I am writing to express strong opposition to the proposed amendment to 18VAC85-120-110, which would permit athletic trainers to perform dry needling.

Athletic trainers lack the training, background, and education necessary to safely insert filiform needles into any part of the human body. This practice requires extensive apprenticeship, in addition to specialized education, and this necessity bears out in the statistics: dry needlers are significantly more likely to cause adverse effects in patients--effects such as pneumothroax (punctured lung).

When a licensed acupuncturist watches dry needling, we really cannot adequately convey our horror at the unsafe technique and inexpert location choices. A huge portion of my own practice has been rectifying the lasting pain and nerve damage from dry needling so aggressively and naively applied to tender areas.

I often say that dry needling resembles acupuncture in its early days, back before it was systematized into a science: naive, clumsy, and dangerous. There's a reason we train the way we do, and it's due to our field's accumulated experience over a long period of time.

Scope creep costs lives. Maintaining our current scopes of practice ensure safety for patients and practitioners, and patient safety should come first, regardless of the financial boon from which the trainers hope to benefit.