FDA Freedom of Information Act Request Reports-Overview

Last week I received via email a response to my Freedom of Information Act Request to FDA and the Department of Health and Human Services. Contained in the email are several pages of documents regarding FDAs investigation into GlitterSniffer Cosmetics and the recall.

It has been a bit of  a struggle in determining how to post this information as the sheer volume of it is a bit overwhelming. In an effort to make this a bit easier to parse I will be separating the posts into the three different reports, divided by section. There will then be a final, separate post with scans of the reports in their entirety, save for what FDA has redacted and one minor redaction I myself made in order to ensure that a former associate of GS is protected as per their request.

A quick note about my FOIA Request: I have been informed I may still receive other documents from other government agencies in addition to what I have already received, which currently stands at 13 documents. There is generally a fee involved in receiving an FOIA request, based on a sliding scale starting at $23.00 for the first hour of research, with copies of the reports priced individually per sheet. I requested a fee waiver from FDA and HHS for this FOIA request on the grounds that this information was in the public interest and readily identified myself as the author of this blog. I was not charged for the research time or copies sent to me for this portion of the request. I publish them now just as I informed FDA and HHS I would, in the public interest.

Post One: Establishment Inspection Report dated 1/10/11 and 2/7/11

Post Two: Memorandum from the Department of Health and Human Services dated 2/8/11

Post Three:  Memorandum from the Department of Health and Human Services dated 7/20/11

Post Four: Scanned copies of the records

Fair warning, if you thought the Michigan Attorney General post was long then you’re in for more of the same with these upcoming posts, which I will be working on in the coming days. I appreciate your patience and will have them up as quickly as possible.

GlitterSniffer Complaints: One Year Later

As of yesterday it has been one year since I first posted to this blog. In that time I have posted about all thing GlitterSniffer Cosmetics, as well as other issues surrounding safety in indie cosmetics. I thought for a long time about what this post should say. I could go on ad naseum, but instead I give you this:

Today I received a response from my Freedom of Information Act Request from FDA and The Department of Health and Human Services. I will be receiving the documents on the GS investigation soon, though I currently have no ETA.

I want to thank you all for your patience as I know this will be another long post once these documents have been received. Until then, I am working on several other posts.

One year later and the grand total of refunds issued by GlitterSniffer Cosmetics for the recall (mine was not recall related) still stands at $0.00.

GlitterSniffer Cosmetics Refund Information

I was contacted via email yesterday by GlitterSniffer Cosmetics proprietor Lela Warren. Lela asked for my assistance in obtaining information to address the refund issues. The following is the plan currently in place to address any monies owed by GlitterSniffer Cosmetics for recalled product, unreceived product, consignments, and fundraisers/charities.

If you purchased recalled products, did not receive product for which you paid, worked with GS on a consignment basis, or had a fundraiser in your name GS asks that you email them using the form provided below. They ask that this format be used so it will be easier for tracking purposes. You will receive an automated response to your email which will serve as your confirmation that your information has been received and has been put into queue for refund. For those affected by the recall the information provided in the email should be sufficient to find your original purchase receipt in GS' records. If the receipt is unable to be located GS will then contact you and ask for either a forwarded email receipt or a screenshot of the Paypal purchase. No products will need to be shipped back to the company to qualify for a refund as your receipt will serve as your proof of purchase. Any information provided to GS will be used for the purposes of refund only.

There is no set timeline at this point for when GS will begin selling again or for how long the refund process will take. A percentage as yet to be determined of GS weekly sales will be earmarked specifically for refunds. GS will provide to me on a weekly basis totals and proof of refunds. I will track the progress to ensure that refunds are being remitted in a timely manner and I will post the weekly totals until such time as all refunds have been paid in full. Lela has stated that she is committed to making this right and has welcomed my continued monitoring of the situation to ensure that the process goes smoothly. If for any reason your refund is denied I ask that you please let me know. While I am not actively involved in the refund process except to post as I always have I do believe that any denials are very germane into shedding light on GS commitment to the refund process.

GlitterSniffer Cosmetics does plan to use funds made from the sale of cosmetics to issue these refunds. Lela has stated that she intends to be fully FDA compliant in the manufacture and sale of these products. FDA has a visit scheduled this week for GS and Lela will be working with them to ensure compliance.

This will be a slow process. Since sales are not expected to be what they once were it may take some time but Lela has committed to refunding everyone who is entitled. This is contingent upon GS being able to operate as a business without interference as currently it is beyond Lela's means to issue refunds with her current work situation .

Lela will be contacting TWLOHA, GLAAD, and ASPCA to work out the issue of the charity funds. Ideas at this point include volunteer work, item donation,or a percentage of the weekly refund money to be specifically earmarked for the charities. There will be further information regarding the charities once they have been contacted.

The refunds will be processed in the order in which they are received, save for Vanessa Barfield and Christie Brooks. At my suggestion GS will be remitting the funds due to them first as their particular situations predated the recall. Lela is still deciding at this point how much the refunds will be per pot and will make that information available as soon as a determination is made.

At this point the GS Facebook Fan Page is once again active and several public posts have been made by Lela. Comments are being moderated so if you choose to post to the page it may not appear immediately. Lela does not have posting privileges to the Complaints Page and there are no plans for her access to be restored.

Here is the form GS requests that anyone wanting a refund send via email to glittersniffercosmetics@gmail.com. They ask that the form be filled out as completely as possible in this format to make the process of finding receipts easier and to speed the process along. Please use the subject line 'Refund Request' to make the email easier to catagorize.

Customer Name- (Name used to place order)
Customer Email- (Email used to place order)
Order Date-
Order Amount-
Transaction ID's- Not required, send only if available
Did you order through Paypal or by other means?
What did you order?
In the event that we cannot find your receipt for this order, do you have access to it?
Any other information you might feel help us help you?

Lela has stated that she is open to any suggestions or feedback that anyone may have regarding GlitterSniffer Cosmetics or the refund process. She is well aware that not everyone will agree with this course of action and states she is fully prepared for whatever reaction may come from her decision to reopen. She maintains that she is committed to her business and will be posting a journal that will be readily accessible to all via the GS Fan Page in order to keep people informed and solicit feedback. She intends to do everything she can to make GS a success.

Though I have had in depth conversations regarding this decision on the part of GlitterSniffer Cosmetics in terms of the refund process the final decision to move forward rests with GS and, ultimately, Lela, as do the consequences and repercussions of that decision and the commitments being made. I will continue to post about the situation to ensure that refunds are being remitted and all guidelines are being followed and will not hesitate to publish whatever the outcome may be. 

