I am concerned that the regulatory action does not adequately define Dry Needling or dictate adequate training requirements for those who may practice this technique. Dry Needling uses acupuncture needles, but Dry Needlers lack acupuncture training. Dry Needling uses similar points to acupuncture, the same tools, and aims to have the same outcomes. As an acupuncturist, I attended hundreds of hours of didactic, theoretical, and practical training, passing examinations which focused on my knowledge of clean needle technique, safe needling practices, and ways in which needling a client can result in adverse events, and how to avoid them. Further, I will continue to receive continuing education in these matters among other clinical strategies and safety concerns, to maintain my licensure and ensure that I can safely conduct the techniques which I am licensed to practice. I strongly believe that any individual who wishes to use the same tools, and similar techniques, as a licensed acupuncture receive the same or similar training to ensure the safety of the residents of Virginia who may seek treatment from such practitioners. I have heard examples from many patients, professors, and colleagues of instances of injury at the hands of an inexperienced and undertrained practitioner of Dry Needling, and even at the hands of a teacher of Dry Needling during a Dry Needling training seminar. I strongly urge those involved in the regulatory action to review the following articles and consider how to keep Virginians safe in regards to the practice of Dry Needling: DOI 10.1089/acu.2016.1187 ; DOI 10.1089/acu.2016.29032.zhu ; "CCAOM Clean Needle Technique Manual - Best practices for acupuncture needle safety and related procedures" with particular attention to the introduction, especially page xviii, and pages 1-23 regarding the types of adverse reactions to acupuncture and the best practices for their prevention and management.

I appreciate your attention to this matter of public health and safety.