Dear Board of Physical Therapy, 

I am a licensed acupuncturist and am writing to object to the intent to draft "dry needling" regulations. I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy that has been adopted by the Virginia General Assembly.

I encourage you not to draft regulations because: 

1. 54 hours of training is a completely inadequate level of training to qualify a physical therapist to safely insert acupuncture needles into patients and the regulations therefore are a serious threat to public safety; The training that PT's receive in dry needling does not have enough supervision to be safe to needle the public. There are also no requirements to perform clean needle technique as is required for Acupuncturists to complete in order to take National Exams. OSHA standards are compromised in clean needle technique. You can view U-tube training videos of a teacher training PT's without following clean needle technique. There are other pictures and videos out also that show the use of Acupuncture points drawn on a live model referencing these points in the training of dry needling. This is a misrepresentation of practice since PT's state that dry needling is not Acupunture. You can see ads for dry needling with needles retained and this is not that practice modality. It is done in Acupuncture. So PT's are taking acupuncture pictures to advertise dry needling. This is a sad misrepresentation of dry needling practice. Now patients are coming to the clinic afraid of acupuncture after receiving dry needling.

PT's are not engaged in a holistic and complete approach to patients medical history and some patients it may not be appropriate to needle. For example immune compromised patients or patient with lymphedema.

People who have received Dry Needling complain that it hurts a lot and they do not get relief of pain, in fact some have stated that they nearly passed out during dry needling. That doesn't happen in Acupuncture.

Additionally PT's are using acupuncture needles to perform dry needling. Acupuncture needles are approved by the FDA for use by Acupuncturists doing Acupuncture. That is illegal, in addition to not having the training, supervised practice and experience to put needles in people.

I fully support the complete document by Mark Seems, L.Ac.

I am an Acupuncturist with over 15 years of experience and a 30 year experienced Nurse and can not support in any manner PT's dry needling patients. Please re

2. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and even medical doctors; 

3. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists. 

Thank you for considering my comments. 

Sincerely, 

Rande Lucas, L.Ac.

907-336-6692

alaskaormed@gci.net