GlitterSniffer Cosmetics: A Quick FDA Update

After the home visits to GlitterSniffer Cosmetics customers began a couple of weeks ago I again  contacted FDA with information regarding the recall. I informed them of the issues regarding the recall in terms of the Enforcement Report, the distribution of the recalled product sent in per the recall FAQ, and pictures showing labeling, possible injury, and the December 2010 photos of Lela's pigment stained hand.

I was contacted by FDA today regarding the GlitterSniffer Cosmetics recall. I responded and am hoping to do a telephone interview this week. There is at least one other person who was contacted and is working on setting up an interview as well.

I am spending the evening putting together a comprehensive list of instances of FDA regulation concerns with GlitterSniffer Cosmetics, in addition to questions I would like answered about the recall. While FDA does not comment on ongoing investigations I am hoping that I can get a few answers to know what has happened thus far.

I have been sent emails from a few people who would like their information passed along to FDA. I plan on including this information as well. If you'd like to supply any information to FDA please feel free to email me.

At some point I do plan on posting about GlitterSniffer Bath, but it appears that will be strictly for purposes of chronicling that it existed, as the shop is now empty and no one has checked in in a month.

GlitterSnifferCosmetics.com is Gone

It appears GlitterSnifferCosmetics.com is gone.

I tested it in several browsers (Firefox, IE, and Chrome) after clearing cache and cookies to be sure and it didn't load in any of them. People have also tried in Safari and Opera and from mobile phones. Aside from one person who was able to access the site from Safari there were no reports of the site being able to load.

Firefox

Chrome

Internet Explorer

As I posted yesterday there is still a 30 day grace period for the site to be recovered by GlitterSniffer Cosmetics. As far as I could determine the renewal costs just under $25.00.

The recall FAQ is no longer available for the public to be informed. There are bits and pieces on this blog, but they are incomplete. I will be uploading the screenshots in full this weekend to GlitterSniffer Complaints MySpace as it has unlimited free picture uploads. They will be set for public viewing without having to 'friend' the profile.

GlitterSniffer Cosmetics: Paypal and FDA-New Information

There have been a couple of developments over the last few days with regards to GlitterSniffer Cosmetics handling of the recall.

A customer who had previously sent a letter from her attorney to GS (which was ignored) requesting a refund of $1,169.15 for all her products and her intent to pursue the matter civilly if it was not remitted in a timely manner contacted Paypal on Monday to inquire about possible recovery of her funds. The customer has several hundred GS pigments and was denied a refund by GS for all of her merchandise. When she inquired about her refund the company denied any of her products were unsafe, despite 92 of them being on the recall list. She then advised the company she would see them in court. The only response she received was a simple "<3".

The injury referenced in the message possibly related to use of GlitterSniffer Cosmetics were corneal abrasions to both eyes, sustained after use of pigments in the Charity Collections. It is unknown which pigments were used specifically, as the customer purchased all three (TWLOHA, GLAAD and ASPCA) and they came in a package together, unlabeled. The customer visited a physician, was unable to wear any eye makeup for a few weeks and continues to this day to have eye sensitivity, despite not having any issues prior to use of GS.

Read from the bottom up

She contacted Paypal at 402-935-2050 and was advised the following:

With the PayPal dispute process, at this point, if PayPal investigates, and if they determine there was fraud, PayPal will start issuing refunds on the claims in the order they were received until the account is out of money. This means, if there is no money in the paypal account, there will be no refunds from PayPal.
The dispute representative did tell me that people could file a small claims court case and have their attorney subpoena PayPal's records regarding a specific seller. If a judge signs off on the subpoena, PayPal would be legally obligated to turn over any and all information regarding a particular seller.
Since I am contemplating a small claims court filing, the information from PayPal would most definitely be of assistance in my case. I am planning to contact my attorney about the subpoena.

According to Paypal if fraud is determined then Paypal would begin paying out claims from money in the GS account until that money is exhausted, though it is currently barred from use by the company itself. This is at odds with the information provided by GS at the time the accounts were frozen, as they clearly stated customers would have to wait 180 days for refunds. Additionally, if a civil case is brought by any individual and a subpoena issued all financial records related to GlitterSniffer Cosmetics would have to be released in pursuit of the matter. Should anyone choose to pursue the matter in this way they would then be privy to any and all financial records Paypal has for both GS accounts. Information such as this could clarify where the money GS earned during its most successful years went, in addition to showing exactly how much was owed in claims and provide further supporting evidence of refunds both issued (currently count: one) and denied by the company.

I posted on May 10, 2011 about a phone call from FDA to a GlitterSniffer Cosmetics customer regarding the recall. The customer was contacted again by FDA on May 18, 2011, this time from the Houston Field Office, Dallas District. The content of the call was the same, and the customer was specifically asked about the recalled pinks. Unlike the last phone call the call was identified by Caller ID as being from FDA. FDA is still apparently pursuing the investigation into the handling of the recall by GlitterSniffer Cosmetics, and the investigation has now spread to a third confirmed Field Office, this time in the South Central portion of the country. The Dallas Field Office is the office I contacted back in January that took one of my original complaints and forwarded it on to the Detroit Office.

GlitterSniffer Cosmetics and the FDA Enforcement Report Followup

I posted about the March 23, 2011 FDA Enforcement Report regarding the GlitterSniffer Cosmetics recall on April 12, 2011. The post outlined concerns with the information provided by GS to FDA, including the lack of receipt of recall letters by GS customers, the number of units distributed, and unapproved mascara not included in the recall.

Today one of the page Admins, ALC, pointed out an item I'd missed during that post. Here is the distribution list provided by GlitterSniffer Cosmetics to FDA in regards to the reach of the recalled products.

According to the information provided by the company to FDA the recalled items affected customers nationwide (US), and in Canada, UK, Taiwan, Australia, Denmark, Spain and Brazil.

On August 4, 2010 blogger Eplefe posted about her experience buying from GlitterSniffer Cosmetics. On March 21, 2010 Eplefe purchased The Super 80's Collection. The Super 80's Collection was recalled by GS in December of 2010 as either containing soap dyes and/or not being FDA approved for use around the eyes. Also interesting to note is that Eplefe's Etsy listing contains absolutely no disclaimer about the collection not being FDA approved, despite GS' continued insistence that it was disclosed in all listings. Eplefe lives in Norway.

