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Regulation & Compliance

Essential Oils, 29 Years On: A Lawyer's Contraindication Checklist Still Applies

A 1998 University of Miami study, cited 227 times in Web of Science, anchors attorney Robert Galamaga's updated liability and contraindication guidance for estheticians using essential oils.

By Rebecca Stone · · 4 min read · 817 words

Composition

  1. A 1998 University of Miami Touch Research Institute study on aromatherapy had 227 Web of Science citations and 686+ Google Scholar citations as of September 4, 2026.
  2. Blending essential oils with a carrier oil reclassifies the esthetician as a "manufacturer" with full legal liability, per attorney Robert J. Galamaga.
  3. Most marketplace essential oils labeled "pure" or "therapeutic-grade" are not grade 1 or 2, and "therapeutic" has no recognized qualifying source.
  4. Contraindications include pregnancy, epilepsy, high and low blood pressure, medication use, children under 13, and excessive alcohol consumption.
  5. Florida still issues no license for aromatherapists; Miami Aromatherapy has been a CEU provider for massage therapists since 2001 (#50-1341).
Essential Oils, Almost 29 Years Later
Essential Oils, Almost 29 Years Later — Andrzej Gdula / unsplash

A 1998 study coordinated with the University of Miami's Touch Research Institute — "Aromatherapy positively affects mood, EEG patterns of alertness and math computations," published in the International Journal of Neuroscience — had been cited 227 times in Web of Science as of September 4, 2026, and more than 686 times in Google Scholar. Robert J. Galamaga, attorney and Director of Education at Miami Aromatherapy, wrote that study's companion article in Les Nouvelles Esthétiques American Edition in February 1998. Almost 29 years later, he has revisited it, and his message to estheticians is blunt: the basics still bind.

Galamaga, a Florida Bar member since 1974 and corporate counsel to Miami Aromatherapy, Inc. and High Def Skin, Inc. for more than 30 years, frames his advice in liability terms. "You, as a professional, and your employer are exposed to a lawsuit for your professional actions or inactions and can and will be successfully sued if your actions or inactions cause injury to another," he writes. His prescription is hardly novel: "Do not do anything wrong."

What must an esthetician check before every treatment?

Galamaga's core demand is a client intake covering medical condition and medication history before any oil or synergy touches skin. Natural does not mean safe, he notes. A client on blood thinners should not receive an oil known to affect clotting. His contraindication list, which he calls non-exhaustive, includes:

  • Pregnancy: doctor's approval required; Galamaga recommends against use unless cleared by a qualified health care practitioner.
  • Epilepsy: he advises against smelling or applying essential oils, as certain oils can trigger a seizure.
  • High blood pressure: doctor's permission required; peppermint (Mentha piperata) can cause a rapid blood-pressure increase.
  • Low blood pressure: doctor's permission required; ylang-ylang (Cananga odorata) will immediately lower blood pressure.
  • Medication or doctor's care generally: physician clearance needed, since oils can raise or lower drug effects.
  • Children under 13: he generally recommends no essential oils at all.
  • Excessive alcohol consumption: he recommends against use.

The client must be told about all contraindications, he writes, "even if this means the loss of a sale." Practitioners also absorb repeated exposure themselves: after a day of manual applications, the therapist's own systems may be overloaded.

When does blending make you a manufacturer?

Here is the compliance point formulators should note. If the esthetician selects and blends oils into a synergy and mixes them with a carrier oil, that person "can now be considered 'a manufacturer,' with all of the legal obligations and liabilities of a manufacturer," Galamaga writes. A synergy — a blend whose chemical composition differs from its component oils — carries that reclassification with it.

Scope of practice is equally firm. Estheticians may use and make oils available, but they cannot claim a product will "cure" an ailment. Certification, he explains, only confirms completion of a course of study; unless you are a licensed medical provider, it grants no authority to prescribe oils to heal a condition. You cannot practice medicine or dispense a drug. Florida, he adds, still recognizes no license for "aromatologists" or "aromatherapists," so no reference standard exists; he recommends reading at least two or three aromatherapy books before choosing a teacher.

What do "pure" and "therapeutic grade" actually mean?

Very little, in Galamaga's telling. Essential oils result from steam distillation of plants, trees and flowers — distinct from carrier oils such as grapeseed or evening primrose, which come from pressed seeds. A lavender fragrance oil is a synthetic compound, not an essential oil. Grades run 1, 2, 3 and onward, and most marketplace oils labeled "pure" or "therapeutic-grade" are not grades 1 or 2.

"There is no recognized source that can qualify an essential oil as 'therapeutic,' as 'therapeutic' is just a marketing term," he writes. A tenth distillation of the harvest can still be called pure. His broth analogy is unprintable in polite procurement documents, but the point stands: dilution of origin is invisible on the label. Even "organic" certification offers limited shield, because acid rain and wind — he cites the Saharan dust reaching South Florida each summer — can carry pesticides onto any field crop.

Does the history hold any weight?

Galamaga's lineage is the familiar one: biblical frankincense, medieval plague gravediggers surviving with garlic, René Gattefossé coining "aromathérapie" in 1928 after plunging a burned hand into lavender oil. Dr. Jean Valnet's "prized localities" still explain why growing region matters. The 227 Web of Science citations suggest the 1998 Miami findings have aged well; the liability checklist has aged better.

His closing verdict: quality grade 1 and 2 oils are difficult to find but available, and an untrained esthetician using them risks civil liability if an adverse effect occurs. Watch Florida, which has licensed no aromatherapy profession since Galamaga began teaching CEU courses for massage therapists under provider #50-1341 in 2001 — and watch whether any state moves to change that.

via youtube.com (Original)

Filed under

  • essential-oils
  • aromatherapy
  • contraindications
  • professional-liability
  • scope-of-practice

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Rebecca Stone

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Staff writer covering people, launches and day-to-day practice in professional skincare and cosmetics industry at INCI File.

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