1-The needle used in 'dry needling' classified by the FDA as a special control (class II) "an acupuncture needle that is intended to pierce the skin in the practice of
acupuncture may be commercially distributed if it is the subject of a cleared premarket notification
(510(k)), complies with the special controls, and meets all other applicable statutory and regulatory
requirements."  Dry needling is acupuncture, attempting to use semantics to alter regulations at the cost of public safety is irresponsible for health providers who take the oath to do no harm.  Acupuncturist learn how to do many forms of acupuncture including 'dry neeeling' without that term being used, we are taughted to use 'ahshi points' tigger points.  The attempt to use scientific research and coin a term to by pass proper education, regulation and licensing is public health concern.  Dry needling by PT, DC, RNs are illegal in many states including California.  I urge your state to compare the education curriculum for acupuncturist in comparison to PTs, and make proper Guille ones of licensing, examination and regulations for the use of acupuncture needles that are classified by the FDA in your state, for the safety of patients.  Thank you for keeping the public safe.