On June 9, 2010 blogger Aijuswhanakno posted about her experience with GlitterSniffer Cosmetics. She too purchased the unlabeled Super 80's Collection and initially gave GS a positive review, even amending her review to include the FDA disclaimer from her listing.  After researching she discovered that the Super 80's Collection was not only unapproved for eye use, but was made with soap dyes, which are not approved for cosmetic use at all. She contacted GS and Lela Warren's response was to refund her and state that she had used the colors with no problems at all. At the time of purchase Aijuswhanakno resided in Japan.

Norway and Japan appear nowhere on the distribution list provided to FDA by GlitterSniffer Cosmetics as being affected by the recall. A quick Google search for GlitterSniffer Cosmetics shows that Aijuswhanakno's post regarding the Super 80's Collection appears 4th on the search list. Even given the benefit of the doubt that both of these bloggers Paypal receipts somehow went missing from GS records the information for at least one of them was readily and publicly available and very easy to find. These two instances, coupled with the other discrepancies with the information provided to FDA, beg the question what, if any, information provided to FDA by GlitterSniffer Cosmetics was correct.

It is speculation at this point as to whether these oversights in the information provided FDA were intentional. It could be that the company did not know how many recalled products were sold, or to whom, or where, or that they forgot they ever sold mascara, or that the Dearborn Heights Post Office was having another one of its GS related issues and lost every single recall letter the company sent out in early February. After all, in GlitterSniffer Cosmetics own Recall FAQ posted in January 2011 they stated unequivocally that they would comply with any request made by a federal agency.

Lets Play GlitterSniffer Cosmetics Connect the Dots

This post is a bit of a Mobius strip so please bear with me as post what amounts to a game of GlitterSniffer Cosmetics Connect the Dots.

Dot One: In December 2010 GlitterSniffer Cosmetics announced a recall of all pink pigments and those that were made using soap dyes. A preliminary list was drawn up which contained the 80's Collection. The 80's Collection was on the first and all subsequent lists, including the list provided to FDA, as per the March 23, 2011 Enforcement Report.

Dot Two: On January 9, 2011 GlitterSniffer Cosmetics posted the recall/refund information to their website, including the information that they had already been in contact with FDA.

Dot Three: According to the FDA Enforcement Report from March 23, 2011 GlitterSniffer Cosmetics stated they sent a letter to all of their customers informing them of the recall on or around February 7, 2011, copies of which were provided during FDA home visits to GS customers this month. Per Title 21 Subpart C Section 7.49 a recall communication must contain several items.

(a) General. A recalling firm is responsible for promptly notifying each of its affected direct accounts about the recall. The format, content, and extent of a recall communication should be commensurate with the hazard of the product being recalled and the strategy developed for that recall. In general terms, the purpose of a recall communication is to convey:
(1) That the product in question is subject to a recall.
(2) That further distribution or use of any remaining product should cease immediately.
(3) Where appropriate, that the direct account should in turn notify its customers who received the product about the recall.
(4) Instructions regarding what to do with the product.
(b) Implementation. A recall communication can be accomplished by telegrams, mailgrams, or first class letters conspicuously marked, preferably in bold red type, on the letter and the envelope:“drug[orfood, biologic,etc.]recall[orcorrection]”.The letter and the envelope should be also marked:“urgent”for class I and class II recalls and, when appropriate, for class III recalls. Telephone calls or other personal contacts should ordinarily be confirmed by one of the above methods and/or documented in an appropriate manner.
(c) Contents. (1) A recall communication should be written in accordance with the following guidelines:
(i) Be brief and to the point;
(ii) Identify clearly the product, size, lot number(s), code(s) or serial number(s) and any other pertinent descriptive information to enable accurate and immediate identification of the product;
(iii) Explain concisely the reason for the recall and the hazard involved, if any;
(iv) Provide specific instructions on what should be done with respect to the recalled products; and
(v) Provide a ready means for the recipient of the communication to report to the recalling firm whether it has any of the product, e.g., by sending a postage-paid, self-addressed postcard or by allowing the recipient to place a collect call to the recalling firm.
(2) The recall communication should not contain irrelevant qualifications, promotional materials, or any other statement that may detract from the message. Where necessary, followup communications should be sent to those who fail to respond to the initial recall communication.
(d) Responsibility of recipient. Consignees that receive a recall communication should immediately carry out the instructions set forth by the recalling firm and, where necessary, extend the recall to its consignees in accordance with paragraphs (b) and (c) of this section.

Dot Four: GlitterSniffer Cosmetics released the Chocolate Collection on or around February 8, 2011.

Dot Five: This screenshot, undated, shows GlitterSniffer Cosmetics facilitating a sale of product they personally recalled, the 80's Collection. It appears to be near the same date of February 8, 2011 as the exact same announcement regarding the Chocolate Collection is seen posted just below it.

Connect all the Dots and here is the picture that is formed: GlitterSniffer Cosmetics knew that the 80's Collection was recalled in December of 2010, spoke with FDA in January 2011,  provided FDA with a recall letter prior to February 7, 2011 that had to, by law, state that further distribution of the recalled product should cease immediately, and yet on or around February 8, 2011 attempted to facilitate the sale of the recalled 80's Collection knowing that this violated not only the terms of the recall letter but FDA regulations regarding a firm initiated recall.

The company can spew semantics all they wish regarding the business decisions prior to the recall (Quote from the Recall FAQ: "I have had no issues with the pigments, and in turn assumed that other people would not either."). What is not debatable at this point is that the company knew they were violating Title 21 by facilitating the sale of recalled product and yet chose to do so anyway, possibly putting at risk uninformed consumers and those selling the recalled product with the company's assistance. That's not a pretty picture to end up with for the company, their customers or for those they attempted to assist in violation of federal regulation.

I will be following up with FDA to provide them with this information.

5/17/11 ETA: Corrected year in the third to last paragraph from January 2010 to January 2011.

GlitterSniffer Cosmetics and the Recall/Refund Process-A Total

Within the past 48 hours at least one refund was issued to a GlitterSniffer Cosmetics customer that had unreceived/incorrect orders since the switch to Google Checkout, an issue unrelated to the December recall. This refund was requested by the customer and unlike several others issued by Google Checkout was issued by the company themselves. Information has been scant as to exactly how many refunds GS has issued for matters related to the December recall and previous missing orders.

