As mentioned, we put a new risk assessment framework in place in 2014, and we developed that jointly with the U.S. EPA and the California Department of Pesticide Regulation.
That risk assessment is done for all pesticides that would be used where there would be bee exposure. That means all outdoor-use pesticides as well as greenhouse-use pesticides. We use the framework for every type of pesticide.
We have an initial screening-level risk assessment, for which we now require more robust data. It includes a number of laboratory studies for adult and larval bees and acute and chronic risk. It looks at both contact and dietary exposure—contact being if the bee would be sprayed or if it's exposed to dried residues on plants, and the dietary exposure is through pollen and nectar. In the initial screening, we have a way to estimate the expected exposure in the pollen and nectar from the application rate at which the pesticide is used.
That is the initial screen that is done for all pesticides. If a potential risk is identified, we can also ask for higher-tier data, which, as I mentioned before, includes tunnel studies, feeding studies, field studies and more realistic information on the exposure data—so that's the levels of pesticide in pollen and nectar that are actually measured, instead of the conservative estimate that's done initially.
We also consider other factors such as agronomic considerations. Is the crop something that is attractive to pollinators and that pollinators will be foraging on or, for example, is it something that's harvested before it blooms so there will not be pollinator exposure through pollen and nectar?
We look at the risk mitigation options as we're determining whether or not risk is acceptable. Is there risk mitigation that we can put in place, such as restricting timing during bloom or prebloom for different scenarios? For seed treatments, do we have to address dust considerations when planting treated seed, for example?
The risk assessment method we have now is very robust. It looks at both adults and larvae. With larvae, we consider the exposure when adults bring pollen and nectar back to the hive. We look at that. We also take into account native pollinators. We consider not only honeybees but also native bees, such as bumblebees and solitary bees, in our assessment.