Thank you for taking my comments. I believe that dry needling by PTs presents a public health risk to the citizens of Virginia. PTs do not have enough training in needling to perform this therapy safely and effectively.  I beleive you should review the recent New Jersey ruling on dry needling on this matter. The Attorney General ruled that dry needling should not be added to the PT scope of practice. Other states such as Washingtin have made similar decisions in recent years.