FORMAL REBUTTAL: INVESTIGATIVE
FAILURE & PROCEDURAL DEFICIENCY

To: WorkSafeBC Claims Adjudication (Claim #42647461)
From: Mark Holand

Subject: Rebuttal of Worksafe Investigation Report (Pages 22—30 of Employer PDF)

I. REBUTTAL OF INVESTIGATIVE FINDINGS

The WorkSafeBC investigation summary is procedurally deficient. It relies on a "Selective
Investigation" model that ignores the worker’s primary technical evidence, fails to address
the specific mechanism of injury (TTTS), and accepts measurements from an improperly

assembled environment as a valid baseline.

ll. THE "IMPROPER ASSEMBLY" VOID

The investigator concluded there was "no evidence of hazardous noise" based on the
Arcose survey. However, the survey was conducted on equipment that was not in its
engineered operating configuration.

e The Evidence: My photos from January 29 (Exhibits A & B) and the employer’s
own audit photos (Exhibit C) confirm the server rack was operated with side panels
removed.

e The Failure: Operating high-output server equipment without its engineered acoustic
housing is a violation of manufacturer specifications. This "improper assembly"
fundamentally alters the resonant frequency and air-velocity noise of the unit.

e The Impact: By testing a disassembled machine, the investigator measured a
"broken" environment.