I am an acupuncturist who has been practicing for over 12 years.  I have taken classes in Trigger Point release (essentially what is done with Dry Needling) in acupuncture school and in Dry Needling in post graduate classes.  Needling over organs must be done carefully to prevent injury.  The lungs are especially vulnerable to pneumothorax.  Many trigger points are located over the lungs.   If not performed properly, the needle can slip between the ribs and injure the patient.  Physical Therapists receive a comprehensive education on anatomy and physiology, including underlying organs, nerves, and blood vessels.  However, safely needling over these structures requires many hours of practice. 

In acupuncture school we needle each ourselves and classmates for more than one semester prior to needling patients.   We spend an entire year as interns needling patients under supervision of licensed acupuncturists.   

With the Dry Needling Regulations in Virginia, Physical Therapists who have no training in inserting needles into patients during their training, are able to needle the public after weekend classes. 

I have had several patients come to me after dry needling by a PT, saying it was one of the most painful experiences they ever had.   As an acupuncturist trained in many needling techniques, I oppose overly aggressive needling of a Trigger Point.  I have been trained in many needling techniques.  I do a thorough intake for each patient to determine the type of needling that is most beneficial for him or her.

This is an issue of public safety.   

The scope of practice of Dry Needling needs to be better defined. It a technique to release Trigger Points.  Any other "Dry Needling" that include acupuncture points, electric stimulation on needles along the spine,  distal needling (needles placed a distance from the Trigger Point), or any other type of needling other than release of Trigger Points is an expansion on the original technique.  This would require even more specialized training.   From my comments on the last version of the Regulations (edited for clarity): 

There are Physical Therapists in the U.S. advertising “Facial Rejuvenation” Dry Needling. This is beyond the scope of "therapy of muscle pain, including pain related to myofascial pain syndrome.”  The face is a sensitive area and patients tend to be more upset with facial bruising.  Any facial needling should require more specialized training.  Physical therapists are also advertising that they are treating sinusitis, an internal condition. Though sinuses can indeed be treated needling facial muscles, an acupuncturist would make a proper diagnosis to treat the underlying cause of the  inflammation as well as give dietary and and lifestyle advise.  A physical therapist treating facial muscles only would be circumventing proper medical treatment.  A physical therapist was advertising treating headaches by needling the hand.    This is using acupuncture while circumventing proper education.  Chinese Medicine has over 2000 years of theory, practice, and research to ensure proper use of points.  If the same points are used in Dry Needling, they should not be used by under-trained practitioners.  Dry Needling, when using a solid filoform needle is an acupuncture technique.