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Records: 897 EMPLOYER 1 WORKSAFE 5 LEGAL 8 INTERNAL 852 PERSONAL 31 ⭐ Key: 26 | Last import: 2026-05-11 10:20
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HOLAND_CLAIM_FILE_p027
πŸ“„ HOLAND_CLAIM_FILE | p.27
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3/22/26, 11:51 PM Gmail - FORMAL REBUTTAL OF WORKSAFEBC CLINICAL OPINION Flora Pang M.Sc., RAUD, Aud(C) β€” Audiologist Advisor O...

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 β€” the ENT consulted January 30, 2026 β€” 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 β€” 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 β€” bilateral ear pain worse in the left ear, tinnitus, hyperacusis, headache, 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 β€” 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 β€” 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 iis 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 β€” 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.

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