Based on a review of the information gathered during the investigation of the matter, the Inquiry Committee was concerned that: (i) the Registrant failed to comply with the requirements of the Safety Program Handbook in performing acupuncture and handling acupuncture needles and thereby placed patients at risk; (ii) the Registrant failed to maintain a hygienic and safe clinic and thereby placed patients at risk; (iii) there was evidence that the Registrant’s treatments may have caused two patients to contract acute hepatitis B; (iv) the Registrant misused the Dr. (doctor) title; (v) the Registrant failed to complete mandatory continuing education courses; and (vi) the Registrant failed to maintain proper clinical records.