To whom it may concern,

Acupuncturists must meet almost 3000 combined hours of didactic and supervised clinical training and pass up to 4 national board exams to be granted licensure for the safe practice of acupuncture.  Physical therapists and other practitioners claim that dry needling is not acupuncture while using filiform acupuncture needles in known acupuncture points or "ashi"/trigger points.  These techniques have been clearly demonstrated as techniques within the body of traditional Chinese medicine for anywhere between 3000-5000 years or longer.  Repurposing these techniques under a different title to avoid the regulation of acupuncture licensure poses a significant threat to public safety.  While there are currently no national standards or recommendations as to the minimum number of hours suggested to meet needle manipulation and safety competencies many leaders in the field suggest that 600 hours of combined didactic and supervised clinical training would serve as the baseline to ensure safe needle practices including safe practices that would prevent incorrect placement or manipulation leading to catastrophic events such as pneumothorax or the puncture of other organs, nerve or tissue damage and internal bleeding.  Please protect the public from minimally trained practitioners attempting to insert filiform needles into patients who would not even know how to evaluate a practitioners credentials in this arena.  Require proof of competency for needle safety or do not allow any practitioner to practice on an unaware public.  Dry needling by untrained practitioners is dangerous.

Thank you for your time and consideration.

Regards,

Joshua Saul LAc.