I was sent a document today by Daphney, an ex-Admin for the Fan Page, which outlines exactly how much, as of January 18, 2011, GlitterSniffer Cosmetics owed for recalled product sent back to the company and unreceived orders/money owed to other Artisans for products created for GS to sell on their site but for which payment was never rendered. I am publishing that information now with permission but not the entire file as it contains personally identifying information.

In all there are 42 names on the list as being owed a refund by GlitterSniffer Cosmetics as of 1/18/11. They range from $448.00 at the highest to $6.50 at the lowest. Some have a tracking number attached and two of them are confirmed as being received by the company. The total amount owed in refunds as of 1/18/11 is $4,011.96. This total does not include all Paypal claims/money requests (confirmed by the fact that my name appears nowhere on the list), recalls not sent back to the company, or anything past January 18, 2011.

I have confirmed with Daphney that as of 4/21/11 I am the only person who received a refund from GlitterSniffer Cosmetics for issues related to the recall. I was refunded $21.50. Daphney issued my refund personally from the second GS Paypal account, out of order and at Lela Warren's insistence, despite my request not meeting any of the terms of the recall to qualify for a refund.

At this point there is no firm number as to how much GS now owes for refunds related to the recall as the information provided to me is several months old, but it does illustrate that although the company had access to their second Paypal account as late as January 28,2011 and the means and money to refund at least some of the claims made prior to mine (there were two for $6.50 which could have easily been paid out had my $21.50 refund not been issued on January 16, 2011, a refund issued despite my request that I be refunded in the order in which my claim was received) they simply chose not to do so.

By no means do I wish to sound dismissive of my refund, but let's get down to brass tacks. It was undeserved in terms of the refund/recall process. I have always been upfront about my request being about concerns about formulation and packaging. Nothing I had was on the recall list. I did not send my items back. My refund served no other purpose than to be published for all to see. That people are still waiting while I have my refund is but another in a long line of self serving choices the company has made, from using unapproved ingredients to make more sales to refusing to remit funds for charities and product created specifically for the company to using the cash infusion from the December investor to start sales again instead of issuing any refunds due. That the company is now issuing refunds to new customers who are ex-Admins and who are being outspoken about the company only further shows that the company has not changed much, if at all.

I'd like to thank Daphney for providing this information. As someone who was very much involved, though not employed, by GS during the time in question she has first hand knowledge that may help put the pieces together as to what exactly happened.

GlitterSniffer Cosmetics Issues a Refund and the FDA is Still Calling Customers

While the GlitterSniffer Cosmetics story had appeared to be winding down, with the Fan Page still down, Google Checkout no longer processing payments, the FDA Investigation, the shutdown of the private fan group, and Lela refusing any and all attempts at communication, there were some new developments today.

GS issued at least one refund. The refund was through Google Checkout and it was for unshipped product to a newer customer who only began purchasing after the recall. Unlike previous emails Google Checkout has sent stating they issued the refund this one was clearly issued by GS.

 

The refund was issued to one of the private group Admins who stepped down earlier this week and publicly retracted her support of GS. This refund was completely unrelated to the recall in December. To date, as near as can be determined, the only refund for items related to the recall that has been issued by GlitterSniffer Cosmetics (and not by credit card companies, banks, or Paypal themselves) was mine, which met NONE of the terms for refund as it relates to the recall (I shipped no product back and none of my items were officially recalled. I asked for a refund for my full purchase price after concerns regarding formulation and sanitation). It was for $21.50.

The details are scant about the contact with yet another GS customer by the FDA. The contact was made by phone and was related to the recall. I'm hoping to get more information and supporting documentation on this call soon and will present it once I do.

These new developments serve to show that there may still be a need for further followup on GlitterSniffer Cosmetics. The company is nothing if not tenacious. Though proprietor Lela Warren had seemingly been shifting her focus elsewhere, to modeling, makeup artist school, and her new job in the food service industry, the refund indicates the company might be trying to recover by making things right, at least with newer customers. There is no indication that previous customers who sent in their recalled product or were affected by the recall can expect to receive the refunds due to them, especially now that Google Checkout will no longer process payments for GS, and the company has refused thus far to issue company checks or bank issued money orders via certified mail.

I will continue to update as new information  becomes available.

*On a side note, I'd like to apologize for the brief pause in posting. I am very much a night owl. Blogger has been having issues lately, and has been down for maintenance during the hours I usually post. Unfortunately I cannot work on the blog during work hours, even at lunch, as per Corporate Security, ever since Lela used my personally identifying information, obtained through my one purchase of GlitterSniffer Cosmetics and intended for sole use during that sale, to email me at work.  Hopefully Blogger has worked their issues out and I can get some posts up over the next few days. If not, I'll be moving the blog to WordPress. I appreciate your understanding.

5/14/11 ETA: Update tags to include GlitterSniffer Cosmetics.

The GlitterSniffer Cosmetics Private Facebook Group and Further FDA Followup

It was announced today that the GlitterSniffer Cosmetics Private Facebook Group will be shutting down permanently as of the end of this week.

The group was originally created as a place for like minded fans to gather that was "GS friendly". The free samples that began arriving in March where an incentive given to fans by GS for joining the group. There have been many Admins over time, some of whom stepped down in late February and shared their stories. Yesterday, after reading Issanna's story, the final three of these Admins stepped down. A link to the blog was posted for all GS private group members to review, GS proprietor Lela Warren was removed as an Admin, and another group was created for the fans to have a place to discuss their love of all things makeup.

In the last few weeks there has been lots of activity surrounding GS: the removal of the GS Fan page by Lela, loss of Google Checkout as a payment option, mass refunds by Google Checkout for unreceived or incorrect orders, the FDA home visits, and now the closure of the private group. Lela has maintained a steady silence through it all, ignoring GS questions on her personal Facebook and refusing to respond to emails and phone calls. Today several people were deleted from her personal Facebook and her wall was closed to comments.

Another GS customer was contacted by the FDA via a phone call on 5/9/11:

It was a fairly short phone call, he told me it was for the pinks and listed the size of the pots, I can't recall what size he said they were.  He asked if I received a letter in the mail, which I did not and he listed my home address to make sure they had it right and made a note that I only knew of the recall because of facebook.

That makes four known contacts of GS customers by the FDA across the country in less than a week. There is no specific timeline for how long an investigation like this lasts, though hopefully there should be a result soon. If a warning letter is sent to GS I plan on filing a Freedom of Information Act request in order to follow up. FDA does not comment on current investigations.

