1

Section 18 Application – Sulfoxaflor (Transform WG Insecticide) 

Tennessee Cotton 

Submitted by the Tennessee Department of Agriculture

Type of Exemption - Tennessee Section 18; Specific Exemption Request; April 4, 2016. This is 

an application for a specific exemption to authorize the use of Sulfoxaflor (Transform WG 

Insecticide EPA Reg. No. 62719-625) to control tarnished plant bug in cotton. 

(1) Identity of contact persons.

(i) Tennessee Department of Agriculture

John Ewell, Product Registration and Insurance Supervisor

Regulatory Services, Tennessee Department of Agriculture 

Ellington Agricultural Center, P.O. Box 40627

Nashville, TN 37204

Office: (615) 837-5340

Fax: (615) 837-5335

Email: john.ewell@tn.gov 

Kathy Booker, Pesticide Administrator

Regulatory Services, Tennessee Department of Agriculture 

Ellington Agricultural Center, P.O. Box 40627

Nashville, TN 37204

Office: (615) 837-5133

Fax: (615) 837-5335

Email: kathy.booker@TN.gov 

(ii) University and registrants contacts:

Scott D. Stewart, Professor and IPM Coordinator

Department of Entomology & Plant Pathology

West Tennessee Research and Education Center

605 Airways Blvd

Jackson, TN 38301

Office: 731-425-4709

Cell: 731-267-6085

Email: sdstewart@utk.edu

Tami Jones-Jefferson

U.S. Regulatory Leader, U.S. Regulatory & Government Affairs – Crop Protection

Dow AgroSciences

9330 Zionsville Road

Indianapolis IN, 46268

Tel: (317) 337-3574

Email: tjjonesjefferson@dow.com
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Jamey Thomas 

US Regulatory Manager

Dow AgroSciences 

9330 Zionsville Road 

Indianapolis, IN. 46268

Office: (317) 337-4138

Email: jdthomas@dow.com

(2) Description of the pesticide. 

Common chemical name (active ingredient): Sulfoxaflor

Brand name: Transform WG (EPA Reg. No. 62719-625)

Formulation: 50WP

Manufacturer: Dow AgroSciences

(A) A confidential statement of formula.

A confidential statement of formula has been previously submitted to EPA with the Section 3 

registration package for Transform WG (GF2372, active ingredient sulfoxaflor). Transform WG is 

a WDG formulation of the active ingredient sulfoxaflor.

(B) Complete labeling to be used in connection with the proposed exemption use.

The proposed label is included in this submission as Attachment A.

(3) Description of the proposed use. The application shall identify all of the following:

(i) Sites to be treated, including their locations within the State:

The insecticide will be restricted to use on cotton fields within the state of Tennessee for the 

purpose of controlling the tarnished plant bug, Lygus lineolaris (Palisot de Beauvois). 

Historically, almost all cotton has been produced in the counties of Dyer, Lauderdale, Shelby, 

Tipton, Carroll, Chester, Crockett, Fayette, Gibson, Hardeman, Haywood, Henderson, McNairy, 

Madison, Giles and Lincoln (Attachment B, USDA NASS 2014 County Estimates for Tennessee, 

http://www.nass.usda.gov/Statistics_by_State/Tennessee/Publications/County_Estimates/Cott

on14_TN.pdf).

(ii) The method of application:

Foliarly applied by air or ground

(iii) The rate of application in terms of active ingredient and product:

1.5-2.25 oz product/acre (0.047-0.071 lb AI/acre). Annual use will not exceed 0.266 lbs active 

ingredient per acre (8.5 oz product/acre).

(iv) The maximum number of applications:
3

Four applications per acre per year

(v) The total acreage or other appropriate unit proposed to be treated:

The National Cotton Council’s annual Cotton Planting Intentions survey estimates that Tennessee 

will plant 193,000 acres in 2016, and if realized, this would be up 25% from 2015. However, 

current economics and grower comments indicate this number could increase to ≈225,000 in 

2016. Tennessee has the potential need to treat 168,750 acres (75%) of this acreage with 

sulfoxaflor for control of tarnished plant bug. This assessment is based on estimates of the IPM 

Extension Specialist (Stewart), agricultural extension agents, and selected consultants that 50-

75% of these acres could experience serious Lygus infestations requiring three or more 

applications of insecticide, and it is these situations where Transform WG is most needed. During 

recent years, three or more applications specifically targeting tarnished plant bug are needed on 

a majority of the acres (e.g., Fig. 1).

Figure 1. Survey results from 2014 (bottom) and 2015 (top) of independent crop consultants in 

West Tennessee showing individual responses and the average (Avg.) number of foliar 

Consultant Identifier

Consultant Identifier
4

insecticide applications made per acre and the number specifically targeting tarnished plant bug

(TPB).

(vi) The total amount of pesticide proposed to be used in terms of both active ingredient and 

product:

Tarnished plant bug, Lygus lineolaris (Palisot de Beauvois), infestations may cause economic 

losses on all acres, but emergency use will be restricted to 168,750 acres in Tennessee during 

2016. No more than four applications, and likely two or less, would be required to reduce the 

impact of this pest. Seasonal use restrictions prohibit more than four applications and 8.5 oz of 

total product use per acre (0.266 lb ai/acre). Thus, the maximum amount of insecticide that could 

be applied is 89,648 lb formulated product or 44,824 lb active ingredient.

(vii) All applicable restrictions and requirements concerning the proposed use which may not 

appear on labeling:

Refer to the Transform® WG container label for first aid, precautionary statements, directions for 

use and conditions of sale and warranty information. It is a violation of federal law to use this 

product in a manner that is inconsistent with all applicable label directions, restrictions and 

precautions found in the container label and this supplemental label. Both the container label and 

this supplemental section 18 quarantine exemption label must be in the possession of the user at 

the time of application.

Applicable restrictions and requirements concerning the proposed use and the qualifications 

of applicators using Transform® WG are as follows:

• Pre-harvest Interval: Do not apply within 14 days of harvest.

• Minimum Treatment Interval: Do not make applications less than 5 days apart.

• Do not make more than four applications per acre per season.

• Do not make more than two applications during the bloom period.

• Do not apply more than a total of 8.5 oz. of Transform WG (0.266 lb AI of sulfoxaflor) per 

acre per year.

• Label must include a pollinator advisory statement including but not limited to the 

following:

o If known apiaries are within one mile of cotton fields intended for treatment, 

applications should be made within three hours of sunset during the flowering period.

o Prior to use of Transform WG, growers and the beekeepers hosted on their farm are 

advised to implement cooperative standards as drafted in the Tennessee Pollinator 

Conservation Plan.

• Before Transform WG can be used tarnished plant bug densities must reach or exceed 

thresholds published in UT Extension’s Insect Control Recommendations for Cotton, PB 

1768 (Stewart and McClure 2016) where populations are equal to or exceed than 15 insects 

per 100 sweeps or 3 per 5 row feet on a drop cloth.

(viii) The duration of the proposed use:

June - September of the 2016 cotton growing season 
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(ix) Earliest possible harvest dates:

September 15, 2016

(4) Alternative methods of control. The application shall contain: (i) A detailed explanation of 

why the pesticide(s) currently registered for the particular use proposed in the application is 

not available in adequate supplies and/or effective to the degree needed to control the 

emergency.

Insecticide Resistance: Pyrethroids

Presently, numerous insecticides are recommended against tarnished plant bug, but varying 

levels of resistance has been documented to nearly every class of these compounds among 

Midsouthern (Arkansas, Louisiana, Mississippi, Tennessee) populations of this insect. Populations 

have demonstrated resistance to pyrethroids (Snodgrass 1996, Snodgrass and Scott 2000) since 

the mid-1990s. Currently, none of the pyrethroids are recommended for tarnished plant bug 

control in the Tennessee because resistance to this class has become widespread and field 

experiments show poor control. A summary of all trials conducted at the Delta Research and 

Extension Center in Stoneville Mississippi from 2004 to 2010 revealed that control with the 

pyrethroids ranged from 0 to 47% control. In general, bifenthrin (ex. Brigade) showed better 

activity against plant bugs than other pyrethroids, but control was still less than adequate (Figure 

2). In Tennessee, data from multiple insecticide efficacy trials are published on the internet at 

http://www.utextension.utk.edu/fieldCrops/MultiState/MultiState.htm. In recent years, these

trials show applications of synthetic pyrethroids provide less than 30% control of tarnished plant 

bugs, which is inadequate against even moderate populations. Please see examples in figures 2

and 3 or refer to other data published online.

