According to the Board of Nursing, you can use essential oils in a diffuser, but as soon as you start to apply it topically, you are using it as a treatment. Nurses need an order from a provider when intended to treat, as it is not regulated by the FDA like an over the counter medication.
As you know, the NH DOE Technical Advisory on Medication During the School Day speaks to non-prescription medications and says they "shall be given only with the written authorization of the parent and/or guardian and if this is in accordance with school policy" -- but as you mention, your school has no policy addressing this specific topic.
I suppose one question would be whether or not an essential oil is considered a medication. There are so many different medical modalities that it makes this question a little more murky. However, I did find an interesting perspective from the FDA's Aromatherapy website (https://www.fda.gov/Cosmetics/ProductsIngredients/Products/ucm127054.htm) outlined below:
Is it a drug?
If a product is intended for a therapeutic use, such as treating or preventing disease, or to affect the structure or function of the body, it’s a drug. For example, claims that a product will relieve colic, ease pain, relax muscles, treat depression or anxiety, or help you sleep are drug claims.
Such claims are sometimes made for products such as soaps, lotions, and massage oils containing “essential oils” and marketed as “aromatherapy.” The fact that a fragrance material or other ingredient comes from a plant doesn’t keep it from being regulated as a drug.
Under the law, drugs must meet requirements such as FDA approval for safety and effectiveness before they go on the market. To find out if a product marketed with drug claims is FDA-approved, contact FDA’s Center for Drug Evaluation and Research (CDER), at email@example.com.
Regardless, and to the best of my knowledge, essential oils are not regulated by the FDA and that leaves you without reliable resources to understand their actions, expected outcomes and adverse reactions. The AAP addresses this in a round-about way in their 2009 Policy Statement—Guidance for the Administration of Medication in School, stating that alternative medications should never be administered without a written physician order. Hopefully, the parent (and provider) will work with you to get the needs of the student met in a safe and realistic manner.
We have included the following in our District Medication Policy:
Alternative medications such as herbal or homeopathic medications, are not tested by the USA Food and Drug Administration for safety or effectiveness. Lack of safety information for these medications limits their appropriate use at school. Alternative medications will require the same provisions as prescription medications, including a Physician's order before being administered at school.
The following resources were helpful in formulating this policy decision:
Posted on Behalf of Emily Martineau, RN
Please remember that responses should be posted in the School Nurse Forum, www.nhschoolnurses.org or directly emailed to Emily.
I am wondering if anyone has policies on students using Essential Oils (not ingested) during school (in this case for a sensory break). Do any nurses allow this with just a note from the parent? Do you only allow with an MD order? We do not have a set policy. I am curious what other nurses are doing if they have encountered this. Thank yo--
Emily Martineau, RN