THEME CAMP FLAME EFFECTS POLICY

Engulf permits theme camps to bring fire art and devices that create fire under certain restrictions. We distinguish between two types of flame art – Sustained Flame Art and Poofers/Dynamic Flame Effects. While the requirements for each are the same (except for Section 9, which has an additional provision for Poofers/Dynamic Flame Effects), there are distinctions between the two types of flame art.

“Sustained Flame Art” means an artistic installation that produces a substantially continuous or steady open flame or flame effect, rather than intermittent bursts or discharges of flame. Examples include propane-fueled flame sculptures, rings of fire, and similar installations.

Sustained Flame Art may vary naturally in flame height or intensity and may incorporate controls permitting an authorized operator to adjust or extinguish the flame. An installation is not considered a “Poofer” or “Dynamic Flame Effect” merely because its flame fluctuates or its output can be adjusted.

A “Poofer” or “Dynamic Flame Effect” means a flame effect designed to produce intermittent bursts or discharges of flame, including effects using an accumulator or other means of accumulating or rapidly releasing fuel.

The following rules apply to both Sustained Flame Art and to Poofers/Dynamic Flame Effects (collectively, “Flame Effects”).

1. Purpose and Scope

Engulf encourages creative use of fire while requiring that propane flame effects be designed, installed, and operated in a manner that reasonably protects participants, operators, property, and the surrounding environment. This Policy applies to Flame Effects as defined above. Note that this policy does NOT apply to fire performances, fire artists (e.g., Conclave), or other performance-based manipulation of fire, which are governed by Engulf’s separate fire-performance requirements, or to the Effigy and Temple burns and other approved burnable art, each of which also have separate Engulf rules. Further, this policy does NOT apply to ordinary camp cooking appliances used for their intended purpose, which are also governed by separate Engulf rules. Burn barrels are not governed or authorized by this policy. Engulf may separately permit or prohibit burn barrels and establish conditions for their use. Finally, note that Engulf does NOT permit mobile Flame Effects. Flame Effects may not be installed or operated on art cars/mutant vehicles, motor vehicles, trailers, bicycles, wagons, or other mobile platforms, and may not be carried or worn while burning.

Compliance with this Policy does not constitute certification of compliance with any law, code, or industry standard. All Flame Effects remain subject to applicable law and any requirements imposed by the property owner, insurer, fire marshal, fire department, or other authority having jurisdiction (“AHJ”). Where those requirements are more restrictive than this Policy, the more restrictive requirement controls.

2. Applicable Standards

Flame Effects must be designed, constructed, installed, and operated consistently with applicable requirements of NFPA 58, Liquefied Petroleum Gas Code, NFPA 160, Standard for the Use of Flame Effects Before an Audience, applicable Louisiana fire- safety requirements, and other requirements of the AHJ.

Engulf may impose safety requirements more restrictive than applicable codes or standards where reasonably appropriate for the event site or conditions.

Unless specifically approved in advance by the Engulf Fire Department (“FIRE”), all Flame Effects governed by this Policy must use propane/LP-Gas as their fuel source.

Flame Effects using liquid fuels, solid fuels, natural gas, or other fuels require specific advance review and approval and may be subject to additional requirements.

3. Advance Registration and Approval

No Flame Effect may be brought into operation at Engulf unless it has been registered with and approved by (“FIRE”).

The responsible artist or operator must provide, upon request:

• a description or photograph of the Flame Effect;

• the intended flame height and direction;

• a description of how the effect is activated;

• the type and quantity of fuel used;

• the maximum operating pressure;

• identification and ratings of any accumulator or pressure vessel;

• a diagram or description of the fuel system, including cylinders, regulators, accumulators, valves, hoses, effect head, and emergency shutoff;

• the proposed location of the effect;

• proposed participant and combustible-material clearances;

• the location of propane cylinders and fire extinguishers; and

• the names of authorized operators.

Material changes to an approved Flame Effect must be disclosed to FIRE and may require reinspection.

4. Onsite Inspection

Every Flame Effect must pass an onsite inspection by FIRE before it is operated or ignited at the Event. Fuel may be connected before approval solely as necessary for assembly, leak testing, and FIRE inspection and test-fire process.

Inspection may include examination of cylinders, accumulators, regulators, hoses, valves, fittings, effect heads, ignition systems, securing methods, emergency shutoffs, extinguishers, placement, clearances, and operating procedures.

Leak testing must be performed using an appropriate leak-detection solution or other method approved for LP-Gas systems. “I don’t smell propane” alone does not qualify as an appropriate test. A flame may never be used to test for leaks.

FIRE may require a controlled test firing as part of the inspection.