Figure 2. An experiment done in Tennessee during 2014 showing inadequate control of tarnished 

plant bugs with pyrethroid insecticides including DoubleTake (bifenthrin + diflubenzuron), 

Mustang Max, and Hero. It also shows the inadequacy of other insecticide classes such (e.g., 
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Athena, Carbine, Brigadier). Ratings are shown for 5 and 6 days after the first and second 

application, respectively (α = 0.05).

Figure 3. Yield data from a season long cotton experiment performed in west Tennessee during 

2010 against tarnished plant bug and stink bug infestation on Bt cotton (Madison Co.). Data do 

not include sulfoxaflor but show the relative inactivity of Brigade (bifenthrin), Carbine 

(flonicamid), Trimax Pro (imidacloprid) and Intruder (acetamiprid); resulting in a statically 

significant yield loss ranging from 19 - 29% after five applications of each compound (P < 0.05).

Use rate is indicated on the x-axis (oz product/acre except acephate which is lb ai/acre).

Insecticide Resistance: Organophosphates and Carbamates

More recently, resistance has been documented to several organophosphates (Snodgrass and 

Gore 2007, Snodgrass et al. 2009). Acephate has been the most widely used and effective 

insecticide for control of plant bugs in cotton but efficacy continues to decrease in much of the 

Mid-South. For the purpose of measuring tarnished plant bug resistance to organophosphates, 

acephate has been used in bioassays to represent the entire class because it is the most utilized 

for field control. For the most part, populations that show greater than 3-fold levels of resistance 

to acephate also have high levels of resistance to dicrotophos (Fig. 4). Figure 4 shows the 

resistance ratios (gray bars) for Baythroid (pyrethroid), Bidrin (OP), Orthene (OP), and Vydate CLV (carbamate) for tarnished plant bugs. This particular population shows high levels of cross 

resistance to all classes of insecticides evaluated. The black bars show percent mortality of 

tarnished plant bugs caged on cotton plants sprayed with field use rates of each of the 

insecticides. In all cases except Vydate, the highest labeled rate was used. None of the 

insecticides provided greater than 48% mortality at field use rates. Additionally, preliminary 

research suggests that there are multiple mechanisms of resistance to the OP’s. There appears 

to be populations with target site insensitivity and metabolic resistance. Most of the plant bug 

populations across the Mississippi River Delta express target site insensitivity, which confers cross 

resistance to the other organophosphates and carbamates. Populations that only have metabolic 

resistance do not always exhibit cross resistance with other insecticides and the cross resistance Pounds / Acre

Lint

500

600

700

800

900

1000

1100

1200

1300

1400

1500

a a a a a a ab bc bc bc c d
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appears to be linked to the specific enzymes involved. Although not tested, a similar situation 

likely exists in Tennessee. Vydate had sometimes perform adequately in Tennessee at rates at or 

above 12 oz/acre (e.g., Fig. 3), but other times provides inadequate control when used by itself or 

as a tank mix partner at reduced rates, similar as to reported in other states. Regardless, DuPont 

has reported a serious breakdown at the plant where Vydate is manufactured, and it appears this 

insecticide will only be available in limited quantities during 2016.

In the Mid-South, field efficacy with both acephate and dicrotophos has declined in recent years. 

Table 1 provides a summary of results from insecticide screening trials conducted by Mississippi 

State University personnel at various locations across the Mississippi Delta from 2005 through 

2010. In 2005, acephate and dicrotophos provided 84.0 and 79.3 percent control, respectively. 

By 2010, control declined to 45.8 and 28.2 percent control, respectively, for these insecticides. 

Similar results were seen for yield losses attributed to tarnished plant bugs over that same time 

period (Table 1). In West Tennessee, resistance monitoring efforts (Table 2) also indicate the 

presence of resistance to organophosphate insecticides (i.e., acephate or methamidophos) in 9 of 

16 populations collected during 2006-2011. Although some OP insecticides such as dicrotophos 

and acephate still provide adequate control in some circumstances, the level of control is declining 

and label restrictions and resistance management guidelines limit their utility. Tank mixing with 

other modes of action is typically recommended to achieve adequate control when severe 

infestations of tarnished plant bug are encountered.

Figure 4. Resistance ratios and control of Lygus with multiple classes of insecticides (AR, LA and 

MS Delta).

With these levels of control, growers commonly experience field control failures with all of the 

organophosphates currently labeled for tarnished plant bug control in most delta environments 

of the Mississippi River and adjacent counties. In West Tennessee, organophosphates are usually

applied in a tank mix with another class of insecticide.

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7 3.6 3.6 4.8

0

25

44

39

48

20

8

0

10

20

30

40

50

60

70

80

90

100

Baythroid (2.6) Bidrin (0.5) Orthene (0.5) Orthene (1.0) Vydate (0.33) UTC

RR Percent Mortality

Percent/RR

 

 
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Table 1. Average (Standard Error) percent control and yield for Acephate and Dicrotophos from

trials conducted in Stoneville, MS from 2005 to 2010 and percent yield reductions compared to 

2005.

Acephate Dicrotophos

Year % 

Control

Yield

(Lint/A)

% Yield

Reductio

n

% Control Yield

(Lint/A)

% Yield 

Reduction

2005 84.0 (5.0) 1342 (47.4) --- 79.3 (5.8) 1374 (78.6) ---

2006 81.7 (3.8) 1213 (131.3) 9.6 83.3 (3.5) 1149 (129.8) 16

2007 83.5 (3.7) NA NA 86.0 (2.6) --- ---

2008 71.6 (2.7) 946 (60.5) 29.5 67.0 (3.1) 936 (93.4) 31.9

2009 55.8 (5.7) 676 (92.6) 49.7 --- --- ---

2010 45.8 (2.3) 984 26.6 28.2 (4.3) 970 (77.0) 29.4

P <0.01 <0.01 <0.01 <0.01

Table 2. Summary of acephate or Monitor (methamidophos) resistance assays for Lygus collected 

from west Tennessee. Bolded numbers indicate populations that exceeded predefined resistance 

threshold (< 75% mortality with a discriminating dose of methamidophos or an LC50 value for 

acephate > 7.5).

Year Collection Site (County)

Discriminating Dose

(% Mortality) LC50 ug

Methamidophos Acephate

2006 Haywood* 86 ---

Lauderdale* 90 ---

Madison* 98

Gibson* 98 ---

Crockett 60 4.92

Dyer 86

2007 Haywood* 72 7.22

Lake* 88 ---

Madison* 68 9.62

Dyer 96 10.53

Crockett 90 4.89

Tipton 88 10.64

2008 Crockett --- 11.03

Madison --- 7.82

Tipton --- 9.43

2011 Madison --- 10.0

 * Spring or early summer samples (other samples were made late summer).

Insecticide Resistance: Neonicotinoids

The neonicotinoid class of insecticides is recommended for both tarnished plant bug control in 

Tennessee. The insecticides in this class have historically only shown marginal control of tarnished 

plant bug following first flower when the most serious Lygus infestations typically occur. This has
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especially true of acetamiprid and imidacloprid (e.g., Fig. 3). Acetamiprid (Intruder or Strafer) is 

rarely tested because its performance is generally too poor to be considered for tarnished plant 

bug control. Very little acetamiprid is used except as a tank mix partner when aphid infestations 

are also present.

Among the neonicotinoids, thiamethoxam (Centric) is more active insecticide against tarnished 

plant bug. However, the University of Tennessee’s insect management guidelines for cotton

(PB1768, http://www.utcrops.com/cotton/cotton_insects/pubs/PB1768-Cotton.20pdf) does not 

recommend using this class of chemistry after first flower as part of an overall resistance 

management plan, and because alternative insecticides or tank mixes often provide better 

control. This resistance management plan also suggests avoiding the use of premixed insecticides 

that also contain a neonicotinoid component (e.g., Endigo and Leverage). Seasonal use rate 

restrictions prevent more than 2-3 applications of thiamethoxam, either as Centric or as the 

premix Endigo formulation. Table 3 and Figure 5 demonstrate the poor performance of 

imidacloprid (Trimax Pro, Couraze 4F or Admire Pro) and bifenthrin (Brigade). Table 5 also shows

the relatively superior performance of sulfoxaflor (Transform) that is often observed.

Endigo is a premix of thiamethoxam and lambda-cyhalothrin and, prior to 2012, was a top 

performing insecticide (e.g., Figure 3). There are now unpublished reports of resistance to 

thiamethoxam in some populations of tarnished plant bug (source: USDA ARS in Stoneville, MS). 

