The following are highlights of reasons to say NO to the draft of regulation:

It violate FDA regulation regarding classified acupuncture and acupuncture practice. PT therapists and anyone who are not licensed by law to practice acupuncture cannot legally purchase acupuncture needles for medical usage.

A creator of regulation misunderstood practice of acupuncture and PT practice. They employ different views of therapy and totally different therapy technique. PT therapists are not receiving adequate acupuncture education and training during school period and are not licensed by law to practice acupuncture.

There are real risks associated with the use of needles by PT therapists who lack the education and supervised clinical training of licensed acupuncturists. The real risk could introduce serious public health problem, like blood vessel, nerve injury from inappropriate needle angle and depth of insertion.

Ann Sun L.Ac  D.O.M.