Doing Raindrop Without a License: Is it Legal? – Volume 4, Number 6

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Doing Raindrop Without a License: Is it Legal? - Volume 4, Number 6 Doing Raindrop Without a License: Is it Legal? - Volume 4, Number 6

Raindrop Messenger

Official Newsletter of CARE

The Center for Aromatherapy Research and Education
12923 BCR 800, Marble Hill, Missouri USA 63764
(573) 238-4846

NOTE: The information in this newsletter is intended for education purposes only. It is not provided in order to diagnose, prescribe, or treat any disease, illness, or injured condition of the body or mind. Anyone suffering from any disease, illness, or injury should consult with a physician or other appropriate licensed health care professional.

Doing Raindrop Without a License: Is it Legal?
by David Stewart, PhD, DNM

Originally Posted November – December 2006

1. Doing Raindrop Without a License: Is it Legal?
by David Stewart

One of the most frequently asked questions by those whom we train in vitaflex and raindrop techniques is “Can I do these legally if I am not a nurse, doctor, massage therapist, or licensed health professional of some kind?” The answer to that question is not a simple “yes” or “no.” It is a complex gray area. However, there are some principles you can apply that will enable you to perform raindrop and vitaflex whether licensed as a health care provider or not.

First of all, it is legal everywhere for anyone, both professional and non-professional, to do raindrop on spouses, friends, and relatives when they don’t charge beyond the cost of the oils. (A raindrop session usually consumes about $25 worth of oils.) Non-health professionals may also charge for their time and services depending on what laws apply and on what they hold themselves out to be. Laws that might be interpreted to apply to raindrop are usually in the realm of massage therapy and bodywork. These laws differ from state to state, from province to province, and even, in some cases, from county to county and city to city.

Discovering the regulations pertinent to you in your area is something you would have to research yourself, that is, if you think it is necessary to know. Such rules are not always clearly written nor easy to understand and can lead to confusion rather than clarity concerning the legality of raindrop.

Secondly, if you perform these techniques without a government recognized license for hands-on practice, it is highly unlikely that any legal difficulties would arise unless someone in your community (a professional) feels threatened by your activities and files a complaint with an authorized board of some kind. Licensing boards don’t usually have teams of enforcers whose task is to search for people who may be in violation of their regulations. They don’t have the resources for such programs. Therefore, unless someone complains about a specific individual, such boards remain unaware and unconcerned. However, if a complaint is filed against you with a government agency, they are legally bound to investigate whether they agree with the complaint or not.

To the best of my knowledge, at this time vitaflex and raindrop techniques have not been legally defined by any government agency in North America. For example, without a legal definition, it would be difficult for the medical profession to substantiate a claim that raindrop is “the practice of medicine.” In a court of law, the practice of medicine has been defined as “what doctors customarily do” and doctors don’t customarily do raindrop. The question of legality usually arises in the context of massage therapy or body work, but can also be considered in the context of nursing.


The State of Missouri, which is where I reside, has some interesting laws and has made some interesting rulings in this regard. Missouri is called “The Show-Me State” because of the reputation of its residents for requiring proof for any newly expressed ideas. State something original or different to a native Missourian and they will often come back with, “Show Me.”

Recently, a licensed Missouri massage therapist was feeling challenged by the raindrop practice of an unlicensed individual in her community who also taught raindrop in a local massage school. She threatened to file a report with the State Board of Therapeutic Massage against both the school and the unlicensed individual. The ambiguity of Missouri regulations for massage professionals suggests several interpretations, some allowing unlicensed people to practice raindrop, others not. Hence, a letter was addressed to the Licensing Board asking them to “show us” a correct and official interpretation of the law.

The Executive Director of the Missouri Board of Therapeutic Massage replied in a letter dated in February 2006 which stated the following:

(1) “Raindrop Therapy is considered ancillary therapy and not massage theory and practice. Therefore, an instructor in this area should not have to be licensed as a massage therapist. Instead, she/he would need to be educated and/or trained in the treatment. . . If a person is demonstrating how Raindrop Therapy is administered, a license for that person is not

(2) “Where the confusion can occur is when any technique is incorporated into and/or advertised as massage therapy. In that case, the licensure becomes an issue. Utilizing Raindrop Therapy does not require a massage therapy license as long as it is not advertised or represented as massage therapy.”