Data collected in Tennessee also shows decreased efficacy of Centric or Endigo (e.g., Table 3).

Table 3. An efficacy trial done in Tennessee during 2015 demonstrating the poor performance of 

Centric (thiamethoxam) and Strafer (acetamiprid). Note that Transform, Orthene + Diamond, and 

Transform + Diamond were the top yielding treatments in this test.

Formulation Appl

1 Strafer 70 % 3 oz wt/a ABC 2.5 bcd 5.8 bcd 24.5 ab 12.0 b 1432 cd

2 Strafer 70 % 3.5 oz wt/a ABC 1.8 cd 10.0 bc 12.0 cd 12.3 b 1466 a-d

3 Strafer 70 % 3 oz wt/a ABC 3.3 bc 5.3 cd 7.5 d 4.8 c-f 1616 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

4 Centric 40 % 2 oz wt/a ABC 4.3 b 7.8 bcd 26.5 ab 9.3 bc 1457 bcd

5 Centric 40 % 2 oz wt/a ABC 2.0 cd 7.5 bcd 15.5 bc 5.8 bcd 1597 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

6 Orthene 90 % 1 lb/a ABC 2.3 bcd 5.8 bcd 7.8 d 2.5 f 1593 abc

7 Orthene 90 % 1 lb/a ABC 1.0 d 6.0 bcd 8.3 d 2.3 ef 1736 ab

Diamond 0.8 lb/gal 6 fl oz/a ABC

8 Bidrin XP II 5 lb/gal 12 fl oz/a ABC 3.1 bcd 11.5 ab 10.8 cd 4.5 b-e 1512 a-d

9 Bidrin XP II 5 lb/gal 12 fl oz/a ABC 2.5 bcd 10.8 abc 9.5 cd 2.3 def 1680 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

10 Transform 50 % 1.75 oz wt/a ABC 1.8 cd 2.0 d 10.0 cd 2.0 def 1742 a

11 Transform 50 % 1.75 oz wt/a ABC 1.0 d 5.5 cd 9.0 cd 3.5 c-f 1696 abc

Diamond 0.8 lb/gal 6 fl oz/a ABC

12 Untreated A 7.5 a 16.5 a 28.0 a 31.5 a 1279 d

Means followed by same letter do not significantly differ (P=.05, LSD)

Description Total TPB Total TPB Total TPB Total TPB Lint (lbs/a)

Rating Date 7/13/2015 7/20/2015 7/27/2015 8/3/2015 10/12/2015

Treatment Rate

Trt-Eval Interval 5 DA-A 12 DA-A 6 DA-B 6 DA-C
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Other Insecticides and Additional Information

There are currently only two other insecticide classes labeled for tarnished plant bug control. The 

first is flonicamid (Carbine), a pyridine caboxamide. Although this insecticide does show activity 

against tarnished plant bugs and provides good control of western tarnished plant bug (Lygus 

hesperus), results have not been promising in the Mid-South (Fig. 5, Table 4). Its primary use has 

been cases where cotton aphids are the primary target, as cotton aphids in Tennessee are now 

resistant to neonicotinoid insecticides. Carbine often provides only 50-60% control of Lygus or 

less. Please refer to other examples of efficacy trials in Tennessee with Carbine and other 

previously discussed insecticide classes (linked below).

http://www.utcrops.com/MultiState/Trials/2014/tpb-FMC%20General%20Cotton.pdf

http://www.utcrops.com/MultiState/Trials/2014/tpb-Intruder%20Summary.pdf

http://www.utcrops.com/MultiState/Trials/2013/FMC-Athena-tpb.pdf

http://www.utcrops.com/MultiState/Trials/2013/FMC-General-TPB.pdf

http://www.utcrops.com/MultiState/Trials/2012/TPB%20SkyRaider%20Cotton.pdf

http://www.utcrops.com/MultiState/Trials/2012/TPB-Athena-Crooks.pdf

Figure 5. Numbers of Lygus per 10 row feet following and 6 and 5 days following a first and second 

application, respectively. Data show how alternative treatments, including Diamond and Carbine, 

equal to competitive standards (Tennessee, 2010).

The data below shows the results for an experiment conducted in Stoneville, MS in 2009. The 

data show the number of nymphs 5 days after the second application of each insecticide in an 

overall control program. A total of 7 insecticide applications were made to the entire field. Five of 

those applications were blanket applications applied across the entire field. Carbine did not 

reduce tarnished plant bug densities below that observed in the non-treated control (Table 6).

0

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20

6 DAT1 5 DAT2
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Table 4. Results from an experiment conducted in Stoneville, MS in 2009 on tarnished plant bug.

Treatment Rate Nymph/5 ft.

Centric 2 oz/A 12.6 B

Bidrin 8 fl oz/A 9.4 B

Acephate 0.75 lb AI/A 5.9 B

Carbine 2.8 oz/A 22.1 A

Non-treated 24.3 A

The other insecticide is novaluron (Diamond), an insect growth regulator. Because novaluron is 

an insect growth regulator, it only controls the immature stages of tarnished plant bug and has 

no activity against adults. Field testing of this insecticide generally showed variable results in 

terms of tarnished plant bug control. In a trial conducted in Sunflower county, MS in 2006, large 

blocks of cotton on a growers farm were treated with Bidrin at 0.5 lb ai/A, Orthene at 1.0 lb ai/A, 

Orthene at 1.0 lb ai/A + Diamond at 0.04 lb ai/A, Bidrin at 0.5 lb ai/A + Diamond at 0.04 lb ai/A, 

and Diamond at 0.06 lb ai/A. Treatments were applied by ground with a high clearance sprayer 

and all treatments were replicated 4 times. The treatments were applied to an established 

population and pre-treatment counts averaged 22.6 nymphs per 5 row ft. Two applications were 

made 7 days apart. Seven days after the second application, tarnished plant bug densities in all 

of the treatments remained well above the action threshold of 3 bugs per 5 row ft, ranging from 

7.2 for Orthene (1.0 lb ai/A) + Diamond (0.04 lb ai/A) to 15.6 nymphs per 5 row ft for Diamond 

alone (0.06 lb ai/A). Similar results were observed in other trials and by consultants and growers 

for the first few years that Diamond was commercially available. Other research has shown that 

Diamond is not very effective on large nymphs. In an experiment conducted in Stoneville, MS in 

2007, fifth instar nymphs were exposed to cotton plants treated with a range of field use rates in 

a spray chamber. The nymphs were allowed to feed on the treated plants until they molted into 

adults or died (Table 5). The percentage of nymphs that molted into the adult stage ranged from 

47.8 at the highest labeled rate to 83.3 at the lowest rate tested. This combined with the rapid 

growth rate of tarnished plant bug makes timing of the application critical. Adverse weather 

conditions (rain, high wind, etc.) are common and can delay applications up to a week. In that 

time frame, susceptible stages of nymphs (1st-3rd Instars) have time to develop to less susceptible 

stages.

Table 5. Impact of Diamond insecticide (novaluron) on late instar tarnished plant bug nymphs in 

a controlled experiment in Stoneville, MS.

Treatment Rate Percent Adults

UTC --- 96.7 A

Diamond 2 83.3 AB

Diamond 4 60.0 BC

Diamond 6 58.5 C

Diamond 9 69.7 BC

Diamond 12 47.8 C

Over the last several years, we have discovered better ways to use Diamond in an overall Lygus

management program. Research in the Mid-South has shown that early preventative applications 

can help reduce the impact of tarnished plant bugs in cotton. However, the timing of these 
12

applications is critical and must target the eggs and early instar stages. The difficulty in using eggs 

as a trigger is that tarnished plant bugs insert their eggs into plant tissue and are not visible in the 

field. This combined with the difficulty in controlling late instar nymphs makes managing this pest 

with Diamond extremely difficult. Using Diamond preventatively in Tennessee, where the 

intensity and timing of Lygus infestations and timings varies considerably poses a real challenge. 

Treating large acreage where Lygus populations may not develop into severe infestations can lead 

to unnecessary insecticide applications. Additionally, control with Diamond against established 

infestations is typically less than adequate unless two applications are made or tank mixed with 

other insecticides. Like adult plant bugs, Diamond has no activity on adult stink bugs and this is 

another reason it generally requires co-application with other insecticides. Further, Diamond is 

hard on beneficial insect populations and often flares populations of aphids and spider mites (e.g.,

Fig. 6). Of course, the same is also true of other alternative insecticides, especially when 

repeatedly sprayed (e.g., Fig. 7). 

