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Open Letter to doTerra and Young Living Corporate Offices: FDA warning letter is a challenge and an opportunity


Wisdom

 

Last year, the FDA issued a warning letter to both Do Terra and Young Living Essential Oils CEO’s about the activities of their distributor networks.

The letter to Young Living states in part:You market your Young Living Essential Oil products through paid consultants; your compensation plan for your consultants is explained on your website http://www.youngliving.com/en_US/opportunity/compensation-plan. Your consultants promote many of your Young Living Essential Oil Products for conditions such as, but not limited to, viral infections (including ebola), Parkinson’s disease, autism, diabetes, hypertension, cancer, insomnia, heart disease, post-traumatic stress disorder (PTSD), dementia, and multiple sclerosis, that are not amenable to self-diagnosis and treatment by individuals who are not medical practitioners. Consumers interested in your Young Living Essential Oil products are then redirected by your consultants to your website, http://www.youngliving.com, to purchase your products and/or register as members (i.e., consultants)”.[1]

The letter to DoTerra states in part: “Your products are marketed through the website http://www.anytimeessentials.com/ and through paid “consultants,” http://www.anytimeessentials.com/work-home/, otherwise referred to as “wellness advocates,” http://www.mydoterra.com/. Your consultants promote your above mentioned dōTERRA Essential Oil products for conditions including, but not limited to, viral infections (including ebola), bacterial infections, cancer, brain injury, autism, endometriosis, Grave’s Disease, Alzheimer’s Disease, tumor reduction, ADD/ADHD,  and other conditions that are not amenable to self-diagnosis and treatment by individuals who are not medical practitioners. Moreover, your consultants redirect consumers to your website, http://www.doterra.com, to register as a customer or member (i.e., consultant), and to purchase your dōTERRA Essential Oil products.”

Here’s a PART of the rub if it’s not already obvious: “Your products are prescription drugs as defined in section 503(b)(1)(A) of the Act [21 U.S.C. § 353(b)(1)(A)]) for some of the claims made for them because, in light of their toxicity or other potentiality for harmful effect, the method of their use, or the collateral measures necessary to their use, they are not safe for use except under the supervision of a practitioner licensed by law to administer them.”

When I come across responses or rebuttals to the information above I often find the same tropes repeated and an absence of detail and appropriate framing of the issues involved. Here are my suggestions for both DoTerra and Young Living corporate organizations on how to go about revamping their training and policy procedures to avoid such issues.

  • Show some respect for philosophy and history by acknowledging the value of diversity rather than avoiding the burden of education. i.e., Invest in your organizational longevity and your distributors long term patronage thru enhanced education offerings.
  • Create partnerships with Aromatherapy, Business and CAM educators that would offer perks for distributors who advance their education level with college degrees or appropriate certifications.
  • Redefine your branding strategy to clearly distinguish who your customers are and why.
  •  Be mindful of nepotism.
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