So in Missouri, insofar as the Massage licensing Board is concerned, teaching raindrop and vitaflex can be perfectly legal with or without a license. It also appears from this statement that doing raindrop is also legal with or without a license as long as it one does not put oneself out as being a massage therapist and does not advertise raindrop as such. The issue of charging or not charging was not mentioned.

Notice that in the language of the Licensing Board letter, raindrop is referred to as “therapy” and as a “treatment.” We avoid these terms since in many places, these terms have legal connotations implying a need for a license. This is why we use the term “raindrop technique.” We also refer to “raindrop sessions” (not treatments) and to ourselves as “facilitators” (not practitioners or therapists).

This recent commentary on the scope of raindrop in the context of professional massage practice in Missouri does not include opinions of the State Boards of Nursing, Chiropractic, Medicine, or any other health-related modality. So while things are ok with the Massage Therapy Board, the practice of raindrop could still be challenged by any of these other boards. In some states, it has been the Board of Registered Nursing who have felt threatened by unlicensed raindrop facilitators and who have gotten involved with the legality of raindrop, trying to declare it as a practice of nursing.


The letter from the Missouri Board of Therapeutic Massage (MBTM) also mentions that those doing or teaching raindrop “need to be educated and/or trained in the treatment.” Taking a CARE Seminar or CARE Intensive earns you certificates of participation which are sufficient proofs of the necessary education and training for raindrop in the eyes of the Missouri board. However, a certificate of participation is not the same as certification or licensing.

A certificate of participation only verifies that you took a formal class. Certification verifies that you have demonstrated a certain level of skill after completing your formal training. Licensing means that a government agency recognizes your right to practice under certain stipulations. You can be certified without being licensed. Certification says you have met a certain level of competence. Licensing says you are legal in the eyes of the government within certain boundaries and have agreed to practice within government regulations. There are exceptions to these definitions. In some states a Licensed Massage Therapist (LMT) is referred to as a Certified Massage Therapist or CMT. So these terms can be confusing when comparing one governmental region with another.

The term, “registration,” is also applied to various professions and can have two different meanings. It can mean the same as certification (i.e. you have passed a competency test) and/or it can mean “licensing,” (which means endorsement by a government agency). For example, one can be a Registered Aromatherapist (RA), which indicates the passing of a written test administered by the Aromatherapy Registration Council (ARC), a non-profit, non-governmental agency. You can also be a “Registered Massage Therapist” (RMT) which is a license granted by a state or province.

Some Certified CARE Instructors (CCIs) are also Registered Nurses or Licensed Massage Therapists, but most CCIs do not have a government-issued license. The Association of Body Massage Professionals (ABMP) accepts CCIs into their insurance program and recognizes CCIs as professional Bodyworkers. The ABMP phone number is 303-674-8478. Their website is


The Missouri Code of State Regulations (#324.265,p.5,#7(1)) specifies whom is exempt from regulation by the Board of Therapeutic Massage (MBTM) as follows: “The following practitioners are exempt from the provisions of this section upon filing written proof with the board that they meet one or more of the following: Persons who act under a Missouri state license, registration, or certification and perform soft tissue manipulation within their scope of practice.” In a recent communication from the MBTM they cited this section and stated, “These exemptions apply to reflexology, chiropractors and energy workers.”

Among other things, raindrop is an “energy modality,” which is why the oils dropped 6-8 inches above one’s spine in order to pass through one’s electromagnetic or energ field. Vitaflex is also energy medicine inasmuch the technique makes use of the piezoelectricity of the body. From this it could be well argued that raindrop and vitaflex techniques are energy work that incorporate reflexology as part of their scope of practice. Therefore, raindrop/vitaflex facilitators who have been trained and certified in these skills should be eligible for exemption from state regulation in Missouri.

This interpretation of the law has not been put forth nor tested, but it does provide a possible avenue within the law of Missouri whereby those who have achieved a designated level of training in raindrop or vitaflex could be legally exempt from state regulation provided they stayed within the limits of what defines the scope of these practices. Such an idea may be applicable in other states or provinces as well.