Where does that leave GlitterSniffer Cosmetics? To be perfectly honest I'm not quite sure. After the recall it seemed that GS would have to cease operations, but then a cash infusion from a private investor allowed them to continue. When Paypal closed their multiple accounts in January Google Checkout and Artfire were there to pick up the slack. GS has a history of rising from the ashes, but it is unknown at this time if this situation is recoverable. Lela is certainly not being forthcoming about it. With the lack of a formal closure announcement and the ongoing FDA investigation it seems prudent at this point to take a wait and see approach. There are still stories to tell and the matter of GlitterSniffer Bath has yet to be addressed. Look for a post on that soon.

I will update as more information becomes available.

GlitterSniffer Cosmetics Recall and the FDA Investigation-NYC

Another day, another visit from the FDA to a GlitterSniffer Cosmetics customer, this time in New York City. The recall letter was also shown during this visit as well.

 She gave me her business card and a copy of a letter that GS allegedly mailed to all there customers. I explained to her my brief experience with GS and what I have heard from others. I told her that my jars were not labeled, I had only placed one order back in 12/10, all randoms. I told the lady all the horror stories I've heard. I showed her the pigments I have. She said not to even bother using them as nail polish. The lady said they were randomly selecting customers from a list of everyone who has ordered GS.

The FDA Enforcement Report about the GS recall classifies it as Class II recall:

Class II recall: a situation in which use of or exposure to a violative product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.

According to Title 21: Section 7.40 there is a notification process that must be followed in a firm initiated recall situation. 

(a) General. A recalling firm is responsible for promptly notifying each of its affected direct accounts about the recall. The format, content, and extent of a recall communication should be commensurate with the hazard of the product being recalled and the strategy developed for that recall. In general terms, the purpose of a recall communication is to convey:
(1) That the product in question is subject to a recall.
(2) That further distribution or use of any remaining product should cease immediately.
(3) Where appropriate, that the direct account should in turn notify its customers who received the product about the recall.
(4) Instructions regarding what to do with the product.
(b) Implementation. A recall communication can be accomplished by telegrams, mailgrams, or first class letters conspicuously marked, preferably in bold red type, on the letter and the envelope:“drug[orfood, biologic,etc.]recall[orcorrection]”.The letter and the envelope should be also marked:“urgent”for class I and class II recalls and, when appropriate, for class III recalls. Telephone calls or other personal contacts should ordinarily be confirmed by one of the above methods and/or documented in an appropriate manner.
(c) Contents. (1) A recall communication should be written in accordance with the following guidelines:
(i) Be brief and to the point;
(ii) Identify clearly the product, size, lot number(s), code(s) or serial number(s) and any other pertinent descriptive information to enable accurate and immediate identification of the product;
(iii) Explain concisely the reason for the recall and the hazard involved, if any;
(iv) Provide specific instructions on what should be done with respect to the recalled products; and
(v) Provide a ready means for the recipient of the communication to report to the recalling firm whether it has any of the product, e.g., by sending a postage-paid, self-addressed postcard or by allowing the recipient to place a collect call to the recalling firm.
(2) The recall communication should not contain irrelevant qualifications, promotional materials, or any other statement that may detract from the message. Where necessary, followup communications should be sent to those who fail to respond to the initial recall communication.
(d) Responsibility of recipient. Consignees that receive a recall communication should immediately carry out the instructions set forth by the recalling firm and, where necessary, extend the recall to its consignees in accordance with paragraphs (b) and (c) of this section.

As an affected customer I can unequivocally state that I have never received a letter, mailgram, or telegram from the company about the recall. To date, not a single customer of GlitterSniffer Cosmetcis has come forward to verify that they received the notification from GS about the recall., despite the company's assertion to the FDA that the letters were sent on or about February 7, 2011.

The FDA's role in a firm initiated recall is to monitor compliance with the terms of the recall. It is not clear what actions, if any, the FDA will take if GlitterSniffer Cosmetics does not follow the outlined recall protocol, though Subpart C 7.40 does indicate that some further measures can be taken, including seizure, multiple seizure, or other court action when it is determined the recall is ineffective.

There is also Subpart E, a section covering Criminal Violations, but it is blank.

The FDA did update the Regulatory Procedures Manual this year, in particular The Park Doctrine. An explanation of The Park Doctrine, as outlined in the manual:

The Park Doctrine, as established by Supreme Court case law, provides that a responsible corporate official can be held liable for a first time misdemeanor (and possible subsequent felony) under the Federal Food, Drug, and Cosmetic Act (“the Act”) without proof that the corporate official acted with intent or even negligence, and even if such corporate official did not have any actual knowledge of, or participation in, the specific offense. A Park Doctrine prosecution...refers to a recommended prosecution of a responsible corporate official for a misdemeanor violation of the Act....Once a person has been convicted of a misdemeanor under the Act, any subsequent violation of the Act is a felony, even without proof that the defendant acted with the intent to defraud or mislead...In some cases, a misdemeanor conviction of an individual may serve as the basis for debarment by FDA.

 It should be noted that the FDA does not routinely recommend such cases for prosecution without consideration of other factors:

1. Whether the violation involves actual or potential harm to the public;
2. Whether the violation is obvious;
3. Whether the violation reflects a pattern of illegal behavior and/or failure to heed prior warnings;
4. Whether the violation is widespread;
5. Whether the violation is serious;
6. The quality of the legal and factual support for the proposed prosecution; and
7. Whether the proposed prosecution is a prudent use of agency resources.

This is but one possible outcome of the current FDA investigation. At this point there is no clear indication that GlitterSniffer Cosmetics proprietor Lela Warren should or will be recommended for prosecution. The FDA could conclude that GS needs to simply send out the letters and continue on with no repercussion. Only time will tell what, if any, consequences the company will have to deal with pending the outcome of the FDA investigation.

GlitterSniffer Cosmetics Recall and the FDA Investigation

On March 23, 2011 the FDA released its enforcement report detailing the information provided to the agency regarding the recall by GlitterSniffer Cosmetics. As previously posted, there were concerns regarding that information, including questions about the letter notifications reportedly sent on or around February 7, 2011 to GS customers, the amount of recalled product that had been distributed, and the mascara that was also not approved that was not included in the recall. I contacted the FDA Office of the Ombudsman on April 20, 2011 to address these concerns and received a reply that the issue would be escalated.

