Dry needling is a subset of acupuncture, a particular style. The greatest risk for severe medical injury from acupuncture needles comes from low trained or poorly trained professionals in other fields. Acupuncturists have minimum of four years post bachelor's degree in training, including location, depth, angle, gauge, duration, technique style. We spend an incredible number of hours on safety. The NCCAOM regulates nearly every state with assessing our level of training and safety. The medical errors for acupuncture are almost completely encountered by short-trained people from PT, sports medicine, nurses, etc. Please consult with the NCCAOM before enacting a scope revision that isn't safe for your population. Dry needling is an acupuncture technique, and should be regulated as acupuncture, and by the acupuncture boards.