That's a great question, Mr. Chair.
Regulatory data is designed to show the extreme scenario. When we talk about the half-life of a product—I'll use neonics as a good example—we often hear that products can last three years or more in the soil. The reason you're hearing that statistic is that when the regulatory data is generated for these products, it has to be under worst-case conditions. With no microbial activity, no sunlight, how long will that product sit in a soil column before it breaks down? That's the extreme end so that the regulator can know what the absolute maximum is. When you actually start to do field studies with the products, you then get a more realistic half-life. That's when you get more of the three, six, or nine months that we're seeing with many of these products.
It's the same with its mobility. We know the properties of the product. We know how mobile it is in water. We know whether it adsorbs to soil and becomes unavailable. All of that data is provided to PMRA so that they can do a risk assessment on the environment and determine the things you've just talked about. Based on the application rate, what is the likelihood of that product moving into the soil, moving into the water, or ending up in streams? What residues would that leave? Would that be toxic to aquatic life?
All of that is part of the data package that is evaluated by PMRA under the act.