If you live in Canada, a new program has recently been accepted by the Canadian Board of Examiners as sufficient for you to practice raindrop and vitaflex legally throughout Canada and the British Commonwealth (some 17 countries). A raindrop practitioner in Canada can become an Integrated Aromatic Science Practitioner (IASAP) and be legally authorized to practice raindrop with no other training, certificate, or license. This credential is not yet recognized in the United States, but that could happen at some future time.

This new degree program is offered exclusively by the Institute for Energy Wellness Studies (IEWS) in Brampton, Ontario (a suburb of Toronto). For more information on their class schedule and tuition, call 905-451-4475 or visit their website at The teaching faculty of this new school includes Dr. Sabina DeVita, Dr. David Stewart, and Dr. Carolyn DeMarco. Their mission and curriculum have been endorsed by D. Gary Young.


The George Gordon School of Law in Isabella, Missouri, offers a number of week-long courses on your rights of religious freedom in the United States based on the covenants of the Bible as well as the tenants of secular law. George has a daily one-hour radio program. Recently (in October 2006) he dedicated a whole week (7 programs) to a discussion of David Stewart’s book, “Healing Oils of the Bible.” His wife, Jacqueline, and daughter, Kohl, recently attended a CARE Intensive in Branson, Missouri, in order to learn raindrop.

According to Gordon, using the “Religious Free Exercise Clause” of the U.S. Constitution along with other provisions of federal and state law, one can file a statement of intent (to engage in raindrop, for example) with their county court house that can enable them to offer raindrop legally with no license or other government approval, irregardless of what laws may be on the books. Complete information and training in this manner of getting around the licensing question is available by taking a week-long course from the Gordon School of Law. The pertinent course is called “Tax and Status.” Matters such as legally avoiding tax liability are also taught in Gordon’s course on “Business,” all in harmony with a Biblical perspective.

For more detailed information on courses offered by the Gordon School, visit The seven one-hour-long programs on “Healing Oils of the Bible” are also archived on this site and can be replayed from there.


Government rules and regulations that may apply to raindrop all boil down to whom the government authorizes to touch another human being. Nurses, chiropractors, massage therapists, MDs, DOs, physical therapists, and other licensed health-care professionals are licensed to touch in the practice of their professions. Hair stylists and beauticians can legally touch, too, but only to restricted body areas such as head, shoulders, hands, and feet. Ordained ministers and recognized church elders are also authorized to touch in blessing, baptizing, and anointing with oils.

In the Bible, the Hebrew word translated as “anoint” is “masach” and the Greek word is “Chrio” or “Chrisma.” Both terms actually mean “to massage or rub with oils” usually accompanied with a prayer or blessing. This is actually what raindrop is, “a massaging or rubbing with oils” which is properly performed in an attitude of prayer or blessing. Hence, since the U.S. Constitution guarantees one the right to practice one’s religion and if that religion includes anointing, then one could conclude that a person can legally perform raindrop anywhere in the U.S. if ordained as a minister or an elder.

That is the approach I have taken. I used to be a licensed United Methodist Pastor, but have given that up to pursue a full-time mission of anointing with and teaching about oils and their healing powers. Anyone can become an ordained minister of the Universal Life Church. It is headquartered in Modesto, California. Simply visit and enroll for free. For a small fee you can obtain a “Clergy Package” containing all the paraphernalia and documents for marriage, baptisms, funerals, etc. I have done this and am a card-carrying ordained minister. You will find my name listed on their website as one of their ministers in Missouri.


Theoretically, if you are doing raindrop as an anointing procedure and as a minister, then you can legally ask for donations for your ministry. So you could effectively charge, not only for your time and service, but for your oils as well. Except for family members, my wife and I do charge most of the time when we do raindrops. We also charge fees most of the time for our raindrop classes. Jesus advised that “The laborer deserves to be paid.” Luke 10:7

I personally have no license from any government agency, yet I practice and teach raindrop freely throughout the U.S. and Canada. If challenged, that would be my defense, that I am exercising my constitutional rights by practicing my religious beliefs and am ordained to do so. Whether that would stand up on a specific state, county, municipal, or provincial court remains to be seen. So far, it has never come to that anywhere in the world.