Figure 6. Aphid “flaring” data from a season long cotton experiment performed in West 

Tennessee during 2010 against tarnished plant bug and stink bug infestations on Bt cotton 

(Madison Co.). Data show how some competitive standards for tarnished plant bug control such 

as Vydate (oxamyl), Diamond (novaluron) and synthetic pyrethroids (e.g., Brigade) worsened

infestations of secondary pests. Aphid infestations were ranked from 1 (low) to 4 (very high), P < 

0.05. Use rate is indicated on the x-axis (oz product/acre).

0.0

0.5

1.0

1.5

2.0

2.5

3.0

Aphid Rating, 1-4

a a b a a a a a a c c b
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0

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20

30

40

50

60

70

80

90

4 2 1 1 0

No. Applications 

(Bidrin or Orthene)

Percent infested plants (7/25)

d

c cd

b

a

0

2

4

6

8

10

12

3 1 0 0

No. Applications 

(Centric or Trimax)

Mite hits per 600 row ft (6/26)

6/18

a

b b b

Early season Late season

Figure 7. Spider mite “flaring” data from a study evaluating treatment thresholds for tarnished 

plant bug in West Tennessee during 2007 (Lauderdale Co.). Data show how some competitive 

standards including neonicotinoids used early season (Centric and imidacloprid such as Trimax, 

Admire Pro, etc.) or organophosphates used during the flowering period (Bidrin and Orthene), 

worsened infestations of secondary pests. Insecticides were rotated as indicated where more 

than one application was made.

In some areas of the Mid-South, tarnished plant bug infestations have reached outbreak levels 

and become uncontrollable. In Tennessee during 2014 and 2015, some consultants recommended

an average of four or more insecticide applications per acre for tarnished plant bug (Fig. 1), and 

some fields received as many as eight applications for this pest. Current trends with insecticide 

resistance and lack of effective alternative technologies will allow problems with tarnished plant 

bug management to intensify. Chemical control options that provide consistent efficacy are not 

available or have significant negative repercussions. Effective Lygus control is a serious, unmet 

need for Midsouthern cotton growers and one that requires immediate and urgent action. This 

has now become an emergency situation.

These results have shown that regardless of the registered insecticide, tarnished plant bug 

populations in the Mid-South have become significantly more difficult to control using common 

recommended insecticides (Lorenz et al. 2009, Moore et al. 2010). As a result, the numbers of 

applications and use rates needed to control Lygus have increased. With a novel mode of action 

and chemical class, sulfoxaflor will successfully control both susceptible and insecticide-resistant 

populations of tarnished plant bug, thereby improving the overall cotton IPM system. This is a 

tremendous economic opportunity for cotton growers, and more environmentally-friendly 

alternative to the sustained frequency of the currently used products. Table 6 shows a study 

conducted in the Mississippi Delta where all of the currently registered classes of insecticides were 

used in an overall management program. In this trial, a total of seven applications were made. 

Each of the insecticides being tested were applied four times, but no more than two times in a 

row. Ratings of tarnished plant bug control were made after the underlined treatments. These 

data show that none of the treatment programs provided consistent control of tarnished plant 

bugs over the entire season. As a result, yields for all of the spray programs were very low 
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compared to state averages in 2010. This experiment shows that an overall tarnished plant bug 

program is not feasible or economical for producers with the few insecticide classes that are 

currently labeled in the Mid-South.

Table 6. Evaluation of tarnished plant bug management programs in the Mississippi Delta in 2010.

Treatment 5 DAT 1

% Control

13 DAT 1

% Control

7 DAT 2

% Control

14 DAT 2

% Control

7 DAT 3

% Control

7 DAT 4

% Control Lint Yield

Vydate 0.33 lb fb Centric 2.5 oz 

fb

Orthene 0.75 lb fb

Orthene 0.75 lb fb

Diamond 6 oz fb

Orthene 0.75 lb fb

Orthene 0.75 lb

69 54 50 0 57 0 549

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Diamond 9 oz fb

Diamond 9 oz fb

Orthene 0.75 lb fb

Diamond 9 oz fb

Diamond 9 oz

60 72 0 31 62 73 482

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Bidrin 6 oz fb

Bidrin 6 oz fb

Diamond 6 oz fb

Bidrin 6 oz fb

Bidrin 6 oz

53 36 0 0 38 0 343

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Vydate 10 oz fb

Vydate 10 oz fb

Diamond 6 oz fb

Vydate 10 oz fb

Vydate 10 oz

31 0 75 0 72 0 343

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Centric 2 oz fb

Centric 2 oz fb

Diamond 6 oz fb

Centric 2 oz fb

Centric 2 oz

21 16 0 0 72 0 405

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Endigo 5 oz fb

Endigo 5 oz fb

Diamond 6 oz fb

Endigo 5 oz fb

Endigo 5 oz

19 12 0 0 26 67 567

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz fb

Diamond 6 oz fb

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz

0 0 0 0 31 23 358
15

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Carbine 2.5 oz fb

Carbine 2.5 oz fb

Diamond 6 oz fb

Carbine 2.5 oz fb

Carbine 2.5 oz

0 40 0 0 18 0 405

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Leverage 360 3.2 oz fb

Leverage 360 3.2 oz fb

Diamond 6 oz fb

Leverage 360 3.2 oz fb

Leverage 360 3.2 oz

0 0 0 0 15 0 397

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Intruder 1.1 oz fb

Intruder 1.1 oz fb

Diamond 6 oz fb

Intruder 1.1 oz fb

Intruder 1.1 oz

0 12 0 0 42 0 372

Vydate 0.33 lb fb Centric 2.5 oz 

fb 

Brigade 5.12 oz fb

Brigade 5.12 oz fb

Diamond 6 oz fb

Brigade 5.12 oz fb

Brigade 5.12 oz

0 24 0 17 38 0 312

Check NA NA NA NA NA NA 225

*Ratings start after 4th application

(ii) A detailed explanation of why alternative practices, if available, either would not provide 

adequate control or would not be economically or environmentally feasible.

Several IPM strategies are recommended for controlling tarnished plant bug in cotton (Gore et al. 

2008). Non-chemical tactics include area-wide control of non-crop alternate hosts. Proper 

selection of early-maturing varieties and managing the optimum planting period are being used

to produce a rapid fruiting and early maturing crop; thereby reducing the time the crop is 

susceptible to this pest. Careful timing of insecticide applications based on revised spray action 

thresholds are used to precisely target populations before they reach outbreak levels. All of these 

practices are currently in place and are being used by cotton producers. However, these 

strategies only serve to suppress populations and are not effective as stand-alone practices. 

Effective chemical control practices are still necessary to provide tarnished plant bug 

management in cotton. As highlighted above the current situation in Tennessee has produced 

severe economic burdens on cotton producers. The Midsouthern states have experienced greater 

reductions in cotton acres compared to other cotton producing regions of the country. The recent 

increase in cost of tarnished plant bug control is an important reason for this decrease in cotton

acres.

Currently, tarnished plant bugs have widespread resistance to the pyrethroids, 

organophosphates, and carbamates. In the case of the organophosphates, resistance is partially 

dominant. A recent study by Snodgrass and Gore showed that because the trait is not recessive, 
16

resistance levels do not decline during the winter. Also, relevant genetics data suggests that gene 

flow can occur between populations that are up to approximately 10 miles apart. These factors 

have contributed to the rapid spread of resistance in much of the Mid-South. Also, this makes 

predicting where the resistance levels will be highest from year to year extremely difficult. The 

widespread resistance to pyrethroids, organophosphates, and carbamates renders these 

insecticides nearly useless for economical cotton production. Over the last ten years, field use 

rates have more than doubled and control has continued to decline. This has put a tremendous 

amount of pressure on the neonicotinoid class. Of that class, thiamethoxam is the most effective 

for tarnished plant bug control. Consequently, 1-4 preflower applications in cotton may target 

both tarnished plant bugs and cotton aphids. Centric (thiamethoxam) has been the insecticide of 

choice in this situation because it provides better control of the whole pest complex than other 

neonicotinoids at that time of the year. The most common rate used at that time of year is 2 oz 

formulated product per acre (0.05 lbs ai/A). The maximum seasonal use rate for Centric is 5.0 oz 

(0.125 lb ai thiamethoxam). Therefore, two applications of Centric at 2 oz/A (0.05 lbs ai per acre 

per application) during the pre-flowering period does not leave enough active ingredient for later 

applications of either Centric or Endigo (thiamethoxam + lambda-cyhalothrin). As already 

mentioned, recent evidence now shows decreased efficacy of Centric on tarnished plant bug. The 

only other labeled insecticides available are Carbine (flonicamid) and Diamond (novaluron). As 

previously described, Carbine is not a reliable control option for Lygus in the Midsouthern states. 

