I am writing to express my concerns about physical therapists performing a technique called "Dry Needling" with the use of acupuncture needles.  How will the consumers be assured that they will receive effective medical care from competently trained practitioners, when the training required for non-acupuncturists to legally use acupuncture needles is only 54 hours.   Licensed acupuncturists have over 3000 hours of closely supervised medical training, guaranteed by detailed medical testing, in order to demonstrate competence to legally provide medical treatment with the use of acupuncture needles.  The work of a licensed acupuncturist has it's foundation in Chinese medical theory.  Acupuncturists are trained to know the location and function of channel pathways.  After making a clear diagnosis of the affected channel pathways, a practitioner can responsibly devise a treatment protocol.  Physical therapists and other non-acupuncturists are concerned only with needling sites of pain, not the consideration of channel theory, nor the evaluation of a patient's symptoms, and will not be able to base their treatment in clear diagnosis.  A safe, effective treatment requires so much more skill and supervised practice. It involves so much more than needling basic trigger points.  A few days ago, two chiropractors told me they plan to start offering dry needling at their office, figured it's an easy treatment, based solely on palpation, and needling of tight or painful tissue.  They aren't intersted in the hours of detailed training Chinese Medicine practors receive and don't believe dry needling requires any medical or analytical skills that informs treatment strategies.  "Just poke a needle in a swollen leg or ankle," one of the chiropractors told me.  They are convinced that 2 or 3 weekends of training is more than enough to practice dry needling.  But they also asked me if I know an acupuncturist who would be willing to teach them the "ins and outs" of dry needling, how to locate points, and how to handle an acupuncture needle.  I asked them how they would feel if an acupuncturist decided to perform spinal adjustments after 54 hours of quick weekend classes.  They replied emphatically.  "There's no way our patients will be adjusted by an inexperienced practitioner."   They admitted that they were beginning to understand why it might be a better idea to have an acupuncturist on staff to treat their patients.   I appreciate your fair, balanced, logical consideration of the public's concerns.  Thank you.