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90 SMT Magazine • February 2014 ance plan? Is it entrenched in our quality man- agement system? What quality and counter- feit avoidance requirements do we flow down to our suppliers? Are our suppliers capable of meeting these requirements, and if so, how do I know? How do our vendors manage their sup- ply chain? Do they send out supplier surveys? Programs that are considered "life critical" should specifically address these questions, and businesses should be focusing on integrat- ing their counterfeit avoidance plans into their quality management system to secure their supply chains and protect their business from counterfeit components. This issue is no lon- ger a matter of ethics. The laws are changing and those organizations that refuse to accept the realities of the current global supply chain are exposing their companies to unquantifiable economic loss and liability. So how did all of this happen? e-Waste and recycling: Part of the Problem Many of us think of recycling and reusing as the right thing to do. We set our recycling bins next to our garbage cans, and we think that everything is going to end up in gleamingly clean, green-efficient buildings, where different products are separated and then recycled into clean and refurbished products, right? Well, not all the time. Ethical recyclers should be certi- fied to ensure they will properly dispose of the toxic ingredients in discarded computers, print- ers, mobile devices, and other systems, to gain the valuable precious metals they contain with little environmental harm. Unfortunately, not everyone is ethical and not everyone is properly recycling. For example, consumers using e-recy- clers who are certified to the E-Stewards Certifi- cation, can have confidence that they practice due diligence. By utilizing a certified e-recycler one can be assured they are not inadvertently providing e-waste to an organization that could potentially pollute the supply chain and con- tribute to the counterfeit epidemic. Why use a certified e-waste recycler? On November 8, 2011, the Senate Armed Services Committee held a hearing on the heels of an investigation into counterfeit electronic parts in the defense supply chain. The investi- gation revealed alarming facts, including that materials used to make counterfeit electronic parts often come from e-waste, shipped from industrialized countries like the United States to countries like China or India. The e-waste is sent to these countries by the ton where it gathers into mounds for process- ing, to be reintroduced back into the supply chain. Each time electronic e-waste is submit- ted to a recycling company that is not certified to properly dispose of those components, they are potentially polluting their supply chain. It increases the likelihood that those components could be used to fuel the counterfeit epidemic. The Gray Market: the What, Why and Who What is the gray market? Manufactur- ers turn to the gray market when the original component manufacturer or their authorized distributors cannot supply the product needed or the lead time is unmanageable. Gray mar- ket companies are typically distributors or bro- kers that are not bound by contracts from the original manufacturer. They have the ability to search for and procure any product from any source of supply, at any time. These companies often use the internet to find the lowest priced stock—not always placing a priority on quality and authenticity. Therefore, whenever parts or KrAMEr oN CoUNTErFEITS Figure 2: Individuals and companies must be responsible for e-waste disposal. THe COuNTerFeIT ePIDeMIC THaT CaN KILL continues