On May 3, 2011 a poster to the Facebook page asked if anyone had been visited by the FDA regarding GlitterSniffer Cosmetics. The poster had a home visit from an FDA agent who was investigating the recall. Here is her story:

Yesterday a representative from the FDA showed up on my doorstep to interview me concerning the GS recall. I've never filed any complaints with any agencies, the only thing I ever did was contact Lela when word of the recall broke out. I was shown a badge and plus I got a card and contact number. He specifically stated he needed to interview me "concerning products I received from Glittersniffer Cosmetics".

He gave me a list of all the product that had been recalled and a photo of what the packaging looks like.

This is what he asked me:
How many items did I purchase from GS. 
How many items were included in the recall.
When did notification of the recall go out.
Did I know of any side effects due to use of the makeup, did I have any reactions.
Did I or anybody I know distribute ANY GS makeup.
My answers
I had close to 50 items
10 were part of the recall
I never received an email or message from GS, it was posted on the website and FB page. I learned about the recall probably the last week of November/first week of December.
I heard of people having reactions but I never had any.
I never distributed any GS makeup, and I got rid of any makeup that I owned that was a part of the recall.

He said they were interviewing people that were local to FDA offices concerning the recall. From what he could tell me they were following up and making sure people had been notified.

Below are photos of the business card and documents left with the poster. As has always been my practice I have removed personally identifying information from the business card as it identifies the agent by name along with contact information. It was a decision I struggled with but as he has not given me specific permission to release this information publicly I feel it best to err on the side of caution. I will state that research indicates he is indeed a Consumer Safety Officer with the FDA in California.

Detail from the packaging document

On May 4, 2011 a second GS customer was visited by the same FDA agent. Her story, edited to remove PII:

Basically he knocked on the door and said he had some questions about the glittersniffer recall. He showed me a recall letter and asked if I got one, I said no. I told him I seen it posted on her website though He asked how many I owned, I said around 230 GASP, he asked if I still had them, I said no. Some were dumped and some were sent to someone else. He asked if I had any reactions, I explained to him the blurred vision I experienced while using GS but wasnt sure if it was the makeup or migranes. He said he was there just to gather information about if GS followed the recall protocol. I told him the list of recalled pigments (the pinks) were not all that should be on there. ALL of them should be on there as she packed and made pigment in unsanitary conditions. He also said I should email him any information and gave me his direct number and email address. He also said they are randomly checking people and their information. redacted took a picture of me and him talking LOL. So I do plan to email him with any and all info that GS is still operating etc. His main concern was IF I had received the recall letter. I told him I never got one in the mail and am pretty sure did not get it through email either.

The Agent and the GS Customer

 

The second poster has offered to forward any information anyone may have to the agent. In my haste to publish I did not get her permission to release her contact information or name. If you have information germane to the GS situation that you would like forwarded to the FDA you may contact me at glittersniffercomplaints@gmail.com. Should I get permission to release her contact information I will update.

It's unknown at this point if this was a followup to the escalation I filed or if this is a routine followup by the FDA. The focus does seem to be on the handling of the recall by GS, specifically the letter that was supposed to have been sent to customers on or around February 7, 2011. 

There has been no indication that GlitterSnifferGlitterSniffer Cosmetics has been contacted again by the FDA.  We know that GS had to provide contact information for all of their past and current customers and it seems that this information is being used by the FDA to contact customers located near field offices about the recall notification. A complete list of FDA field offices may be located here.

I will continue to follow up as more information becomes available. Thank you to the two posters for sharing.

5/5/11 ETA: Completed the second to last paragraph, which disappeared in between my writing the post and publishing it.  My apologies for not catching this prior to publishing.

Buyer Beware: The Conservatorie Followup

The Conservatorie sent out a mass email today and updated their Facebook page addressing concern about their warranty statement and the mislabeling issue. I was forwarded the email by several people and am publishing it in full, edited only to remove personally identifying information of the recipient and the direct link to The Conservatorie site.

Date: Wed, 4 May 2011 03:07:40 -0500
To: redacted
Subject: Product Warranties and Mislabeling
From: info@theconservatorie.com

Date:  May 4, 2011
From:  Katie Voquy (Owner- The Conservatorie, Inc)
To:  The Conservatorie community

There have been some questions lately about a policy specifying that our products are sold for personal use only.  We have never stated that it is for “personal use only” anywhere on www.theconservatorie.com.  We have and have always stated that “The information contained in this website is for general information purposes only. Although the information at this website is presented in good faith and believed to be correct, The Conservatorie makes no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Use of this site and the information therein is at the user's sole risk”. 

We make no warranties on products not produced directly by The Conservatorie for this reason:
Any product ordered direct from a manufacturer is always accompanied with a Certificate of Analysis, as required by the FDA.  Once we open that batch to break down into smaller, more manageable sizes for our customers, that certificate is no longer valid, and can only be warrantied if it is recertified by an independent lab – a cost prohibitive option for those who are purchasing a few ounces of an item.  Because we are selling you a product without a valid Certificate of Analysis, we cannot warranty the ingredient; should you use for resale, we will not be held liable should there ever be an issue with a product you’ve created.  For those who do want a Certificate of Analysis and backed with our warranty, these can be provided for an extra charge to cover the re-certification with a minimum purchase of 500 grams. 

We will be happy to provide the MSDS for any product we sell upon request.  If you’re unsure if a particular ingredient is the same as another from another company, please feel free to ask - we will be happy to provide you with the name of the supplier and any corresponding trademarked name to prevent you from accidentally ordering duplicates.

Any product produced by The Conservatorie (including private label) in our lab is certified and is 100% warrantied with no fee for the certification on purchases of 500 grams or more. Products directly manufactured by us will be marked as a “TC Exclusive” product.  You may buy any “TC Exclusive” material with the assurance that they are covered by guarantees and warranties without having to pay for a recertification fee.