Now I cannot guarantee that doing and being ordained as I have done will protect you legally or that it would ultimately even protect me should authorities choose to make a legal issue of it, but I am not concerned. The legality of offering raindrop without a license is thus far a nebulous and gray area in the laws as they are currently written. You could be harassed for doing it, but as for conviction of a crime, that is highly unlikely. As for my wife, she teaches and does raindrop here in Missouri and throughout the country same as I and she has chosen not to become ordained as I have done. Legal ordination is still a human institution. Those of us who do raindrop feel ordained from a higher source. This leads us to another interesting legal dimension on the topic of doing raindrops legally without a license.


The State of Missouri has an interesting clause in its constitution. To paraphrase, it says that “state laws shall apply only when not superseded by scriptural law.” The ramifications of this clause, and similar ones in other state constitutions, form a basis for some of the precepts taught at the Gordon School of Law.

My wife and I are law abiding citizens and Jesus did say in Matthew 22:21, “Render unto Caesar the things which are Caesar’s,” thus implying that there are an appropriate places for complying with secular laws. But in the eyes of the Pharisees Jesus was also a law breaker, seeing that he did not follow the letter of their laws. So just because a professional licensing board may say it is illegal to do raindrop without a license does not necessarily mean it is our spiritual duty to do so. Maybe so. Maybe not. Of course, going against temporal authority carries potential consequences from temporal authority. Jesus and his disciples encountered those consequences and accepted them in order to carry out their divinely ordained mission.

With regard to doing and teaching raindrop without a clearly defined license to do so, for us we really don’t care what human laws may imply or don’t imply about raindrop. To us it is a spiritual practice in which we are engaged, ordained and approved by God. I feel led by the spirit to do what I do. Into what legal consequences that may lead me at some future time is not something about which I am concerned at this time. I only know what I must do from my heart.

A healing ministry is one of faith. It cannot be practiced in fear. I personally doubt if my wife and I will ever be challenged by any legal authority, but if we ever are we will deal with it at that time in faith as we practice and teach raindrop in faith. How you personally handle doing raindrop within the present unclear legal climate is your choice. It is between you, your family, and God. That is the bottom line.

2. A Cup of Ningxia or a Bushel of Beets?
by David Stewart

I don’t need to expound on the wonders of Ningxia Red Juice(R). Just go to, which is linked with the Young Living website, It is full of data from scientific studies as well as wonderful testimonies of the health benefits of Ningxia Red Juice. I personally drink 2-3 liters a month along with consuming a package of dried wolfberries, which are the juice’s principle ingredient.


Brunswick Laboratories in Wareham, Massachusetts, has tested a number of the major brands of superjuices for their free radical neutralization capabilities. These include Xango(R), Noni(R), Goji(R), Limu(R), and Ningxia Red(R) juices. Ningxia Red (ORAC = 1500) contains almost three times the antioxidant capability as the nearest competitors, Xango and Noni (ORAC = 550).

The ORAC scale was developed for the U.S. Department of Agriculture at Tufts University. ORAC stands for “Oxygen Radical Absorbance Capacity.” Free radicals are partial molecules that are chemically aggressive. In our bodies they can damage our organs and tissues, which accelerates aging and can lead to chronic diseases and cancer. So any food that gobbles up free radicals is good for our health and can help maintain youth and extend our longevity.

In the literature from competing superjuices, their stated values for ORAC readings can be misleading. A proper ORAC value is based on 100 milliliters (approx 3.5 fluid ounces or 7 tablespoons or almost half a cup) of the food being tested. That is a quantity equal to seven 15 ml bottles of oil. In other words, ORAC is a measure of the number of free radicals neutralized by 7 tablespoons of the juice. Some companies quote an ORAC number that corresponds to as much as a whole quart or liter of their juice. This would be 10 times the standard quantity for a legitimate ORAC test which would render a reading ten times too high to be called “ORAC” and compared to other ORAC numbers obtained legitimately.

So be wary of companies that claim that their antioxidant capacity is greater than Ningxia Red. ORAC numbers are meaningless without stating the quantity of juice tested. When you read an ORAC score associated with a product, see if they also mention whether it was from 100 ml of their product or some other amount. In the YLEO literature, you will see this stated in the fine print as being properly based on a 100 ml sample. The comparisons YLEO makes with other juices are fair and valid, all based on 100 ml samples of every brand compared.


