I'm writing to object to the proposed "dry needling " regulation in Virginia.      WHO has a clear definition that dry needling is acupuncture and suggests non-physicians should have minimal 1500 hours training in needling medicine to practice acupuncture/dry needling.     So to practice acupuncture/dry needling, the non medical doctor practitioner should put himself/herself into a rigorous hours of acupuncture training program;   otherwise it is a serious threat to the public health.     A massage therapist has to at least fulfill certain hours of training to do massage.   A orthopedic surgeon has to fulfill certain hours of training to qualify to do surgery.    A chiropractor has to go through a certain hours of training to do chiropractice adjustment.     This applied to acupuncture/dry needling as well.   This is common sense in medicine where one has to train with minimal number of hours set by the regulation before they can practice.