3/22/26, 11:51 PM Gmail - FORMAL REBUTTAL OF WORKSAFEBC CLINICAL OPINION Flora Pang M.Sc., RAUD, Aud(C) — Audiologist Advisor O...

professionals trained and experienced in noise measurement methodology and accepts the Arcose data without
qualification.

The Arcose Consulting Ltd. noise survey has been formally challenged in my WorkSafeBC Supplementary
Submission dated March 19, 2026, identifying six independent methodological deficiencies. These include:

The survey was conducted March 6, 2026 — 53 days after my injury date and after | had already been absent
from the workplace for five weeks. The acoustic environment was not assessed during the period of my
exposure.

The survey used broadband A-weighted measurement. The TSI SoundPro DL-1 instrument used by Arcose is
capable of 1/3 octave band analysis and speech intelligibility testing. Neither capability was utilized. Broadband
A-weighted averaging mathematically masks frequency-specific energy. A resonance source producing elevated
output at a specific frequency may not be detected by broadband averaging even if that frequency-specific
energy is physiologically significant.

Arcose was not provided with my Acoustic Trauma Brief, my audiogram, my clinical diagnosis, or my
WorkSafeBC claim information when commissioned. This has been formally documented in my January 27
witness statement submitted March 18, 2026. The consultant assessed a standard broadband noise exposure
question rather than a frequency-specific clinical exposure question because the clinical context was withheld
from them by the commissioning party.

The Arcose report was commissioned by Austin Puder, Senior Manager Train Operations — the same manager
who was informed of my ear injury in person on January 27, 2026, with a union representative present, and who
subsequently told me to take it to WorkSafeBC. His knowledge of my injury prior to commissioning Arcose is
documented in my formal witness statement submitted March 18, 2026.

Acclinical opinion that accepts without qualification acoustic data produced under these conditions has not
applied appropriate scientific scrutiny to its evidentiary base.

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.

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The clinical opinion states the noise measurements were collected using appropriate equipment and analyzed by

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