"Dry Needling" is an invasive procedure using Acupuncture Needles that has associated medical risks. Physical therapy practitioners have claimed more than thousand hours training of Anatomy and other biomedical knowledge. However, there is no training courses providing invasive procedure or needling technique under PT educaiton system. Inadequate training of health care professionals is a threat to public health safety. All the intensive training and practice under-supervision before practice independently is necessary to provide safe treatment to the public. This is the top priority and common concern of Health care professionals including Medical Doctors, Dentists, Nurse Practitioners, Acupuncturists et al.

Clearly, equaling the training of licensed Acupuncturists (more than 1000 hours of Acupuncture theory and practice) with what is being proposed by the Board of Physical Therapy ( No training requirment for physical therapists to practice “dry needling” independently), will expose the public to a huge risk of unsafe procedure and/or injury.

The needles which are used in the practice of so-called "dry needling" by physical therapists are exactly the same as the needles used in the practice of Acupuncturists for thousands of years. And there is no difference of the invasive needling prcedure between "Dry Needling" and Acupuncture. Regulating the same procedure under different regulations and legislations in Virginia is not acceptable with the potential public health safety concern. I strongly oppose the Regulatory Action of "Dry Needling" practice by physical therapiests without adequate training and qualification.

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