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3/22/26, 11:51 PM Gmail - FORMAL REBUTTAL OF WORKSAFEBC CLINICAL OPINION Flora Pang M.Sc., RAUD, Aud(C) — Audiologist Advisor O...
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FORMAL REBUTTAL OF WORKSAFEBC CLINICAL OPINION Flora Pang M.Sc., RAUD, Aud(C) — Audiologist
Advisor Opinion Date: March 20, 2026 WorkSafeBC Claim #42647461 — Mark Holand Submitted: March 20,
2026
1 message
mark holand <marktholand@gmail.com> Fri, Mar 20, 2026 at 4:36 PM
To: "Cassady, Jaylin" <Jaylin.Cassady@worksafebc.com>, Ariane.Janson@worksafebc.com, "Ficzycz, Pierce" <pierce.ficzycz@worksafebc.com>,
flora.pang@worksafebc.com
FORMAL REBUTTAL OF WORKSAFEBC CLINICAL OPINION Flora Pang M.Sc., RAUD, Aud(C) —
Audiologist Advisor Opinion Date: March 20, 2026 WorkSafeBC Claim #42647461 — Mark Holand
Submitted: March 20, 2026
PURPOSE
This document constitutes a formal rebuttal of the Clinical Opinion dated March 20, 2026, prepared by Flora
Pang M.Sc., RAUD, Aud(C), Audiologist Advisor, WorkSafeBC, in relation to claim #42647461.
The clinical opinion contains fourteen identified errors of fact, methodology, clinical reasoning, and procedural
fairness that individually and collectively invalidate its conclusions. Each error is documented below with
reference to the source material on file.
This rebuttal is submitted for immediate inclusion in my claim file and in support of my formal appeal of the denial
decision communicated March 20, 2026.
ERROR 1 — MISIDENTIFICATION OF THE ACOUSTIC SOURCE
The clinical opinion describes the mechanism of injury throughout as exposure to computer fans.
This is factually incorrect.
The acoustic source at Workstation 3, OMC1, 6800 14th Ave, Burnaby was two floor-mounted industrial server
racks. This is confirmed by every document on this claim file:
My Acoustic Trauma Brief filed with WorkSafeBC January 29, 2026 describes two large floor-mounted servers
behind Workstation 3 and includes photographs taken the same day.
The BCRTC internal investigation report prepared by Jason Mayo CRSP, dated March 12, 2026 states the room
contains a server rack which produces some noise. This is the employer's own document confirming the source
was a server rack.
The Arcose Consulting Ltd. noise survey dated March 11, 2026, commissioned by BCRTC, states in its
Observations section: two server racks are located at the southeast corner of the room, approximately 1 meter
from the nearest computer simulation desk. Arcose itself identified the source as server racks not computer fans.
The WorkSafeBC Prevention Services Inspection Report #202618842990A dated February 25, 2026 states the
employer representative stated the room contains a server rack which produces some noise.
Every document on this claim file identifies the acoustic source as server racks. Not computer fans. The clinical
opinion is the only document in this entire file that describes the source as computer fans.
This misidentification is not semantic. Industrial server racks and computer fans are categorically different
acoustic sources with fundamentally different acoustic profiles, frequency characteristics, resonance properties,
and physiological effects. Every comparison made in this clinical opinion — to BC Ferry data centers, hospital
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