Dear Sir or Madam:

I am a student in the doctoral program of Traditional Oriental Medicine and a Licensed Acupuncturist in the state of California.

The proposal to dry needle by a Physical Therapist with mere 54 hours of training is a complete misunderstanding and disrespect for the Traditional Oriental Medicine (TOM).  In the State of California, the mere beginning practitioner has a minimum of 2200 hours of classroom hours as well as 970 clinical hours of training to qualify to sit for the licensiing exam.

Allowing a PT to needle a patient from a very limited unilateral physical point of view will open a too wide a door to misrepresent the TOM.

I urge you to refrain from supporting this proposal as the negative consequences will far out weigh the benefits.

Thank you for your kind consideration.

Shaun Borsntein, L.Ac.