Diamond is the only other insecticide available for late season tarnished plant bug control. 

Diamond is an insect growth regulator that only controls the immature stages. Therefore, 

Diamond applications are exclusively used with another class of chemistry to control adults. Also, 

application timing is critical with this insecticide and applications are often sprayed too late to 

provide the most effective levels of control. Thus, the use of Transform WG will be important for 

alleviating some of the economic hardships that cotton growers in Tennessee are currently 

experiencing.

As expected and previously mentioned, the excessive use of some products for tarnished plant 

bug are now beginning to induce additional pest problems (spider mites and cotton aphids) in 

some areas. There is a strong correlation between the number of applications targeting tarnished 

plant bugs and other pests such as cotton aphids and/or spider mites (Figs. 6, 7 and 8). Problems 

with these secondary pests have subsided this past 3-4 years, much to the credit of using 

Transform in IPM program. The loss of Transform is of great concern to producers and pest 

management practitioners. Organophosphate, carbamate and pyrethroid insecticides can impact 

natural beneficial arthropod populations and flare secondary insects. Acephate is commonly used 

for Lygus control and can flare aphids, mites, and bollworm populations. Pyrethroid insecticides 

often flare aphids and mites, as well. By using sulfoxaflor, we expect a reduction in the use of 

some insecticides, especially acephate, dicrotophos, and oxamyl. The ecological and toxicological 

profile of sulfoxaflor is considered to be more favorable than the ecological and toxicological 

profiles of these insecticides. Data indicates that sulfoxaflor is not likely to flare aphids and mites. 

Therefore, the use of Transform will and has provided significant economic benefits for cotton 

growers in Tennessee. Furthermore, the use of Transform since 2012 has replaced products that 

are well known to be more toxic to honeybees therefore increasing the overall safety to honey 

bees and likely other pollinators (Zhu et al. 2015)
17

Figure 8. Correlations between Lygus applications and applications for other pests (Mississippi).

(5) Effectiveness of proposed use. The application shall contain data, a discussion of field 

trials, or other evidence which provide the basis for the conclusion that the proposed pesticide 

treatment will be effective in dealing with the emergency.

Sulfoxaflor (Transform WGTM) has been evaluated in laboratory and field trials for the past several 

years. Recent publications by Babcock et al. (2010) and Zhu et al. (2011) clearly define the biology 

and biochemistry of sulfoxaflor and demonstrate a novel mode of action against sap feeding 

insects including those in the order Heteroptera. Insects in the genus Lygus are included in this 

order. Sulfoxaflor-induced mortality was similar between insecticide-resistant and insecticidesusceptible strains of several Homoptera and Heteroptera. No cross-resistance was detected to 

sulfoxaflor in populations expressing resistance to a broad range of modes of action. These 

research projects support a novel mode of action for sulfoxaflor including those insecticides with 

similar chemical structures (neonicotinoids). 

Data from several field trials in Tennessee and elsewhere demonstrate the excellent efficacy of 

sulfoxaflor (Transform) relative to the best alternative insecticides(Figs. 9 and 10, Tables 3, 7, and

7). Other examples are published online at http://www.utcrops.com/MultiState/MultiState.htm. 

In all tests including sulfoxaflor, this product has provided excellent control either as good as or 

better than the best alternative treatment (typically acephate at the highest labeled rates). Data 

from other areas of the MidSouth highlight the value of Transform in preserving yield when used 

in combination or rotation with alternative treatments (e.g., Tables 9). 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

1 3.1 5.2 4.9 3.2 7.5 5.5 6.5 6

Spider Mites

Cotton Aphid

Mite/Aphid Applications

 

 

Lygus Applications

r = 0.9634

r = 0.8401
18

Figure 9. Numbers of Lygus per 10 row feet, showing the relative efficacy of sulfoxaflor vs. 

competitive standards, Tennessee, 2011.

Figure 10. Numbers of Lygus per 10 row feet, showing the relative efficacy of sulfoxaflor vs. 

competitive standards, Tennessee, 2010.

Table 7. Standard efficacy test comparing Transform to standard insecticides in the Mississippi 

Delta in 2010.

Treatment Seasonal Mean TPB Adults and Nymphs

Transform 0.045 lb + Bifenthrin 4.27 oz 13.3 e

0

2

4

6

8

10

12

14

16

Transform 

1.5 oz

Transform 

2.25 oz

Bidrin 

8 oz

Acephate 90S 

17.8 oz

Endigo 

5 oz

Untreated

Plant bugs 6 DAA

Plant bugs 14 DAA

0

5

10

15

20

25

30

35

4 DAT1 4 DAT2 8 DAT2

0.25“ of rain 1.25 hours after application 1
19

Transform 0.067 lb 14.0 de

Transform 0.067 lb + Bifenthrin 4.27 oz 16.8 de

Endigo 0.08 27.5 bc

Bidrin 0.05 lb 35.0 b

Orthene 1 lb 23.0 cd

Untreated 135.8 a

P = 0.0001

Table 8. Standard efficacy test comparing Transform to standard insecticides in the Mississippi 

Delta in 2009.

2009 Transform Efficacy Test Compared to Common Standards for Tarnished Plant 

Bug

Product Seasonal Mean TPB Adults and Nymphs

Transform 0.067 lb 8.5 d

Orthene 1 lb 16.3 c

Bifenthrin 6.4 oz 20.3 c

Centric 2.5 oz 33.5 c

Bidrin 0.05 lb 35.0 b

Transform 0.067 lb + Bifenthrin 6.4 oz 8.0 d

Untreated 82.0 a

P = 0.0001

Table 9. Percent control and yields from a tarnished plant bug program trial conducted in 

Wayside, MS in 2010.

Treatment Seasonal Mean

No. Lygus

Seasonal Mean 

Lygus % Control

Lint Yield

Transform 0.045 lb fb Transform 

0.045 lb fb 

Orthene 1 lb fb

Transform 0.045fb

Transform 0.045

46.8 c 84 a 1266 a

Transform 0.067 lb fb Transform 

0.067 lb fb 

Orthene 1 lb fb

Transform 0.067 lb fb Transform 

0.067

42.1 c 85 a 1267 a

Orthene 0.5 lb +

Diamond 9 oz fb

Bidrin 0.5 lb fb

Endigo 0.08 lb fb

Orthene 0.75 lb +

Karate 0.04 lb fb

Orthene 1.0 lb

128.3 b 56 b 1019 b

Untreated Check 292.3 a NA 664 c 1

Means followed by the same letter are not significantly different (P<0.05).
20

Although natural enemy populations provide little benefit for tarnished plant bug management, 

alternative insecticides targeting plant bugs reduce natural enemy populations and “flare” other 

pests such as twospotted spider mite or cotton aphid. A study conducted in Stoneville, MS in 

2013 compared overall management programs. The treatments included cotton grown with all 

classes except neonicotinoids or sulfoxaflor, all classes except sulfoxaflor, and all available classes. 

Overall, 1-2 applications were needed for twospotted spider mite in the treatments where 

sulfoxaflor was not used (Fig. 11). Additionally, the treatments that did not include sulfoxaflor 

each needed to be sprayed separately for cotton aphid. A portion of this is due to sulfoxaflor 

control of cotton aphids, but preservation of beneficial insects also contributed. In summary, the 

use of sulfoxaflor for tarnished plant bug management can reduce the number of insecticide 

applications targeting other pests because of the lower toxicity to beneficial arthropods. Overall, 

yields and economic returns were greater where all classes of insecticides were included.

 

Figure 11. Impact of insecticide use programs for tarnished plant bug management on the number 

of insecticide sprays for twospotted spider mite and cotton aphid.

From 2014 to 2015 a graduate student at Mississippi State University conducted a study 

comparing the tarnished plant bug IPM program to a standard approach at multiple planting dates 

Hills and Delta regions of Mississippi. In the IPM approach, sulfoxaflor was a standard component 

of the insecticide use strategy. It was also occasionally used in the standard approach when aphids 

were also present. Overall, the IPM program resulted in greater yields, fewer insecticide 

applications, and greater economic returns compared to the standard approach (Fig. 12).
21

Figure 12. Economic returns for a tarnished plant bug IPM program compared to a Standard 

approach in Mississippi averaged across 2014 and 2015. The BMP treatments included sulfoxaflor 

as a foundation of the overall IPM program. It was occasionally used in the standard approach 

mainly to manage cotton aphid.

