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SUPPLEMENTARY SUBMISSION 05
πŸ“„ HOLAND_CLAIM_FILE_p035 to p065 | p.39
πŸ“ Extracted Text (OCR)
FINDING 5: 53-DAY GAP β€” CONDITIONS AT TIME OF INJURY UNVERIFIED

The Arcose survey was conducted on March 6, 2026 β€” 53 days after my injury began on
January 12, 2026. The employer's own representative confirmed to WorkSafeBC on March 18,
2026 that the room configuration during testing was the same as when | was there. However,
the specific state of the equipment β€” panel on or off, thermal condition, load state, system
configuration β€” was not documented at the time of injury and was not formally verified at the
time of testing. A noise survey conducted 53 days after a reported injury, without documentation
of conditions at the time of injury, cannot serve as a definitive assessment of occupational
exposure.

FINDING 6: SCOPE OF EXPERTISE β€” WRONG ASSESSMENT TOOL FOR THE CLINICAL
INJURY

The Arcose survey was conducted by an EHS consultant holding a Diploma in Occupational
Health and Safety and a Certified Radiation Safety Technologist designation. The final reviewer
holds CIH and CRSP designations with a background in industrial hygiene. The assessment
methodology applied β€” A-weighted broadband measurement, time-weighted average
calculation, comparison to the 85dB occupational exposure limit β€” is the correct and standard
approach for assessing industrial noise-induced hearing loss risk in environments such as
manufacturing facilities, construction sites, and machinery operations.My injury is not industrial
noise-induced hearing loss. It is a neurological middle-ear injury caused by sustained exposure
to narrowband mechanical resonance at a specific dominant frequency of 328Hz. The clinical
mechanism is Tonic Tensor Tympani Syndrome (TTTS) β€” a condition documented in
peer-reviewed otolaryngology and audiology literature, particularly in relation to acoustic shock
from tonal noise sources at sub-industrial levels. TTTS does not require exposure above 85cB.
It requires sustained exposure to a specific tonal stimulus that triggers involuntary middle-ear
muscle spasm, initiating a neurological feedback loop.A-weighted measurements
mathematically attenuate frequencies below 500Hz. The 328Hz resonance | identified is in the
frequency range most aggressively filtered by A-weighting. The assessment tool used by
Arcose was, by mathematical design, least sensitive to the specific frequency responsible for my
injury.The TSI SoundPro DL-1 instrument used by Arcose is capable of 1/3 octave real-time
spectral analysis β€” the mode required to identify discrete tonal components including the
328Hz resonance. This mode was not used. Speech Interference Level testing was also not
used, despite the instrument being capable of it and despite my exact complaint being on
record. The appropriate assessment for this injury would be conducted by or in consultation with
an audiologist, otolaryngologist, or acoustic engineer with specific expertise in tonal noise
hazards, tensor tympani physiology, and neurological acoustic injury. BCRTC commissioned a
standard industrial noise survey to investigate a clinical neurological injury claim β€” without
providing the clinical context that would have changed the scope, the methodology, and the
professional specialty required. That decision was made by BCRTC. The consequences are
reflected in a report that does not address the injury it was commissioned to investigate.

A noise survey that uses A-weighted broadband measurements to assess a narrowband
tonal neurological injury is the acoustic equivalent of testing colour vision with a black
and white chart. The instrument works perfectly. The test is simply not designed for the
condition being assessed.