In addition to its antioxidant capacity, Ningxia Red also contains high levels of many essential minerals, amino acids, proteins, and vitamins. So its benefits go well beyond those measured by the ORAC scale. Read some of the testimonials on and you can see that daily intake of this wolfberry product can be nothing short of miraculous.

Young Living’s other superjuice is Berry Young Juice. It has the same ORAC rating (1500) as Ningxia Red. So drink either one daily and you will improve your life for life. The secret ingredient in these two juices is wolfberries (Lucium barbarum) which are native to northern China. For centuries, residents of this remote area have been noted for their longevity. They frequently live to be 120 and 150 years of age and more, while maintaining their strength, virility,teeth, and eyesight, free from arthritis, diabetes, cancer, and heart disease. Numerous studies have correlated their extraordinary health to the wolfberries in their daily diet.

Young living was the first to import these plants to America and currently harvests more than 100,000 wolfberry bushes at their farm in Utah. They import dried wolfberries from China which are also sold through Young Living. Besides the website cited above, Young Living has a variety of literature and DVDs on the merits and nutritional properties of wolfberries and wolfberry products.


One of the wonderful things about building a networking business through Young Living is that it can be done successfully in so many ways. There are the oils, which are the best in the world and unique in so many ways, which form the basis of most YLEO distributors’ businesses. They there are the personal products, chemical-free soaps, shampoos, skin products, vitamins, and supplements. And then there are the wolfberry products. Some YLEO distributors have build highly successful businesses focusing entirely on Berry Young Juice or Ningxia Red Juice.

Here is a dramatic demonstration you can do at a business-building meeting in presenting the powers of Berry Young or Ningxia Red Juice. Display the following items on a table:

4 pounds of carrots
2 quarts of carrot juice
8 oranges
1 pint of orange juice
2 pounds of beets
2 cups of beet juice
2 cups of raspberries
1 cup of blueberries

Some people object to Ningxia Red or Berry Young Juice because of the price. Two tablespoons (1 fl. oz.) of these juices costs from $1.25 to $1.60 depending on whether you paid wholesale or retail price. Point out that the nutritional value of two tablespoons of these wolfberry juices is equal to any one of the above items on the table. How does the price of two quarts of carrot juice compare? Or two cups of raspberries? Or if you like, how about a cup of Ningxia Red or a bushel of beets? They would all cost more. Furthermore, which would be easier to consume, eight oranges or two tablespoons of Ningxia Red, (not to mention a bushel of beets for a cup of Ningxia)?

The comparisons above were first published in the September 2001 issue of the Raindrop Messenger. At that time it was only available in hard copy, not on the internet, and had a circulation of less than two hundred distributors. The calculations at that time were for Berry Young Juice, but they work also for Ningxia Red since their ORAC values are the same.

During the 2006 YLEO Grand Convention in September, Marcella Vonn Harting, a YLEO Diamond, gave a breakout session using the demonstration above, with a colorful table by the podium filled with fruits and vegetables. Her workshop was on how to focus on Ningxia Red to build a successful YLEO business. She had with her a new distributor, Don Clair from Illinois, who had achieved the level of Silver in only four months taking the Ningxia Red Approach. At the convention, Marcella asked me to make this idea available to everyone in the context of Ningxia Red. So here it is. Have fun. And thanks Marcella for creating such a great visual for us.

Official Newsletter of CARE
The Center for Aromatherapy Research and Education
12923 BCR 800, Marble Hill, Missouri USA 63764
(573) 238-4846

NOTE: The information in this newsletter is intended for education purposes only. It is not provided in order to diagnose, prescribe, or treat any disease, illness, or injured condition of the body or mind. Anyone suffering from any disease, illness, or injury should consult with a physician or other appropriate licensed health care professional.

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In each issue of The Raindrop Messenger you will find articles and essays on a variety of topics related to health and longevity. Our hope is to be informative and, perhaps, inspiring to you for the benefit of your physical, mental, social, emotional, and spiritual life. The Raindrop Messenger is also a friendly way of keeping you abreast of CARE’s ongoing programs, activities and helpful books and videos.

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