Please say NO to unsafe 18VAC85-120-110. There is a major concern regarding the use of dry needling by athletic trainers—a practice that poses significant risks without proper training. Dry needling involves inserting solid needles into the body, an invasive procedure that requires extensive expertise.

Licensed acupuncturists undergo thousands of hours of rigorous training in anatomy, technique, and safety protocols, ensuring patient welfare. Athletic trainers, in contrast, often receive only 20–50 hours of instruction, which falls far short of the necessary standards for safe needle use. This lack of training increases risks such as organ punctures, nerve damage, and infections.

Additionally, allowing inadequately trained practitioners to perform dry needling compromises patient trust, informed consent, and professional accountability. It blurs the lines of scope-of-practice laws meant to safeguard public health.

Responsible and regulated practices are essential for any invasive technique, and dry needling is no exception.

Thank you for your consideration.