Sulfoxaflor (DAS test code GF-2372, proposed trade name TransformTM) has been evaluated in 

laboratory and field trials for the past several years. Recent publications by Babcock et al. (2010) 

and Zhu et al. (2010) clearly define the biology and biochemistry of sulfoxaflor and demonstrate 

a novel mode of action against sap feeding insects including those in the order Heteroptera. 

Insects in the genus Lygus are included in this order. Sulfoxaflor-induced mortality was similar 

between susceptible and insecticide-resistant strains of several Homoptera and Heteroptera. No 

cross-resistance was detected to sulfoxaflor in populations expressing resistance to a broad range 

of modes of action. These research projects support a novel mode of action for sulfoxaflor 

including those insecticides with similar chemical structures (neonicotinoids). 

All available data indicates that sulfoxaflor is an excellent tool for managing tarnished plant bug 

infestations in Tennessee and Midsouthern cotton IPM programs by improving efficacy, reducing 

input costs, and increasing yields. This compound has a selective spectrum of activity, has not 

shown a propensity to flare other pests, can be used as a rotational or tank-mix partner with other 

chemistries, and has demonstrated value against insecticide-resistant populations. It is likely that 

sulfoxaflor will be the backbone of chemical control strategies for tarnished plant bug and is 

critically needed in this emergency situation. 

(6) Discussion of residues for food uses. If the proposed use is expected to result in residues of 

the pesticide in or on food, the application shall list the food likely to contain such residues and 

shall contain an estimate of the maximum amount of the residue likely to result from the 

proposed use, together with the information on which such estimates are based.

Acute Assessment

Food consumption information from the USDA 1994-1996 and 1998 Nationwide Continuing 

Surveys of Food Intake by Individuals (CSFII) and maximum residues from field trials rather than 

tolerance-level residue estimates were used. It was assumed that 100% of crops covered by the 

registration request are treated and maximum residue levels from field trials were used.
22

Drinking water. Two scenarios were modeled, use of sulfoxaflor on non-aquatic row and orchard 

crops and use of sulfoxaflor on watercress. For the non-aquatic crop scenario, based on the 

Pesticide Root Zone Model/Exposure Analysis Modeling System (PRZM/EXAMS) and Screening 

Concentration in Ground Water (SCI-GROW) models, the estimated drinking water 

concentrations (EDWCs) of sulfoxaflor for acute exposures are 26.4 ppb for surface water and 

69.2 ppb for ground water. For chronic exposures, EDWCs are 13.5 ppb for surface water and 

69.2 ppb for ground water. For chronic exposures for cancer assessments, EDWCs are 9.3 ppb 

for surface water and 69.2 ppb for ground water. For the watercress scenario, the EDWCs for 

surface water are 91.3 ppb after one application, 182.5 ppb after two applications and 273.8 

ppb after three applications. 

Dietary risk estimates using both sets of EDWCs are below levels of concern. The non-aquaticcrop EDWCs are more representative of the expected exposure profile for the majority of the 

population. Also, water concentration values are adjusted to take into account the source of the 

water; the relative amounts of parent sulfoxaflor, X11719474, and X11519540; and the relative 

liver toxicity of the metabolites as compared to the parent compound. 

For acute dietary risk assessment of the general population, the groundwater EDWC is greater 

than the surface water EDWC and was used in the assessment. The residue profile in 

groundwater is 60.9 ppb X11719474 and 8.3 ppb X11519540 (totaling 69.2 ppb). Parent 

sulfoxaflor does not occur in groundwater. The regulatory toxicological endpoint is based on 

neurotoxicity. 

For acute dietary risk assessment of females 13-49, the regulatory endpoint is attributable only 

to the parent compound; therefore, the surface water EDWC of 9.4 ppb was used for this 

assessment. 

A tolerance of 0.3 ppm for sulfoxaflor on grain sorghum has been established. There is no 

expectation of residues of sulfoxaflor and its metabolites in animal commodities as a result of 

the proposed use on sorghum. Thus, animal feeding studies are not needed, and tolerances 

need not be established for meat, milk, poultry, and eggs.

Drinking water exposures are the driver in the dietary assessment accounting for 100% of the 

exposures. Exposures through food (sorghum grain and syrup) are zero. 

The acute dietary exposure from food and water to sulfoxaflor is 16% of the aPAD for children 1-

2 years old and females 13-49 years old, the population groups receiving the greatest exposure.

Chronic Assessment

The same refinements as those used for the acute exposure assessment were used, with two 

exceptions: (1) average residue levels from crop field trials were used rather than maximum 

values and (2) average residues from feeding studies, rather than maximum values, were used 

to derive residue estimates for livestock commodities. It was assumed that 100% of crops are 

treated and average residue levels from field trials were used.

For chronic dietary risk assessment, the toxicological endpoint is liver effects, for which it is 

possible to account for the relative toxicities of X11719474 and X11519540 as compared to 
23

sulfoxaflor. The groundwater EDWC is greater than the surface water EDWC. The residue profile 

in groundwater is 60.9 ppb X11719474 and 8.3 ppb X11519540. Adjusting for the relative 

toxicity results in 18.3 ppb equivalents of X11719474 and 83 ppb X11519540 (totaling 101.3 

ppb). The adjusted groundwater EDWC is greater than the surface water EDWC (9.3 ppb) and 

was used to assess the chronic dietary exposure scenario.

The maximum dietary residue intake via consumption of sorghum commodities would be only a 

small portion of the RfD (<0.001%) and therefore, should not cause any additional risk to 

humans via chronic dietary exposure. Consumption of sorghum by sensitive sub-populations 

such as children and non-nursing infants is essentially zero. Thus, the risk of these 

subpopulations to chronic dietary exposure to sulfoxaflor used on grain sorghum would be 

insignificant.

The major contributor to the risk was water (100%). There was no contribution from grain 

sorghum to the dietary exposure. All other populations under the chronic assessment show risk 

estimates that are below levels of concern. 

Chronic exposure to sulfoxaflor from food and water is 18% of the cPAD for infants, the 

population group receiving the greatest exposure. There are no residential uses for sulfoxaflor.

Short-term risk. Because there is no short-term residential exposure and chronic dietary 

exposure has already been assessed, no further assessment of short-term risk is necessary, the 

chronic dietary risk assessment for evaluating short-term risk for sulfoxaflor is sufficient.

Intermediate-term risk. Intermediate-term risk is assessed based on intermediate-term 

residential exposure plus chronic dietary exposure. Because there is no residential exposure and 

chronic dietary exposure has already been assessed, no further assessment of intermediateterm risk is necessary.

Cumulative effects. Sulfoxaflor does not share a common mechanism of toxicity with any other 

substances, and does not produce a toxic metabolite produced by other substances. Thus, 

sulfoxaflor does not have a common mechanism of toxicity with other substances. 

Cancer. A nonlinear RfD approach is appropriate for assessing cancer risk to sulfoxaflor. This 

approach will account for all chronic toxicity, including carcinogenicity that could result from 

exposure to sulfoxaflor. Chronic dietary risk estimates are below levels of concern; therefore, 

cancer risk is also below levels of concern.

There is a reasonable certainty that no harm will result to the general population, or to infants 

and children from aggregate exposure to sulfoxaflor as used in this emergency exemption 

request.

The above content (Expected Residues for Food Uses) was prepared by Michael 

Hare, Ph.D., Texas Department of Agriculture.

(7) Discussion of risk information
24

Human Health (Toxicological Profile)

Sulfoxaflor is a member of a new class of insecticides, the sulfoximines. It is an activator of the 

nicotinic acetylcholine receptor (nAChR) in insects and, to a lesser degree, mammals. The nervous 

system and liver are the target organs, resulting in developmental toxicity and hepatotoxicity.

Developmental toxicity was observed in rats only. Sulfoxaflor produced skeletal abnormalities 

likely resulting from skeletal muscle contraction due to activation of the skeletal muscle nAChR in 

utero. Contraction of the diaphragm, also related to skeletal muscle nAChR activation, prevented 

normal breathing in neonates and increased mortality. The skeletal abnormalities occurred at high 

doses while decreased neonatal survival occurred at slightly lower levels.

Sulfoxaflor and its major metabolites produced liver weight and enzyme changes, and tumors in 

subchronic, chronic and short-term studies. Hepatotoxicity occurred at lower doses in long-term 

studies compared to short-term studies.

