Why Tolkien is not an occult author

Occasionally, people have asked me why the magic in The Lord of the Rings does not make the book unsafe to read. Magic is occult, they say. How can such a book be safe? On the other hand, how can one of the books most beloved of Christians around the world be occult?

Definitions (and no I am not and never have been in debate):
Occult (noun or adjective): Dealings with devils or describing things related to dealings with devils.
Magic: The use of supernatural (relative to the human being) powers.
Safe (for our purposes): Portraying the occult in a negative way or not at all.

First, how is it possible for any work of fiction to be occult at all? The occult is real, and fiction is not. There are two ways in which a work of fiction may contain occult content.

1. By necessity
2. By interpretation

1. Occult by necessity means that characters in the book have dealings with evil spirits. There are two problems with this, however: fantasy often occurs in an imaginary reality, so the devil equivalent is very hard to find, and an evil spirit would not say that he is evil.
Because of the imaginary element, one cannot judge supernatural phenomena inside a fantasy by the same criteria as the same phenomena in the real world. For example, the ability to levitate at will is an occult ability in the real world, but this would not be so if one wrote a fantasy where the characters naturally had the ability to turn gravity on and off. If a natural explanation is possible (even if not stated) within the context of the fantasy world, the fantasy is not occult by necessity.
Also because of the imaginary element, one cannot confuse an ability that would be supernatural in a human with an ability that would be nautural for the imaginary being. For example, Gandalf, as a Maia (not a human), has the ability to instigate opening-spells and shutting-spells, etc. As he is an incarnate Maia, however, he requires the medium of language to make his will expressed to material things. This would be an occult ability for the reasons above for a human. Most of the "good" magic in The Lord of the Rings is of this variety, more akin to impossible technology or mateiralized poetry than to supernatural powers (e.g. the elven-rings, the Mirror of Galadriel, the Palantiri, Aragorn's sword-sheath, etc.)
What can be called occult by necessity, then? Nothing less than that which actually implies dealings with evil spirits: the ability to call on spiritual powers above yourself (this is different from Lucy's magic spell in Prince Caspian, as that took place through the action of an inherently commandable nonpersonal but supernatural medium (and by medium I do not mean seance-driver)) at will for anything from mind-reading to twig-mending, the ability to remove (not invincibly constrain) the free will of another, etc. Among the good characters in The Lord of the Rings, this is never done, and among the evil...well even if it is done, it does not make the book less safe, as they are the evil characters.

2. Occult by interpretation means including thing characteristic of the human occult religion, such as actual spells (yes, they exist), allusions to yogic meditation, white/black false dichotomy, etc. The reason this is called occult by interpretation is because given the fantasy setting, they could be interpreted as perfectly natural phenomena, but because of the danger that some occult things present to humans (Star Wars does contain occult resemblances, but because there is really no more in it than in many pagan faiths, I am not worried) even the inclusion of them with innocent intentions is too dangerous to be used, especially since it could, if it were really innocent, be theoretically tweaked so that it is no longer recognizably occult but still is magical enough for the lover of honest fantasy. I am not well-versed in the specifics of the occult, but Lord of the Rings, as far as I know, contains none of them.