MEDICAL EVIDENCE REBUTTAL

Response to the WorkSafeBC Clinical Opinion of March 20, 2026
WarkSafeBC Claim #4264746 1 — Mark Holand

Clinical Opinion under review: Flora Pang, M.Sc., RAUD, Aud(C), A udiologist Advisor, dated 2026-03-20 (Form
6SBS86)

Prepared for submission to the WorkSafeBC Review Division

1. Executive Summary

-_-—.
The Clinical Opinion authored by Flora Pang, Audiologist Advisor, on March 20, 2026 concludes that “the main
driving factors of the worker's complaints are likely his pre-existing and non-occupational conditions of migraines and
noise sensitivity, rather than the incident itself.” That conclusion is the sole basis.on which the ear-injury component of
this.claim remains unaccepted.

Specialist medical evidence obtained since March 20, 2026 — from an otolaryngologist, a neurology and pain
specialist, an independent audiology clinic, and the worker's own prescription claims history — directly contradicts
each factual basis on which that conclusion rests. In summary:

e Managed baseline, disrupted by exposure: the worker's migraine condition was under active, documented
management before January 2026 and was destabilized, not revealed, by the workplace exposure.

¢ Wrong mechanism-of-injury framework: the Opinion tested the claim only against “acoustic trauma” and
“acoustic shock,” two mechanisms specialists agree do not apply, while never assessing the autonomic and
muscular tension mechanism the worker's own treating specialists identified.

¢ Ignored objective audiological findings: independent testing found a 20-30 dB asymmetry and confirmed
hyperacusis, neither of which is addressed in the Opinion.

e Selective use of its own central exhibit: the Opinion quotes the January 30, 2026 ER record's note that the
noisy environment likely triggered the worker's migraine, then uses that same trigger as a reason to deny the
claim rather than apply it.

© No engagement with the medication timeline: a seventeen-month, two-medication prescription record
changed materially within days of the exposure and has not returned to baseline; the Opinion docs not mention
it.

e Mischaracterized sensory profile and sequelae: the worker's sensory sensitivity is treated as purely
pre-existing without addressing why it made this specific exposure clinically significant, and post-injury
psychological symptoms are folded into the “pre-existing” picture despite emerging only after the exposure.

None of these gaps would be dispositive alone. Together, they show a Clinical Opinion that reached its conclusion
without engaging the evidence available to it, and that the worker's subsequent specialist evidence directly rebuts. This
document sets out that rebuttal, source by source, for the Review Division.

2. The Clinical Opinion Under Review
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The Opinion was requested by Sr. Adjudicator Jaylin Cassady on March 5, 2026, on the question of “biological
plausibility" — specifically, “what is the nature of the worker's complaints?” and “is the reported condition above
refated to or consistent with the incident?” Ms. Pang answered both questions on March 20, 2026, evaluating the claim
exclusively within an audiological framework.

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