Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Physical Therapy
Regulations Governing the Practice of Physical Therapy [18 VAC 112 ‑ 20]
Action Practice of dry needling
Stage Proposed
Comment Period Ends 7/26/2019
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7/26/19  11:24 pm
Commenter: yuna jan

Safety Concerns


Licensed Acupuncturists engage in many hours of clinical, safety and continuing education in order to refine their
specific clinical skills including the piercing of skin to achieve therapeutic effect and avoid harm.

In Maryland acupuncturist students are required to complete a minimum of 660 hours of supervised clinical training, as well as coursework in safety and infection prevention. In addition, after graduation, licensed acupuncturists in Maryland are required to complete 30 continuing education hours every two years to refine their clinical skills of piercing the skin for therapeutic effect. Many choose to study more than the minimumrequirements.

Physical therapists however, have no such training while in school and their non-regulated post-graduate dry needling courses are short (as little as 27 hours18).

Individuals who attain national acupuncture certification through the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) undergo a rigorous training program at a minimum standard of three academic years, 1490 hours in acupuncture, including point location and needle technique. Of the 1490 hours in acupuncture, 660 hours must be clinical hours, in other words, hours spent practicing acupuncture under the supervision of a LAc.

In addition, NCCAOM-certified Acupuncturists are required to be certified in Clean Needle Technique and must complete Continuing Education Units in order to maintain their certification.19

The National Center for Complementary and Alternative Medicine, a division of the National Institutes for Health, states: “Acupuncture is generally considered safe when performed by an experienced practitioner [emphasis added] using sterile needles. Relatively few complications from acupuncture have been reported. Serious adverse events related to acupuncture are rare, but include infections and punctured organs. Additionally, there are fewer adverse effects associated with acupuncture than with many standard drug treatments (such as anti-inflammatory medication and steroid injections) used to

manage painful musculoskeletal conditions like fibromyalgia, myofascial pain, osteoarthritis, and tennis

elbow.”20 The World Health Organizations confirms: “In competent hands, acupuncture is generally a safe procedure with few contraindications or complications. Nevertheless, there is always a potential risk, however slight, of transmitting infection from one patient to another (e.g. HIV or hepatitis) or of introducing pathogenic organisms. Safety in acupuncture therefore requires constant vigilance in maintaining high standards of cleanliness, sterilization and aseptic technique. There are, in addition, other risks which may not be foreseen or prevented but for which the acupuncturist must be prepared. These include: broken needles, untoward reactions, pain or discomfort, inadvertent injury to important organs and, of course, certain risks associated with the other forms of therapy classified under the heading of "acupuncture".21

“The most important finding from this survey is that there were no serious adverse
events associated with 34,407 treatments provided by professional acupuncturists
[emphasis added]. We estimate that,
with 95% confidence, the underlying serious adverse event lies between 0 and 1.1 per 10,000 treatment episodes.22

“No serious adverse events were reported, where these were defined as requiring hospital admission, prolonging hospital stays, permanently disabling or resulting in death (95% CI; 0 to 1.1 per 10,000 treatments). This conclusion was based on data collected from one in three members of the British Acupuncture Council. Given that the whole membership delivers between one and a half and two million treatments a year, this is important evidence on public health and safety. When compared with medication routinely prescribed in primary care, the results suggest that acupuncture is a relatively safe

treatment modality.”23


18. Kinetacore. Level I Course. Applications for Pain Management and Sports Injuries. Web Retrieved August 14, 2012 from:

19."Council of Colleges of Acupuncture and Oriental Medicine Position Paper on Dry Needling."Acupuncture Today Is a Leading Provider of Acupuncture News, Info
and Research Information in the World. Web. 28 Dec. 2011. <>.

20.Simons DG, Travell JG, Simons LS.Travell and Simons’ Myofascial Pain and Dysfunction; the Trigger Point Manual. 2nd ed. Baltimore, Md: Williams & Wilkins;

21.Dry Needling in Orthopaedic Physical Therapy Practice, Jan Dommerholt, PT, MPS.Orthopaedic Practice Vol. 16;3:04

22.MacPherson, Hugh, Kate Thomas, Stephen Walters, and Mike Fitter."A Prospective Survey of Adverse Events and Treatment Reactions following 34,000
Consultations with Professional Acupuncturists."

23.MacPherson, Hugh, Kate Thomas, Stephen Walters, and Mike Fitter.CITATION "A Prospective Survey of Adverse Events and Treatment Reactions following
34,000 Consultations with Professional Acupuncturists."Acupuncture in Medicine. BMJ Journals, 2001.Web. 7 Apr. 2012.

CommentID: 74536