Approval applies only to the configuration and location inspected. Moving an effect, materially changing its fuel system, or altering its operating characteristics may require reinspection.

FIRE approval may be withdrawn at any time if the effect malfunctions, conditions change, or operation is deemed unsafe.

5. Fuel Cylinders and Pressure Vessels

LP-Gas cylinders must:

• be approved for LP-Gas service;

• have a current required certification or qualification;

• be free from material rust, damage, leakage, or other unsafe condition;

• remain upright unless specifically designed for another orientation;

• be secured against tipping or movement;

• be stored in a safe and approved location;

• have valve guards or protective features intact where applicable; and

• be protected from vehicle traffic and other foreseeable physical damage.

Accumulators, surge tanks, and other pressure vessels must be manufactured, rated, and maintained for the pressures to which they will be exposed.

Improvised pressure vessels are prohibited.

A pressure vessel may not be welded, drilled, altered, or repaired except in a manner permitted by the applicable pressure-vessel standard and performed by appropriately qualified personnel.

Where supply pressure can exceed the maximum allowable working pressure of an accumulator or other component, suitable pressure regulation and overpressure protection must be provided.

6. Fuel Lines, Valves, Fittings, and Regulators

All hoses, pipe, tubing, regulators, valves, fittings, connectors, and related components must be:

• designed for LP-Gas service;

• rated for the maximum pressure reasonably possible at that location in the system; and

• maintained in good condition.

Air hose, pneumatic tubing, PVC, vinyl tubing, and other components not rated for LP- Gas service are prohibited.

Hose clamps are prohibited on LP-Gas fuel lines. Hose connections must use properly manufactured or crimped fittings designed for the hose and service involved.

Metallic LP-Gas piping and fittings operating above 125 psi must be Schedule 80 or otherwise specifically rated for the pressure and LP-Gas service.

Fuel lines must be routed or protected to reduce tripping, crushing, abrasion, heat exposure, and accidental disconnection.

Safety devices, regulators, pressure-relief devices, and emergency shutoffs may not be disabled, bypassed, blocked, or modified in a manner inconsistent with their intended function.

7. Emergency Fuel Shutoff

Every Flame Effect must have a clearly identified and readily accessible primary emergency fuel shutoff.

The emergency shutoff must be capable of stopping fuel flow to the entire Flame Effect regardless of the number of cylinders supplying the effect.

A quarter-turn valve, emergency stop control, or equivalent FIRE-approved system must permit rapid shutdown without requiring an operator to approach the flame head.

The emergency shutoff must remain accessible while the effect is operating and must be known to all authorized operators.

FIRE may require additional isolation valves at cylinders, accumulators, pilots, or effect heads depending upon the design.

8. Installation and Securing

A stationary Flame Effect must be securely mounted or otherwise protected against tipping, unintended movement, or change in flame direction. If necessary, FIRE may require the Flame Effect to be secured to the ground by cables.

Fuel cylinders, accumulators, hoses, and controls must be positioned so that participants cannot reasonably tamper with, trip over, damage, or inadvertently operate them.

9. Flame Direction and Clearances

A minimum clearance of 20 feet must be maintained between the flame-discharge and heat-affected area of a Flame Effect and combustible and flammable materials, including tents, fabric structures, stored fuel, dry vegetation, and other combustible materials.

No tree limb, foliage, fabric, electrical line, structure, or other combustible material may overhang the approved flame-discharge and heat-affected area.

Twenty feet is a minimum, not an automatic safe operating distance. FIRE may require greater horizontal or vertical clearance based upon:

• expected flame height and width;

• duration and frequency of discharge;

• operating pressure;

• orientation of the effect;

• radiant heat;

• wind;

• dryness of vegetation;

• surrounding tree canopy;

• participant density; and

• other site conditions.

The operator must demonstrate the effect sufficiently during inspection for FIRE to establish an appropriate operating perimeter.

Specific to Poofers/Dynamic Flame Effects, Poofers must discharge substantially vertically unless another orientation has been specifically approved by FIRE.

No Poofer may be directed toward participants, camps, tents, vehicles, structures, trees, vegetation, fuel storage, or another foreseeable combustible hazard.

10. Participant Safety Perimeter

FIRE shall establish or approve an audience safety perimeter appropriate for each effect.

The participant perimeter may be greater than the combustible-material clearance.

The operator is responsible for maintaining the approved perimeter whenever the effect is capable of operation.

Where participant movement or crowd conditions make the approved perimeter impossible to maintain, operation must cease.

