To Whom It May Concern: While dry needling has been found to be effective in treating trigger points, it frequently uses acupuncture books are references and acupuncture needles in their treatment. By these two facts alone, it should be classified as acupuncture. Acupuncturists have national board exams that require hundreds of hours of didactic studies as well as many hundreds (sometimes over a thousand) supervised clinical hours. While PTs may have adequate knowledge of anatomy, they simply lack the training to safely use needles, something that has not traditionally been part of the physical therapy tools. PTs will argue that what they are doing is not acupuncture because it is not treating the patient holistically. Regardless of theory, it is an invasive procedure that uses needles up to 4 inches long over major organs and vessels of the body. To allow PTs to use acupuncture procedures under the guise of dry needling poses an unnecessary risk to those who are seeking an alternative to current standards of care for pain management. Thank you for your time.