I am writing to express my concern for the public's health and safety regarding the practice of "Dry Needling".

The use of the term "Dry Needling" by the physical therapy profession is an attempt to set this practice apart from the educational and licensing requirements of acupuncture practitioners. The training, standards of practice, and licensing requirements for the insertion of needles in patients are well established and published. These standards must carry over to other professions, unless specifically exempted by law. Changing the name of a modality should not allow practitioners to disregard or bypass established standards.

In the interest of public health and safety, I urge you to impose a moratorium on the practice of "Dry Needling" by physical therapists not licensed as acupuncturists until such time as adequate training and licensing standards for them are met.