PT's have, since the beginning of "Dry Needling", been able to circumvent adequate training and continuing education requirements.  We have seen an increase in incidents of pneumothorax and nerve damage as a result. We have also seen an encroachment of "acupuncture as done by PT's"  (recent advertisement-  "allergy relief with dry needling").  We are not against the practice of dry needling being done by a trained and licensed professionals (acupuncturists and MD's who have certified in medical acupuncture) who must have clean needle certification, hundreds of hours of clinical supervision, and continuing education requirements.  Even surgeons are required to have OVER 100 hours of clinical supervision to ensure needle safety (separate from the didactic education of acupuncture).  The American Medical Association has a written a formal opinion recommending that PT's not be allowed to do dry needling because of the significant lack of training and no continuing education requirements nor oversight.   We recommend that, due to significant public safety concerns, oversight by a board OUTSIDE the PT board is allowed to  establish safety and continuing education requirements as well as narrowly defined scope of practice so that the public can be assured of competency and safety before PT's are allowed to add dry needling to their practices.