gases having a pressure exceeding 104 psia in a container at 130F, regardless of the pressure at 70F, or (c) A liquid or mixture of liquids having a vapor pressure exceeding 40 psia at 100F as determined by UFC Standard No. 9-5.2) See Gases under pressure
Explosive
Chemical Hygiene, Fire, HazCom, Emergency Response
1) A substance that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature
2) A solid or liquid chemical which, by itself, can chemically react to produce gases at such a temperature and pressure and at such a speed as to cause damage to the surroundings. Pyrotechnic chemicals are included even when they do not evolve gases..
Water-reactive
HazCom, Chemical Hygiene, Fire, Emergency Response
1) A substance that reacts with water to release a gas that is either flammable or presents a health hazard.
2) Solid or liquid chemicals which, when exposed to water, can become spontaneously flammable or give off flammable gases in dangerous quantities. These chemicals are divided into three categories (1, 2, and 3) based on the strength of their reaction with water, with Category 1 being the most reactive.
Pyrophoric
HazCom, Chemical Hygiene, Fire, Emergency Response
1) A substance that will ignite spontaneously in air at a temperature of 1300 F (54.40 C) or below.2) A) Pyrophoric gases are gases that will ignite spontaneously in air at a temperature of 130 F (54.4 C) or below. B) Pyrophoric solids and liquids are chemicals which, even in small quantities, are liable to ignite within five minutes after coming into contact with air.
Oxidizer
Chemical Hygiene, Hazcom, Fire, Emergency Response
1) A) Oxidizing gases are gases which may cause or contribute to the combustion of other material more than air does, generally by providing oxygen. B) Oxidizing solids and liquids are substances which, while not necessarily combustible themselves, may cause or contribute to the combustion of other material, generally by yielding oxygen. Note: Oxidizing solids and liquids are each divided into three hazard categories (1, 2, and 3) based on their ability to accelerate combustion, with Category 1 being the strongest oxidizer.
2) A substance, other than a blasting agent or explosive, that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
Panic Hardware
STF, Emergency Response, IIPP
A bar which extends not less than one-half the width of each door leaf, not less than 30 nor more than 44 inches above the floor, which will unlatch the door when a force to the bar not to exceed 15 pounds is applied in the direction of exit travel.