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

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. Flora Pang referenced my photographs and
simultaneously described the source as computer fans. Anyone reviewing the photographs and the clinical
opinion simultaneously will observe this contradiction immediately.

This contradiction exists within the clinical opinion's own cited evidence.

ERROR 11 — MIGRAINE HISTORY MINED AND MISREPRESENTED

The clinical opinion places significant weight on the worker's long history of migraines as evidence that his
condition is pre-existing and non-occupational.

This characterization misrepresents the nature of my migraine management.

Along history of migraines managed through regular medical check-ins every three to four months for
prescription renewal and trigger management does not constitute a debilitating pre-existing condition. | have
been actively working to reduce migraine frequency by identifying and eliminating triggers. My migraines were
successfully managed prior to January 12, 2026.

The critical clinical fact that the clinical opinion does not address is this — my first ever Emergency Room visit for

a migraine was January 30, 2026. Not before. Every prior medical contact regarding migraines was routine
outpatient management. Standard prescription renewal. Trigger discussion. Supplement review.

Aworker who has never required emergency care for migraines in his entire life and then attends the Emergency

Room for the first time on January 30, 2026 — 18 days after beginning exposure at Workstation 3 — is not
presenting a pre-existing condition running its normal course. He is presenting a pre-existing condition that has
been catastrophically destabilized by a new workplace exposure.

That distinction is clinically significant and entirely absent from this opinion.

ERROR 12 — DR. ZAHABI'S OBSERVATION INVERTED

The clinical opinion cites Dr. Zahabi's suspicion that the work environment might have triggered the worker's
migraine headaches and then uses this observation to support a conclusion of non-occupational causation.

This is the direct opposite of what Dr. Zahabi's observation supports.

Dr. Zahabi suspected workplace triggering. That is a medical professional identifying potential occupational
causation. Under WorkSafeBC's aggravation principle a workplace exposure that triggers or aggravates a pre-
existing condition is compensable.

Furthermore Dr. Zahabi's observation was the clinical turning point that led me to understand my condition was
sensory in nature — acoustic stimuli triggering a physiological cascade. His observation was not evidence
against my claim. It was the first medical professional acknowledgment of the mechanism | had been describing
since January 2026.

https://mail.google.com/mail/u/0/?ik=7 1cd554d908&view=pt&search=all&permthid=thread-a:r-7285702432806815945&simpl=msg-a:r47323213862129...

5/7