WORKING TO MAKE A DIFFERENCE

Memo
(continued)

Worker last name First name Middle initial WorkSafeBC claim number
HOLAND MARK 42647461

ERROR 5 — INVALID ENVIRONMENTAL COMPARISON

The clinical opinion compares my exposure environment to a BC Ferry data center
and a central computer processing area of a large hospital and concludes these
environments produce similar noise levels below hazardous thresholds.

This comparison is not scientifically valid.

BC Ferry data centers and hospital computer processing areas are purpose-built
data environments. They are engineered installations with proper acoustic
enclosures, appropriate ventilation systems, and equipment installed according to
manufacturer specifications and applicable building codes.

The server installation at Workstation 3, OMC1 is currently under active
investigation by the City of Burnaby Building Division. On March 19, 2026, Cecilia
Cheung P.Eng., Assistant Chief Building Inspector, City of Burnaby confirmed that
my complaint regarding unpermitted installation, missing server rack side panels,
open ceiling penetrations, and electrical code violations has been forwarded to the
Building Inspections Supervisor for review and further action.

The installation at OMC1 has not been confirmed compliant with applicable building
codes, electrical codes, or fire codes. A missing server rack side panel —
photographed January 29, 2026 — means the acoustic and thermal containment
engineered into the equipment was absent during the period of my exposure.
Comparing a potentially non-compliant unpermitted installation to purpose-built
engineered data environments is not a valid scientific basis for clinical conclusions
about equivalent acoustic exposure.

ERROR 6 — AGGRAVATION PRINCIPLE MISAPPLIED

The clinical opinion 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.

This conclusion misapplies WorkSafeBC's own aggravation principle.

Under WorkSafeBC policy a workplace injury does not need to be the sole cause of
a condition to be compensable. A workplace exposure that aggravates, accelerates,
or significantly contributes to a pre-existing condition constitutes a compensable
workplace injury.

Furthermore the clinical opinion contains an internal contradiction on this point. It
cites Dr. Zahabi's observation that the work environment might have triggered the
worker's migraine headaches as supporting context. Dr. Zahabi — the ENT
consulted January 30, 2026 — specifically suspected workplace triggering. Flora
Pang used Dr. Zahabi's suspicion of workplace causation as supporting evidence
for a conclusion that the condition is non-occupational.

She cited workplace triggering to deny a claim for workplace triggering.

This is internally contradictory and does not represent sound clinical reasoning.

ERROR 7 — TONIC TENSOR TYMPANI SYNDROME NOT ADDRESSED

Tonic Tensor Tympani Syndrome does not appear anywhere in this clinical opinion.
TTTS is a recognized clinical condition characterized by involuntary tensor tympani
muscle spasm triggered by acoustic stimuli, stress, or autonomic activation. It
produces exactly the symptom profile | have reported consistently since January
2026 — bilateral ear pain worse in the left ear, tinnitus, hyperacusis, headache,

68B33

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