Safety:

Needling is in an invasive procedure that carries risk of harm to blood vessels, muscles, tendons, and internal organs.

 1.  54 hours in an inadequate amount of time to safely learn to needle all the areas of the body.  I understand that physical therapists receive a very thorough education in Anatomy and Physiology, but needling deep into the body is a skill that requires more than continuing education classes.  

2. There should be required observation of dry needling before needling a patient.

3. There should be supervised internship period prior to being certified to needle the public. 

4.. There should be certification of proper and safe needling techniques.  Clean Needle Technique is a required risk management course above and beyond acupuncture classes.  http://www.ccaom.org/downloads/7thEditionManualEnglishPDFVersion.pdf   Equivalent training should be required for dry needling.

5.  There should be comprehensive competency testing before certification to needle the public.

Education:

There is no accreditation process for Dry Needling courses.  There are many different courses available today. How do you ensure proper training?   Who is teaching the class?   Some adhere very closely to the original definition of Dry Needling.  Some are using acupuncture points, and these classes should not be available to anyone who does not complete a full acupuncture education

Scope of Practice:

Any Dry Needling regulation should require very defined Scope of Practice for non acupuncturists. I am happy to see the proposed regulations do include a defined Scope of Practice.  There are Physical Therapists 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 headings by needling the hand.  The picture clearly shows a distal acupuncture point known for treating pain.  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.  Modern research is showing the underlying mechanisms of how needling these points reduce pain and some Physical Therapists are using the research to advertise Dry Needling as a superior technique to acupuncture.