Lastly, we apologize for the delay in making the public aware of the changes we made in the information provided on our labels and on our website.  This delay is partly due to the time-consuming process in obtaining the correct information before sharing them to our customers and the public.  With assistance of information obtained from the FDA, we will address the rules and regulations in the latter portion of this response.  To set the records straight, all product information prior to Oct 2010 and after March 20, 2011 are, in fact, correct.  Since Oct 2010, we have switched suppliers and have been updating our website to reflect that.  Along the way, we have failed to keep our product information and labeling updated.  We understand that this has had negative effects to our customers’ businesses, and we sincerely apologize.  We have taken corrective measures to share this burden with our customers, and for those that have contacted us, we have either refunded or replaced the items in question.  For those who have purchased any mislabeled product(s) from The Conservatorie between October 2010 and March 2011, we will be glad to work with you.  Please contact our customer service department during working hours (8 am – 5 pm, PST) Monday to Friday at 1-877- 998-2462 for assistance.
Best Regards,

Katie Voquy
Owner & CEO
The Conservatorie, Inc
10955 Arrow Route Suite 103
Rancho Cucamonga, CA 91730
(909) 989-1888
http://theconservatorie.com/
http://www.facebook.com/theconservatorie
http://twitter.com/ConservatorieCo

To be unsubscribe click here :

redacted

Thank you

Please note that as of the publication of this post this announcement is nowhere to be found on The Conservatorie site.

While it is admirable that The Conservatorie is now being forthcoming regarding the mislabeling issue, as someone who was personally affected by both of these recalls as a consumer I can tell you that the information they are now releasing is not altogether correct.

The RockABetty Beauty recall occurred on or around January 19, 2011. That was the date I personally contacted RABB regarding some of my shades with glitter after seeing the recall notice. At that point TC had already been in contact with RABB and indicated that these glitters were not eye approved, despite being sold as such, which resulted in the RABB recall. In the case of the glitter TC knew the product was mislabeled three months ago but did not make anyone aware about the glitters safe use. As the company was demonstrably aware there was an issue with the use of the glitters to the point that the site was updated with that information there should have been no delay in notification. The company knew and their customers should have been informed in a much more timely manner.

The Morgana Cryptoria lipstick recall occurred on 3/17/2011. The issues with mislabeling that impacted MC were that the ingredients that were sold were either not safe for lip use in the United States, or were not vegan. As these products were sold as vegan lipsticks the labeling change had a detrimental effect on the business, causing the recall of nine shades of lipstick. When these ingredients were originally purchased carmine, chromium oxide green, and ferric ferrocyanide were not listed by The Conservatorie. It was only due to the diligence of MC in researching prior to reordering that the formulator discovered the change. These changes were on the TC site at least a month and a half ago but again, no effort was made to announce the change on their site (except to update the product excel sheet) or via contact with their customers until today.

Additionally, there is this:

We have taken corrective measures to share this burden with our customers, and for those that have contacted us, we have either refunded or replaced the items in question.

Though The Conservatorie initially worked with Morgana Cryptoria a refund request as it relates to the mislabeling issue made a few weeks ago was denied, citing the "at your own risk" policies shown in the email sent today.This refund denial runs counter to TC assertion today that they have either refunded or replaced the items.

I cannot speak as to the personal use issue. As stated in my previous post there was no official word as to why The Conservatorie did not make these changes more readily accessible to the public.

In sum, while it appears The Conservatorie is making strides in correcting the mislabeling issue, at least in terms of publicity, it can be shown that they were well aware of the issue at least three months ago and that whatever delay in announcing it today was not due to obtaining the correct information, as they had updated their site with that information during that period. The company knew, made the changes, but did nothing to notify their customers so they could make an informed decision until it was announced publicly by a third party. Even then it took The Conservatorie sixteen days to formulate this announcement, an announcement that is still not listed on their site, and, as in the case of Morgana Cryptoria, the information regarding refunds and replacement is not correct.

5/5/11 ETA: I published in this post that the mislabeling issue was addressed on 5/4/11 via email and The Conservatorie Facebook page. I was remiss in posting this information. The mislabeling issue was not addressed or announced on the Facebook page. It is still not currently on The Conservatorie site either. The only announcement of the mislabeling issue was via email.

FDA Dispute Resolution-Followup

Two hours after my email to the FDA Office of the Ombudsman regarding the escalation of my complaint about the March 23 FDA Enforcement Report and the information within it I received a reply.

My concerns have been forwarded to the Compliance Division of the FDA Center for Food Safety and Applied Nutrition, the FDA regulatory arm for cosmetics.

I will update as more information becomes available.

FDA Dispute Resolution

I emailed the FDA Office of the Ombudsman  at ombuds@oc.fda.gov to escalate my FDA complaint in regards to the March 23 FDA Enforcement Report and the information it contained.

According to the FDA site the Office of the Ombudsman is for dispute resolution:

The Office of the Ombudsman is a resource for individuals and for companies when they are experiencing problems with the regulatory process or with the application of FDA policies or procedures. The Office of the Ombudsman provides assistance if there are problems or concerns that are not being addressed, or cannot be addressed, at the center or district level, or when there are concerns about raising an issue at that level. If requested, confidentiality will be maintained by the Office of the Ombudsman to the greatest extent possible.

I outlined my concerns about the information provided to the FDA about the recall, including the communication of the recall by the company and the possibility that the reach exceeds the 500 units in commerce that was reported to the FDA. I included a link to the post with supporting information and I identified myself by name.

There is no clear turnaround time for response, but I plan to make a follow up call in a week to (301) 796-8530 if I have not heard back about my concerns with the handling/reporting of the GlitterSniffer Cosmetics recall.

Buyer Beware: The Conservatorie

**I would like to make it unequivocally clear that I have no knowledge that GlitterSniffer Cosmetics ever purchased from The Conservatorie. This post is about an ingredient supplier and it's effect on several MMU companies and is being posted for informational purposes as The Conservatorie has not made the information public. If you are a formulator or a person who purchased from The Conservatorie for personal use please take a moment to check your ingredients. Though the company is not publicly releasing this information there is a chance that what you have been sold may not be used for what you intended.**

Over the last few months safety of Indie MMU has been in the spotlight. I am very cognizant of the fact that there are people who are now shying away from Indie makeup due in part to this blog. This is very unfortunate, as most Indie MMU sellers are safe and put out amazing, unique products, and, for the most part, this blog is here to illustrate the business practices of one company. GlitterSniffer Cosmetics is not representative of Indie MMU as a whole. Most Indie MMU companies take safety seriously and the health of their customers is their first concern.

Recently two of these companies were faced with the unfortunate task of recalling products. RockABetty Beauty and Morgana Cryptoria initiated recalls after discovering that their ingredient supplier The Conservatorie (first link on the google search) had changed their ingredient information and what they had previously purchased as either eye or lip safe or vegan was, in actuality, not.

