eceee's comments on the self-regulatory initiative (SRI) for medical imaging equipment

(17 Nov 09) In the light of relatively low aggregate energy consumption of medical imaging equipment, and the importance to safeguard the primary function of these products, eceee welcomes the self-regulatory initiative as a good intention to contribute to energy efficient product development.

However, eceee has a few additional specific comments:

• Would it be possible to introduce SRI:s for the other modalities at a faster pace than the proposal suggests?
• COCIR:s intention is to start with ultrasound products in 2009. Targets for this modality have been set to 6% reduction in energy consumption for new ultrasound products placed on the market between 2010 and 2012.  According to the proposal, this corresponds to a reduction of 25% compared to 2005. The target of 6% appears to be modest, but without a reference to best available technology (BAT) or a definition of an index, it is not possible to assess the ambition level of the proposal. The answer also depends on whether this is an average for the industry, or an average for each manufacturer.
• Medical imaging equipment is often operated in a system with other standardised products, such as displays and computers.  It is important that ambitious and well-defined targets be set and maintained for those standardised energy-consuming products, to ensure that all medical equipment will benefit from advances made in these areas.
• eceee believes that the stand-by energy consumption of these products may be an important aspect of their total energy consumption. The possibility to reduce stand-by consumption while ensuring rapid reactivation should be investigated.
  

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