Reproductive effects included an increase in Leydig cell tumors which were not treatment related 

due to the lack of dose response, the lack of statistical significance for the combined tumors, and 

the high background rates for this tumor type in F344 rats. The primary effects on male 

reproductive organs are secondary to the loss of normal testicular function due to the size of the 

Leydig Cell adenomas. The secondary effects to the male reproductive organs are also not 

treatment related. It appears that rats are uniquely sensitive to these developmental effects and 

are unlikely to be relevant to humans.

Clinical indications of neurotoxicity were observed at the highest dose tested in the acute 

neurotoxicity study in rats. Decreased motor activity was also observed in the mid- and high-dose 

groups. Since the neurotoxicity was observed only at a very high dose and many of the effects are 

not consistent with the perturbation of the nicotinic receptor system, it is unlikely that these 

effects are due to activation of the nAChR.

Tumors have been observed in rat and mouse studies. In rats, there were significant increases in 

hepatocellular adenomas in the high-dose males. In mice, there were significant increases in 

hepatocellular adenomas and carcinomas in high dose males. In female mice, there was an 

increase in carcinomas at the high dose. Liver tumors in mice were treatment-related. Leydig cell 

tumors were also observed in the high-dose group of male rats, but were not related to treatment. 

There was also a significant increase in preputial gland tumors in male rats in the high-dose group. 

Given that the liver tumors are produced by a non-linear mechanism, the Leydig cell tumors were 

not treatment-related, and the preputial gland tumors only occurred at the high dose in one sex 

of one species, the evidence of carcinogenicity was weak. 

Ecological Toxicity

Sulfoxaflor (N-[methyloxido[1-[6-(trifluoromethyl)-3-pyridinyl]ethyl]-lambda 4-sulfanylidene]) is 

a new variety of insecticide as a member of the sulfoxamine subclass of neonicotinoid insecticides. 

It is considered an agonist of the nicotinic acetylcholine receptor and exhibits excitatory responses 

including tremors, followed by paralysis and mortality in target insects. Sulfoxaflor consists of two 

diastereomers in a ratio of approximately 50:50 with each diastereomer consisting of two

enantiomers. Sulfoxaflor is systemically distributed in plants when applied. The chemical acts 

through both contact action and ingestion and provides both rapid knockdown (symptoms are 

typically observed within 1-2 hours of application) and residual control (generally provides from 
25

7 to 21 days of residual control). Incident reports submitted to EPA since approximately 1994 have 

been tracked via the Incident Data System. Over the 2012 growing season, a Section 18 

emergency use was granted for application of sulfoxaflor to cotton in four states (MS, LA, AR, TN). 

No incident reports have been received in association with the use of sulfoxaflor in this situation.

Sulfoxaflor is classified as practically non-toxic on an acute exposure basis, with 96-h LC50 values 

of >400 mg a.i./L for all three freshwater fish species tested (bluegill, rainbow trout, and common 

carp). Mortality was 5% or less at the highest test treatments in each of these studies. Treatmentrelated sublethal effects included discoloration at the highest treatment concentration (100% of 

fish at 400 mg a.i./L for bluegill) and fish swimming on the bottom (1 fish at 400 mg a.i./L for 

rainbow trout). No other treatment-related sublethal effects were reported. For an 

estuarine/marine sheepshead minnow, sulfoxaflor was also practically non-toxic with an LC50 of 

288 mg a.i./L. Sublethal effects included loss of equilibrium or lying on the bottom of aquaria at 

200 and 400 mg a.i./L. The primary degradate of sulfoxaflor is also classified as practically nontoxic to rainbow trout on an acute exposure basis (96-h LC50 >500 mg a.i./L).

Adverse effects from chronic exposure to sulfoxaflor were examined with two fish species 

(fathead minnow and sheepshead minnow) during early life stage toxicity tests. For fathead 

minnow, the 30-d NOAEC is 5 mg a.i./L based on a 30% reduction in mean fish weight relative to 

controls at the next highest concentration (LOAEC=10 mg a.i./L). No statistically significant and/or 

treatment-related effects were reported for hatching success, fry survival and length. For 

sheepshead minnow, the 30-d NOAEC is 1.3 mg a.i./L based on a statistically significant reduction 

in mean length (3% relative to controls) at 2.5 mg a.i./L. No statistically significant and/or 

treatment-related effects were reported for hatching success, fry survival and mean weight.

The acute toxicity of sulfoxaflor was evaluated for one freshwater invertebrate species, the water 

flea and two saltwater species (mysid shrimp and Eastern oyster). For the water flea, the 48-h EC50

is >400 mg a.i./L, the highest concentration tested. For Eastern oyster, new shell growth was 

significantly reduced at 120 mg a.i./L (75% reduction relative to control). The 96-h EC50 for shell 

growth is 93 mg a.i./L. No mortality occurred at any test concentration. Mysid shrimp are the most 

acutely sensitive invertebrate species tested with sulfoxaflor based on water column only 

exposures, with a 96-h LC50 of 0.67 mg a.i./L. The primary degradate of sulfoxaflor is also classified 

as practically non-toxic to the water flea (EC50 >240 mg a.i./L).

The chronic effects of sulfoxaflor to the water flea were determined in a semi-static system over 

a period of 21 days to nominal concentrations of 6.25, 12.5, 25, 50 and 100 mg a.i./L. Adult 

mortality, reproduction rate (number of young), length of the surviving adults, and days to first 

brood were used to determine the toxicity endpoints. No treatment-related effects on adult 

mortality or adult length were observed. The reproduction rate and days to first brood were 

significantly (p<0.05) different in the 100 mg a.i./L test group (40% reduction in mean number of 

offspring; 35% increase in time to first brood). No significant effects were observed on survival, 

growth or reproduction at the lower test concentrations. The 21-day NOAEC and LOAEC were 

determined to be 50 and 100 mg a.i./L, respectively.

The chronic effects of sulfoxaflor to mysid shrimp were determined in a flow-through system over 

a period of 28 days to nominal concentrations of 0.063, 0.13, 0.25, 0.50 and 1.0 mg a.i./L. 

Mortality of parent (F0) and first generation (F1), reproduction rate of F0 (number of young), length 

of the surviving F0 and F1, and days to first brood by F0 were used to determine the toxicity 
26

endpoints. Complete F0 mortality (100%) was observed at the highest test concentration of 1.0 

mg a.i./L within 7 days; no treatment-related effects on F0/F1 mortality, F0 reproduction rate, or 

F0/F1 length were observed at the lower test concentrations. The 28-day NOAEC and LOAEC were

determined to be 0.11 mg and 0.25 mg a.i./L, respectively.

Sulfoxaflor exhibited relatively low toxicity to aquatic non-vascular plants. The most sensitive 

aquatic nonvascular plant is the freshwater diatom with a 96-h EC50 of 81.2 mg a.i./L. Similarly,

sulfoxaflor was not toxic to the freshwater vascular aquatic plant, Lemna gibba, up to the limit 

amount, as indicated by a 7-d EC50 for frond count, dry weight and growth rate of >100 mg a.i./L 

with no significant adverse effects on these endpoints observed at any treatment concentration.

Based on an acute oral LD50 of 676 mg a.i./kg bw for bobwhite quail, sulfoxaflor is considered 

slightly toxic to birds on an acute oral exposure basis. On a subacute, dietary exposure basis, 

sulfoxaflor is classified as practically nontoxic to birds, with 5-d LC50 values of >5620 mg/kg-diet 

for mallard ducks and bobwhite quail. The NOAEL from these studies is 5620 mg/kg-diet as no 

treatment related mortality of sublethal effects were observed at any treatment. Similarly, the 

primary degradate is classified as practically nontoxic to birds on an acute oral exposure basis with 

a LD50 of >2250 mg a.i./kg bw. In two chronic, avian reproductive toxicity studies, the 20-week 

NOAELs ranged from 200 mg/kg-diet (mallard, highest concentration tested) to 1000 mg/kg-diet 

(bobwhite quail, highest concentration tested). No treatment-related adverse effects were 

observed at any test treatment in these studies.

