I am a licensed acupuncturist and I am writing to object to the proposed "dry needling" regulation in Virginia. I believe the regulations present a serious threat to public health.

I have been practicing acupuncture for over 30 years. I understand that it is not difficult to lean acupuncture, but being a good acupuncturist is difficult. Dry needle, in nature, is acupuncture. It uses same needle and method to treat patient's disease and pain. It is known that patient's pain could be caused by muscle's or tender's problem, but it could also be internal organ disorder. If a practitioner didn't have enough training, he/she would be unable to choose correct points to treat patient's illness or pain. In such case, failing to make right diagnosis will delay the patient's treatment and thus do harm to patient.

Acupuncture is one of the oldest practices of Chinese medicine involving the traditional Chinese philosophy and culture. Allowing physical therapists with only 80-hour study to practice acupuncture is absolutely putting patients in risk. Patient may not be aware of the difference between West and East medicine. However, the practitioner and particularly the policy maker must be aware of this, as they should take responsibility in preventing physical therapist who are incompletely trained in the acupuncture field to treat patient using needle.

No matter how physical therapist converts the regular needle to "dry needle", the nature of acupuncture cannot be changed. I truly hope the government and policy makers can see the nature of this rather than be clouded by the word "dry needle" and put patients in risk.

Thank you very much.