With regard to 18VAC112-20-121, I am firmly against the Board of Physical Therapy approving the practice of dry needling. While I have great respect for the profession of physical therapy, dry needling done by physical therapists poses a danger to public saftety because they are essentially practicing acupuncture without the proper training. Dry needling uses needles to alleviate pain from trigger points. Although acupuncture encompasses much more than simply putting the needles where there is pain, the needling of painful or ashi points is acupuncture. Therefore, dry needling is acupuncture. For my Masters in Acupuncture and Oriental Medicine, I took 163 credits which is equivalent to 4 years of school. There were four semesters of clinical internships where we were supervised by our acupuncture professors. The reason for all this training is for efficacy and most importantly safety. After school, acupuncturists take the NCCAOM board exams which include tests on biomedicine, acupuncture, chinese herbology and the foundations of Oriental Medicine. In addition, Virginia requires licensed acupuncturists to have updated continuing education. All of these measures are to ensure that we as a profession are held to the highest standard and can treat patients with minimal risk. It is absurd and dangerous to think that several hours of dry needling training can produce practitioners who can safely perform what is in essence, acupuncture. As the proposal states, "Dry needling is an invasive procedure" which begs the question, why would the board give itself permission to perform invasive procedures without proper training? Pneumothorax, infection, nerve, blood vessel or organ injury are serious and very real consequences of needling without sufficient training. These results will reflect poorly on dry needling and physical therapy. Acupuncturists work hard during school and beyond to perfect their skills in order to safely help their patients. Physical therapists also work hard to ensure their patients get the best care. If dry needling is not even a requirement in physical therapy school but acupuncturists learn it for years, how can you say that physical therapists doing dry needling is in the best interest of the patient? We can work together for the health and safety of our communities. I often refer patients to physical therapy as it is  a valuable resource. Please have the respect for acupuncture to do the same.