WORKING TO MAKE A DIFFERENCE

Memo
(continued)

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

sleep disruption, and nocturnal motor spasms.

TTTS is specifically associated with sustained exposure to sub-threshold acoustic
stimuli rather than impulse noise or sudden acoustic events. It does not require
exposure above 85 dBA to develop. It is documented in the clinical literature as
occurring in individuals with noise sensitivity and autonomic nervous system
dysregulation.

Flora Pang assessed acoustic trauma requiring 130 dB SPL and acoustic shock
requiring sudden unexpected sound. She did not assess TTTS. She did not rule it
out. She did not reference it. She rendered a clinical opinion on an auditory injury
claim without addressing the only recognized clinical mechanism consistent with the
reported symptom profile and exposure conditions.

A clinical opinion that does not address the relevant diagnosis is not complete.

ERROR 8 — PROCEDURAL DUE PROCESS VIOLATION

Flora Pang's clinical opinion is dated March 20, 2026. It was requested by Ms.
Jaylin Cassady, Sr. Adjudicator on March 5, 2026.

| received notification of claim denial by telephone on March 20, 2026 — the same
day the clinical opinion was dated.

| was not provided with the clinical opinion prior to the denial decision. | had no
opportunity to review its findings, identify its errors, respond to its conclusions, or
provide additional evidence before it was used as the basis for claim denial.
Procedural fairness requires that a worker have meaningful opportunity to respond
to adverse clinical opinions before they form the basis of claim decisions. | was
denied that opportunity. The clinical opinion and the denial were delivered
simultaneously.

This procedural failure is independent of the substantive errors identified above and
constitutes an additional ground for appeal.

ERROR 9 — OMISSION OF JANUARY 26 SICK DAY

The clinical opinion states the worker began missing time fully in the afternoon of
January 29, 2026.

This is factually incorrect.

January 26, 2026 was my first sick day due to this workplace injury. This was my
first sick day due to a work related injury in 30 years of heavy industry employment.
It is documented in the claim file. The clinical opinion omits this entirely,
compressing the injury timeline in a way that minimizes the severity and progression
of symptoms.

A clinical opinion that misrepresents the injury timeline cannot accurately assess
biological plausibility.

ERROR 10 — PHOTOGRAPH EVIDENCE CONTRADICTS THE REPORT'S OWN
CONCLUSIONS

The clinical opinion references worker photographs stating the worker completed
his own sound analysis and included photos of the desk arrangement.

Those photographs show industrial server racks behind Workstation 3. Not
computer fans.

The very photographs cited as supporting evidence in this clinical opinion directly
contradict its foundational characterization of the acoustic source as computer fans.

68B33

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