I disagree.

As a safety person, I definitely use words like implied and assume, when they fit. Let me provide some definitions, so at least we may share a common frame of lexical reference going forward.

• Permit (n) - an official document giving someone authorization to do something.
• Implied (adj) - suggested but not directly expressed; implicit.
• Assume (v) - suppose to be the case, without proof.

In higher education, there are seldom official documents giving someone authorization to do something, documents that fit the mold of an "operating permit." When faculty have been assigned space for research, it is suggested but not directly expressed that they will do so in accordance with the institution's policies and procedures. Other safety people may have other words for that - I use "implied."

Safety people assume things all the time - we could not live in a world where we do not make assumptions. Fire sprinkler systems save lives, when they are allowed to operate as designed. We are obliged, under code, to visually inspect the isolation valves monthly, or weekly if they are not supervised. It takes a few minutes to isolate a fire sprinkler system at such a valve, which would impair the system's ability to function in case of fire, with a much increase likelihood of death or serious physical injury to the occupants of the portion of the building that impaired sprinkler system would otherwise have protected. However, fire code allows owners to inspect a valve on the first day of a month and the last day of the subsequent month - as much as 25,000 times the duration of the activity that causes an impairment, and still assert the inspection program complies with code. We do not have proof that such valves are still open in the intervening time, yet code allows us to suppose this is the case. The other examples where this is the case are legion - when was the last time any of us used a four-gas meter in supplied air to simply gain entry to our offices? Other safety people may have other words for that - I use "assume."

I categorically reject the appeal to pity and the attempt to disprove the rule by pointing to the exception. There have been literally millions of staff hours in higher education laboratories, under no "operating permits" if my view is valid, since 2008 where no-one has died, where no-one has ben seriously injured, and where no environmental contamination has occurred. It is simply not the case that mayhem, death, serious physical injury, and environmental degradation necessarily attend teaching and research laboratories in higher education when a system of "operating permits" is not in place. The presence or absence of the "operating permit" does not make the lab safe.

I look forward to reading a re-written post that describes the reality of the pursuit of science, teaching, and discovery in a higher education context, and does not rely on implication or assumption. Have at it, sir.

John

John DeLaHunt, MBA, ARM

Risk and Life Safety Manager

Treasurer, CSHEMA - EHS Leadership in Higher Education

The University of Texas at San Antonio

Office of Risk and Emergency Management

One UTSA Circle

Central Receiving Warehouse 1.01.12D

CRW 1.01.12D/MC05500

San Antonio, TX 78249-3209

(210) 458-4420 voice

(210) 458-7450 fax

john.delahunt**At_Symbol_Here**utsa.edu