MASTER OUTLINE — THREE
SUBMISSION DOCUMENTS

WorkSafeBC Claim #42647461 — Mark Holand A one-page map of what each document
covers, its structure, and where the three overlap.

1. Review Division Submission (1,2 and 3)

The formal appeal filed with WorkSafeBC's Review Division against the March 20/23, 2026
denial.

Requests reversal of Claim #42647461's denial. Argues procedure first, then medical merits,
on the position that both independently justify setting the Clinical Opinion aside.

e Part !— Decision under review; states the order of grounds and why procedure is
addressed first.
e Part Il — Procedural irregularities:
o ILA— 3-day gap between the internally recorded decision (Mar 20) and
worker notification (Mar 23); its effect on the statutory review clock.
o 1L.B— The 1991/4992 benchmark dates present in Pang's draft notes; absent
from the final Opinion and References list.
2 l.C — Timing of BCRTC's Mar 13 adverse employment action relative to the
claim decision; asks whether the employer had advance visibility.
9 II.D — Relief requested on the procedural grounds,
e Part Ill— Occupational and medical evidence:
9 IILA— The OMC1 hazard itself (unpermitted server racks, missing panel,
MyHSE report).
9 I.B— The worker's own 328 Hz acoustic telemetry and glass-reflection
analysis, submitted Feb 6, 2026 and never addressed by the Opinion,
e Part IV — Reliability of the Clinical Opinion on its own terms:
o |IVA— Symptom onset vs. the Jan 30 10 dB threshold shift at 8kHz.
° 1V.B— Why an 8-hour time-weighted average erases a directional resonance

peak. ‘

o V.C—The 17-month stable medication baseline, disrupted within days of
exposure.

0 IV.D — Mischaracterization of sensory profile and post-injury psychological
symptoms.

o I.E — Ongoing treatment and the pending Jul 16 ENT consultation.
e Part V— Four WCAT precedents involving the same
averaging/symmetry/pre-existing-condition pattern.
e Part VI— Summary of relief: fix the limitation clock, investigate employer contact, set
aside the Opinion, accept the claim, or in the alternative refer for an independent
ENT opinion.

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