Irwin pointed out that OBEs appear to occur under conditions of either very high or very low arousal. For example, Green found that three quarters of a group of 176 subjects reporting a single OBE were lying down at the time of the experience, and of these 12% considered they had been asleep when it started. By contrast, a substantial minority of her cases occurred under conditions of maximum arousal, such as a rock-climbing fall, a traffic accident, or childbirth. McCreery has suggested that this paradox may be explained by reference to the fact that sleep can supervene as a reaction to extreme stress or hyper-arousal. He proposes that OBEs under both conditions, relaxation and hyper-arousal, represent a form of "waking dream", or the intrusion of Stage 1 sleep processes into waking consciousness.