Dear Board of Physical Therapy, 

I am a licensed acupuncturist in the state of Virginia and California.  I am writing to OBJECT to the intent to draft "dry needling" regulations.  I believe the regulations present a serious threat to public health and would authorize physical therapists to engage in acts that are clearly outside the scope of practice for physical therapy. 

I encourage you NOT to draft regulations because: 

1. 54 hours of training is inadequate level of training to qualify a physical therapist to safely insert acupuncture or other forms of needles into patients.  In comparison, to Licensed Acupuncturist who receive over 500 hours in the topic of Acupuncture needling alone (not including theory and clinical supervised practice).   The regulations as proposed by the profession of physical therapy are therefore a serious threat to public safety;
2. The dry needling rules are illegal, because they would allow physical therapists to engage in acts that are outside the legal scope of practice for physical therapy as defined by Virginia's General Assembly. There is nothing to support that the General Assembly ever intended to allow physical therapists to insert acupuncture needles into patients absent the same level of training required for licensed acupuncturists;
3. Dry needling constitutes the practice of acupuncture under Virginia law and there is no basis for allowing physical therapists to practice acupuncture with only a small percentage of the training required for acupuncturists and medical doctors.

Thank you for considering my comments. 

Sincerely, 

J. Haunani Chong Drake, L.Ac.