11. Propane Storage

Spare propane cylinders must be stored:

• upright and secured;

• in a ventilated location;

• protected from vehicle impact and participant interference;

• away from ignition sources, operating Flame Effects, tents, and combustible structures; and

• in accordance with Engulf’s general fuel-storage rules.

Unless FIRE approves otherwise based upon the installation, spare propane storage must be located at least 25 feet from an operating Poofer or other open flame.

Smoking and open flame are absolutely prohibited in propane storage areas.

Only cylinders connected as part of the approved operating system should be located within the Flame Effect installation.

12. Fire Extinguishers

Every Flame Effect must have at least one readily accessible minimum 5-pound BC or ABC dry-chemical fire extinguisher appropriate for an LP-Gas fire.

The extinguisher should be positioned so that an operator can readily reach the extinguisher and shutoff without passing through the likely flame or fire path.

FIRE may require additional or larger extinguishers based upon the size and configuration of the effect.

All operators must know the location and proper use of the extinguishers.

13. Authorized Operators

A Flame Effect may be operated only by an individual:

• at least 21 years of age;

• identified to FIRE as an authorized operator;

• familiar with the effect and its normal and emergency operation;

• familiar with the location and operation of the emergency fuel shutoff;

• capable of using the required fire extinguisher; and

• sober and unimpaired.

Operators may not consume alcohol or impairing substances while operating or acting as the responsible safety operator for a Flame Effect.

No participant may be invited or permitted to activate a Flame Effect unless that participant is an authorized operator.

14. Attendance and Control

A Flame Effect may never be left operating or capable of participant activation without an authorized operator in direct attendance.

The responsible operator must maintain sufficient control over the effect to stop operation immediately if an unsafe condition develops.

Controls must be protected against accidental or unauthorized activation.

When the authorized operator leaves the installation or the effect is not in approved operating hours, the system must be placed in a condition that prevents unauthorized operation.

15. Inspection Before Operation

Before the first operation of each day or operating period, the operator must inspect the Flame Effect, including as applicable:

• cylinders;

• hoses and fuel lines;

• fittings and connections;

• regulators;

• valves;

• accumulators and pressure vessels;

• effect heads;

• ignition or pilot systems;

• emergency shutoff;

• mounting and securing systems;

• fire extinguishers; and

• the surrounding operating area.

The system must be checked for propane leakage after initial assembly and whenever a cylinder, hose, fitting, regulator, or other fuel-system connection has been changed or disturbed.

A Flame Effect with a suspected leak, damaged component, malfunction, or other unsafe condition may not be operated until the condition has been corrected.

16. Operating Conditions and Weather

The operator must continuously observe environmental and site conditions.

Operation must cease whenever wind, drought, vegetation conditions, participant behavior, equipment malfunction, loss of safety perimeter, or any other circumstance makes continued operation unsafe.

FIRE, Rangers, Engulf Leadership, or designated safety personnel may order immediate shutdown of any Flame Effect.

Engulf may prohibit or restrict Flame Effects because of burn bans, fire-weather conditions, requests or orders of public authorities, insurance requirements, or conditions at the Event site.

An effect approved earlier in the Event does not have a right to continue operating when conditions change.

17. Emergency Procedures

If an uncontrolled flame, fuel leak, equipment failure, unintended discharge, fire outside the intended effect, or other hazardous condition occurs:

1. Stop activation of the effect.

2. Shut off the propane supply using the emergency shutoff if it can be done safely.

3. Keep participants away from the affected area.

4. Use appropriate extinguishing equipment if safe to do so.

5. Immediately notify FIRE, Rangers, or other Event emergency personnel.

6. Do not resume operation until the cause has been identified, corrected, and the

effect has been re-approved by FIRE.

Where propane is escaping without ignition, operators should prioritize shutting off the fuel source and keeping ignition sources and participants away from the area rather than attempting to operate electrical or other equipment that could create an ignition source.

18. Authority of Engulf Safety Personnel

FIRE, Rangers, Engulf Leadership, and other personnel designated by Engulf may order a Flame Effect shut down, depressurized, disconnected, relocated, modified, or removed from service whenever they reasonably believe that continued operation presents an unacceptable risk.

The decision to suspend operation may be made immediately and does not require proof that the Flame Effect violates a particular provision of this Policy.

An operator who refuses to comply with a safety shutdown instruction may lose authorization to operate Flame Effects for the remainder of the Event.

19. Operator Responsibility

Approval or inspection by Engulf does not transfer responsibility for the Flame Effect to Engulf or its volunteers.

The artist and authorized operators remain responsible for the safe condition, installation, maintenance, and operation of their equipment and for complying with applicable laws, codes, permits, manufacturer requirements, and directions of the AHJ.