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

Flora Pang inverted the clinical meaning of Dr. Zahabi's observation to support denial of a claim for the exact
condition Dr. Zahabi suspected.

ERROR 13 — NOISE SENSITIVITY HISTORY MISREPRESENTED
The clinical opinion states the worker noted that he has a history of sensitivity to low level noises.
This is a material misrepresentation of what | reported.

| stated | have high fidelity hearing. | have protected my hearing throughout a 30 year career in heavy industry
precisely because | value it as my most important professional and personal sense. | have worked in genuinely
noisy environments — mainline railway track maintenance, tower rigging in Northern Alberta, heavy equipment
operations — and have consistently worn appropriate hearing protection throughout.

| do not have a pre-existing history of pathological sensitivity to low level noises. | have never been diagnosed
with hyperacusis prior to this injury. | have never avoided normal acoustic environments. | have never reported
noise sensitivity to any physician prior to January 2026.

High fidelity hearing and pathological noise sensitivity are categorically different conditions. One is an asset |
have carefully protected throughout a 30 year career. The other is a condition | did not have before January 12,
2026.

The clinical opinion converted my statement about protecting a valued sensory asset into evidence of a pre-
existing pathological condition. This misrepresentation materially affected the clinical conclusions and constitutes
a factual error of significant consequence.

ERROR 14 — MARCH 5 EMERGENCY ROOM FOOTAGE REVIEW MISCHARACTERIZED

The clinical opinion states regarding the March 5, 2026 ER visit — the physician reviewed footage of the worker
sleeping that he provided and did not see any evidence of tonic clonic movements.

This characterization misrepresents both my clinical presentation and what occurred during that interaction.

| presented sleep footage specifically to demonstrate cyclical nocturnal motor activity consistent with a
physiological feedback loop. The resident's initial response was that everyone moves in their sleep. | specifically
directed the physician to observe the cyclical and repeating pattern of the movements — not random positional
changes characteristic of normal sleep movement but a recurring cycle consistent with an identifiable
physiological source and feedback mechanism.

Tonic clonic movements are the convulsive movements of generalized epileptic seizure. | never claimed to be
having epileptic seizures. | claimed to be experiencing nocturnal motor spasms consistent with tensor tympani
feedback loop activity during sleep — a recognized feature of TTTS.

The clinical opinion characterized this interaction as the physician finding no evidence of tonic clonic movements
— implying | claimed seizures and was clinically disproven. | claimed cyclical nocturnal spasms consistent with
TTTS. That claim was not assessed. It was not addressed. It was reframed as a seizure claim and dismissed on
those grounds.

This is a material misrepresentation of both my clinical presentation and the physician interaction on March 5,
2026.

FORMAL REQUESTS
| am formally requesting that WorkSafeBC:

1. Withdraw the Clinical Opinion dated March 20, 2026 prepared by Flora Pang M.Sc. RAUD Aud(C) on the
grounds that it contains fourteen identified errors of fact, methodology, clinical reasoning, and procedural
fairness that collectively invalidate its conclusions.

2. Commission a replacement clinical opinion that correctly identifies the acoustic source as industrial server
racks, addresses Tonic Tensor Tympani Syndrome as the relevant injury mechanism, evaluates the clinical

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