Although Fermentis is comfortable with direct pitching, they recommend a specific procedure. From
https://fermentis.com/wp-content/uploads/2019/10/Brochure_Tips_and_Tricks_BAT_BD.pdf:
"If the brewery is not equipped with a system designed for the rehydration step,
we highly recommend a direct pitch.
To do so we recommend using the necessary quantity in weight of ADY and to
put it into the fermentation vessel during the first part of the wort cooling step.
The temperature of cooling will be the same as the temperature used to start
fermentation. There is no need for aeration during this process.
Step 1
Start to fill your fermenter with hopped wort until the cone is filled
Step 2
Sprinkle dry yeast directly in the hopped wort
Step 3
Finish to fill the fermenter"
I also emailed Fermentis about dry pitching and was advised not to pitch on foam: "Sprinkling the yeast on the foam will leave some yeast outside of the liquid which is no good."
By the way, this is a great discussion. Thanks to all who commented.