Dry needling is clearly a subset of acupuncture practice; it uses the same tools in the same modality.  Even medical doctors, who have infinitely more training than PTs are required to have extensive training to practice acupuncture.  Dry needling is an invasive and dangerous procedure, accompanied by inherit risks, including pneumothorax, permanent nerve damage and infection.  If PTs are to expand their scope of work to using acupuncture needles, they should at least be held to the same training standards as medical doctors.  The current draft of the regulation is reckless and puts the public at risk.