I won't speak to how the EU made their decision, but our assessment was a risk-based assessment that looked at environmental exposure and effects for bees. It followed the new pollinator risk assessment framework that we had developed in conjunction with the U.S. EPA, so it has a large data component.
We looked at both laboratory and basic studies, but we also had many higher-tier studies. We looked at information from the public literature, as well as some registrant-submitted data. The higher-tier studies look at more realistic effects, so we had information on pollen and nectar residues in crops that were treated in Canada—the actual levels measured. We had semi-field studies, so that included tunnel studies where you put bees in a tunnel and they're exposed in a realistic situation to crops that are treated. We had feeding studies where, again, they're in a natural environment and they are exposed through a known concentration in their feeding solution to different test doses of neonics, and we looked for sensitive effects measures on that. The studies were over a long exposure period, so it was over a long, six-week exposure period, which is a lot of the growing season, and then they continued to be monitored through the fall and through overwintering, and we looked at the colony health in the spring as well.
We had all of that information. We also had sensitive information from public literature looking at other types of bees, such as bumblebees, and used all of those effects measured.
In 2019, as you know, we published our final decision on that. We removed a lot of uses for high pollinator-attractive crops to protect bees. We put other mitigations in place, such as restricting the timing of application so you could not apply during bloom for many pollinator-attractive crops, and other restrictions, such as some pollinator-attractive crops you could only apply postbloom.
We put all of those mitigations in place to protect bees, and we kept registered products with mitigation in place where risk was acceptable.
The difference with the EU was that they have different uses and things as well, but they did not necessarily have the same pollinator residue levels in pollen and nectar that we had in North America from those crops. To my knowledge, they did not look at the same field-level studies. That's the long study that I described with feeding. They did not have that as part of their package when they considered their risk profile.