In the case of RABB the company responded to customer concerns about glitter fallout by checking the ingredients on The Conservatorie site, only to find that the listings had changed and none of the glitter they had purchased was eye safe. The company immediately pulled all of their shades containing glitter and posted about the recall. They offered several options to their customers, including reformulated shades, trades for other shades, refund, or store credit. They then followed through on all their commitments.

Morgana Cryptoria discovered the ingredient changes in their own research. As a matter of course they research ingredients even if they have previously purchased them. As soon as the company realized the ingredients had been changed they issued a recall on some of their lipsticks, offering store credit, refund, or exchange. In all nine shades were recalled, some as containing carmine (the lipsticks were sold as vegan) and some not approved for lip use in the US as they contained Chromium Oxide Green or Ferric Ferrocyanide. Morgana Cryptoria has also followed through on their commitments.

A third company, whose line has yet to be launched, has had to reformulate at least 4 shades as they contain carmine, an ingredient change that affects this particular company as they will sell strictly vegan product. Due to issues with the INCI listing on The Conservatorie site they may have to reformulate several more.

There has been no effort on the part of The Conservatorie to notify customers that they changed their ingredients. Had it not been for the diligence of the above mentioned formulators the issue would still be unknown.

There was another change to The Conservatorie site as well. If you click the first link in the google search linked here, scroll to the bottom, and click on the Policies link you can read the suppliers' revised policy. This policy is what prevents me from linking directly to the site. Another change is that it, in effect, releases the company from any liability whatsoever. It states that they do not guarantee that any of their information is correct and that everything on the site is used 'at your own risk'.The company has made an all out effort to protect themselves, but no effort to communicate the ingredients changes to their customers.

At this time there is no official word as to why The Conservatorie has not made public these changes which have already resulted in 2 recalls. All three of the formulators I've written about in this post have been in contact with the company and they are aware that the changes have resulted in recalls and reformulation.

So what changes were made? Some of their products are now listed as containing carmine, Ferric Ferrocyanide, Chromium Green Oxide, and Chromium Hydroxy Green. Some glitters, previously listed as eye safe, are no longer listed as eye safe. You can review their updated ingredients list by accessing any of their micas and clicking on the Info Chart, which opens a PDF. Below I will post screenshots of Google cached versions of some of their affected previous ingredients for comparison.

A note about Chromium Green Oxide and Chromium Hydroxy Green as The Conservatorie now has them listed. It seems that The Conservatorie is referring to Chromium Oxide Green and Chromium Hydroxide Green, neither of which are lip safe. Even with the updated list the ingredients are not correctly listed. These names are not INCI compliant. Anyone going off this list to label would still be labeling incorrectly as the INCI is incorrect. As per the FDA ingredients on cosmetics must be listed in descending order of predominance by INCI. The correct INCI for these are Chromium Oxide Green (CI 77288) and Chromium Hydroxide Green (CI 77289).

Here are the screenshots for the previous ingredients for some of the affected ingredients, as of 3/7/11 per Google cache.

And from The Conservatorie Twitter, dated 2/3, an answer about the safe use of their glitters:

I present this information for a couple of reasons. As consumers we have a right to know that what we are purchasing, be it from a commercial cosmetics company, an Indie company, or a supplier is what it claims to be. The Conservatorie is not being forthcoming and the extent of the reach of these ingredients is unknown. These recalls do not lie at the feet of the Indie MMU companies who purchased these ingredients and people should know that. I also wanted to show that not all recalls have to be handled in the manner that GS' is.

I would like to thank RockABetty Beauty and Morgana Cryptoria not only for their permission to publish, but for the manner in which their recalls were handled. They could have easily pulled their products and reformulated, but they did not. They researched and did what was best for their customers. Both companies were transparent and apologetic. Though unfortunate, the recalls for these companies only serve to illustrate that diligence in research, concern for the customer, and simply doing what is right goes much farther than the fact that a product had to be recalled ever could. That both companies stepped up to the plate, not only in terms of their recalls, but in answering my inquiries and wanting first and foremost for others to be informed by this publication speaks volumes. It is a horrible situation to be in, but both handled it with grace and a business acumen geared toward the customer.

Again, if you purchased from The Conservatorie please check your ingredients. Be Safe. Be informed. Be well.

GlitterSniffer Cosmetics and the FDA Enforcement Report

On March 23, 2011 The Food and Drug Administration released their Enforcement Report. Included in the Enforcement Report was the recall by GlitterSniffer Cosmetics. The report states the facts that were provided to the FDA by GlitterSniffer Cosmetics regarding the recall, including the recall list, number of products, and notification methods.

FDA Enforcement Report, March 23, 2011

In looking at the report it appears that there may be some issues with the information.

The recall list shows everything that has been officially recalled by the company and the stated reason is thus:

The firm is recalling products which contain ingredients that are not approved for use around the eye.

If this is the case then where are the pink and green mascara on the list?

 
By the company's own admission neither of these products is eye approved, yet these products were omitted from the recall and the information provided to the FDA.

The FDA was also informed this in terms of distribution:

VOLUME OF PRODUCT IN COMMERCE
500 units

A rough accounting, gathered from the GS Complaints Facebook page, Twitter, and email is 1269 pots of recalled pigment. That number is a rough estimate of official recalls, posted by people who saw the message in 18 hours, who felt comfortable sharing. When a non specific number was given (such as 20+) it was rounded down.

This could be easily dismissed as speculation, because there is no solid proof that the amount people state they had is indeed what was dispensed to the public by GlitterSniffer Cosmetics.

Here is just one photo of the roughly 600 pots of recalled product sent home with an Ex-GS Admin in late January/early February.

It should be noted that this alone represents more recalled product than was disclosed to the FDA by GlitterSniffer Cosmetics, and there are still many people who either traded, sold, used, or simply disposed of their recalled product. Suffice to say the estimate given to the FDA by GlitterSniffer Cosmetics appears to be incorrect.

Additionally, the FDA was told that letters were sent out as of February 7, 2011 regarding the recall. As of the writing of this post, not a single person who responded has received a communication via letter about the recall from GlitterSniffer Cosmetics.

Here is what has started arriving in late March instead: Free, postage paid samples given to new fans of GlitterSniffer Cosmetics.

It would seem that once again, GlitterSniffer Cosmetics is not following up on its commitments not only to its customers regarding the recall process, but to the FDA as well.