Physical therapists are using acupuncture needles as a tool to treat patients. Acupunture needles are regulated by the FDA as a class 2 medical device, and should be used by practioners who have a sufficient amount of accredited training to practice safely on patints. Dry needling is within the scope of practice of Acupuncture which is regualated by law in 45 states. Dry needling should be regulated under Acupuncture law. Seperate regulation of dry needling will only benefit physical therapists to get chance to use acupuncture with insufficient training and may mislead consumers.