The National Guild of Acupuncture & Oriental Medicine, OPEIU Guild 62, AFL-CIO, www.NGAOM.org, takes the position that the practice of acupuncture by professionals other than those with training equivalent to that of licensed acupuncturists constitutes an unacceptable safety risk to the public. “Dry needling” is acupuncture. The two concepts cannot be conflated. “Dry needling” is the action of inserting an acupuncture needle into a tender or painful point and then appropriately manipulating it for therapeutic purposes.  “Dry needling” is not “manual therapy;” it is acupuncture. It is important to emphasize that “dry needling” is an invasive, acupuncture needle intervention (that is, it is acupuncture, a specialized form of minimally invasive surgery), whereas manual therapy is a noninvasive, hands-on intervention (for example, massage, mobilization/manipulation).  “Dry needling” is not a “technique;” it is acupuncture. The act of inserting an acupuncture needle into the body, under any pretext, or for any purpose whatsoever, is the practice of acupuncture. Physical therapists and other allied health professionals who are not licensed by law to practice acupuncture are using acupuncture needles to perform “dry needling.”

Physical therapists and other allied health professionals who are not licensed by law to practice acupuncture are not qualified to perform “dry needling.”“Dry needling” is outside the scope of practice and beyond the scope of education and training of physical therapists. There are serious public health risks associated with the use of acupuncture needles by physical therapists and other allied health professionals who lack the education and supervised clinical training of licensed acupuncturists. These risks include blood vessel, nerve and organ injury from inappropriate acupuncture needle angle and depth of insertion, inappropriate acupuncture needle manipulation and the risk of infection.