For bees, sulfoxaflor is classified as very highly toxic with acute oral and contact LD50 values of 

0.05 and 0.13 μg a.i./bee, respectively, for adult honey bees. For larvae, a 7-d oral LD50 of >0.2 μg 

a.i./bee was determined (45% mortality occurred at the highest treatment of 0.2 μg a.i./bee). The 

primary metabolite of sulfoxaflor is practically non-toxic to the honey bee. This lack of toxicity is 

consistent with the cyano-substituted neonicotinoids where similar cleavage of the cyanide group 

appears to eliminate their insecticidal activity. The acute oral toxicity of sulfoxaflor to adult 

bumble bees (Bombus terrestris) is similar to the honey bee; whereas its acute contact toxicity is 

about 20X less toxic for the bumble bee. Sulfoxaflor did not demonstrate substantial residual 

toxicity to honey bees exposed via treated and aged alfalfa (i.e., mortality was <15% at maximum 

application rates). 

At the application rates used (3-67% of US maximum), the direct effects of sulfoxaflor on adult 

forager bee mortality, flight activity and the occurrence of behavioral abnormalities is relatively 

short-lived, lasting 3 days or less. Direct effects are considered those that result directly from 

interception of spray droplets or dermal contact with foliar residues. The direct effect of 

sulfoxaflor on these measures at the maximum application rate in the US is presently not known. 

When compared to control hives, the effect of sulfoxaflor on honey bee colony strength when 

applied at 3-32% of the US maximum proposed rate was not apparent in most cases. When 

compared to hives prior to pesticide application, sulfoxaflor applied to cotton foliage up to the 

maximum rate proposed in the US resulted in no discernible decline in mean colony strength by 

17 days after the first application. Longer-term results were not available from this study nor were 

concurrent controls included. For managed bees, the primary exposure routes of concern include 

direct contact with spray droplets, dermal contact with foliar residues, and ingestion through 

consumption of contaminated pollen, nectar and associated processed food provisions. Exposure 

of hive bees via contaminated wax is also possible. Exposure of bees through contaminated 
27

drinking water is not expected to be nearly as important as exposure through direct contact or 

pollen and nectar.

In summary, sulfoxaflor is slightly toxic to practically non-toxic to fish and freshwater water 

aquatic invertebrates on an acute exposure basis. It is also practically non-toxic to aquatic plants 

(vascular and non-vascular). Sulfoxaflor is highly toxic to saltwater invertebrates on an acute 

exposure basis. The high toxicity of sulfoxaflor to mysid shrimp and benthic aquatic insects 

relative to the water flea is consistent with the toxicity profile of other insecticides with similar 

MOAs. For birds and mammals, sulfoxaflor is classified as moderately toxic to practically nontoxic on an acute exposure basis. The threshold for chronic toxicity (NOAEL) to birds is 200 ppm 

and that for mammals is 100 ppm in the diet. Sulfoxaflor did not exhibit deleterious effects to 

terrestrial plants at or above its proposed maximum application rates. 

For bees, sulfoxaflor is classified as very highly toxic. However, if this insecticide is strictly used as 

directed on the Section 18 supplemental label, no significant adverse effects are expected to 

Louisiana wildlife. Of course, standard precautions to avoid drift and runoff to waterways of the 

state are warranted. As stated on the Section 3 label, risk to managed bees and native pollinators 

from contact with pesticide spray or residues can be minimized when applications are made 

before 7 am or after 7 pm or when the temperature is below 55◦

F at the site of application.

Environmental Fate

Sulfoxaflor is a systemic insecticide which displays translaminar movement when applied to 

foliage. Movement of sulfoxaflor within the plant follows the direction of water transport within 

the plant (i.e., xylem mobile) as indicated by phosphor translocation studies in several plants. 

Sulfoxaflor is characterized by a water solubility ranging from 550 to 1,380 ppm. Sulfoxaflor has a 

low potential for volatilization from dry and wet surfaces (vapor pressure= 1.9 x 10-8 torr and 

Henry’s Law constant= 1.2 x 10-11 atm m3 mole-1

, respectively at 25 °C). Partitioning coefficient of 

sulfoxaflor from octanol to water (Kow @ 20 C & pH 7= 6; Log Kow = 0.802) suggests low potential 

for bioaccumulation. No fish bioconcentration study was provided due to the low Kow, but 

sulfoxaflor is not expected to bioaccumulate in aquatic systems. Furthermore, sulfoxaflor is not 

expected to partition into the sediment due to low Koc (7-74 mL/g).

Registrants tests indicate that hydrolysis, and both aqueous and soil photolysis are not expected 

to be important in sulfoxaflor dissipation in the natural environment. In a hydrolysis study, the 

parent was shown to be stable in acidic/neutral/alkaline sterilized aqueous buffered solutions (pH 

values of 5, 7 and 9). In addition, parent chemical as well as its major degradate, were shown to 

degrade relatively slowly by aqueous photolysis in sterile and natural pond water (t1⁄2= 261 to 

>1,000 days). Furthermore, sulfoxaflor was stable to photolysis on soil surfaces. Sulfoxaflor is 

expected to biodegrade rapidly in aerobic soil (half-lives <1 day). Under aerobic aquatic 

conditions, biodegradation proceeded at a more moderate rate with half-lives ranging from 37 to 

88 days. Under anaerobic soil conditions, the parent compound was metabolized with half-lives 

of 113 to 120 days while under anaerobic aquatic conditions the chemical was more persistent 

with half-lives of 103 to 382 days. In contrast to its short-lived parent, the major degradate is 

expected to be more persistent than its parent in aerobic/anaerobic aquatic systems and some 

aerobic soils. In other soils, less persistence is expected due to mineralization to CO2 or the 

formation of other minor degradates.
28

In field studies, sulfoxaflor has shown similar vulnerability to aerobic bio-degradation in nine out 

of ten terrestrial field dissipation studies on bare-ground/cropped plots (half-lives were <2 days 

in nine cropped/bare soils in CA, FL, ND, ON and TX and was 8 days in one bare ground soil in TX). 

The chemical can be characterized by very high to high mobility (Kfoc ranged from 11-72 mL g-1

). 

Rapid soil degradation is expected to limit chemical amounts that may potentially leach and 

contaminate ground water. Contamination of groundwater by sulfoxaflor will only be expected 

when excessive rain occurs within a short period (few days) of multiple applications in vulnerable 

sandy soils. Contamination of surface water by sulfoxaflor is expected to be mainly related to drift 

and very little due to run-off. This is because drifted sulfoxaflor that reaches aquatic systems is 

expected to persist while that reaching the soil system is expected to degrade quickly with slight 

chance for it to run-off.

When sulfoxaflor is applied foliar on growing crops it is intercepted by the crop canopy. Data 

presented above appear to indicate that sulfoxaflor enters the plant and is incorporated in the 

plant foliage with only limited degradation. It appears that this is the main source of the 

insecticide sulfoxaflor that would kill sap sucking insects. This is because washed-off sulfoxaflor, 

that reaches the soil system, is expected to degrade.

In summary, sulfoxaflor has a low potential for volatilization from dry and wet surfaces. This 

chemical is characterized by a relatively higher water solubility. Partitioning coefficient of 

sulfoxaflor from octanol to water suggests low potential for bioaccumulation in aquatic organisms 

such as fish. Sulfoxaflor is resistant to hydrolysis and photolysis but transforms quickly in soils. In 

contrast, sulfoxaflor reaching aquatic systems by drift is expected to degrade rather slowly. 

Partitioning of sulfoxaflor to air is not expected to be important due to the low vapor pressure 

and Henry’s Law constant for sulfoxaflor. Exposure in surface water results from the drifted parent 

compound, and only minor amounts are expected to run-off only when rainfall and/or irrigation 

immediately follow application. The use of this insecticide is not expected to adversely impact 

Louisiana ecosystems when used according to the Section 18 label. Of course, caution is needed 

to prevent exposure to water systems because of toxicity issues to aquatic invertebrates. As

stated on the Section 3 label, this product should never be applied directly to water, to areas 

where surface water is present or to intertidal areas below the mean water mark. Also, the label 

includes the statement “Do not contaminate water when disposing of equipment rinsate.”

Endangered Species 

A list of the endangered species present in this application was obtained from the US Fish and 

Wildlife Service website (Attachment C). None of these species are expected to be impacted by 

applications of sulfoxaflor to control plant bugs, due to very low toxicity to these organisms and/or 

the fact that they do not occur in the Tennessee cotton ecosystem. This product does adversely 

affect insects, including bees, and aquatic invertebrates, but the limited exposure to these species 

should not negatively affect endangered and threatened species when all applications label 

precautions are followed and preformed.

Resulting Environment from Sulfoxaflor Use

Tennessee’s farmscape should experience a reduction in the number of insecticide applications

used to control tarnished plant bug. This reduction will be even more important considering that 

many of those replaced applications will be for organophosphate or carbamate insecticides. The 

availability of sulfoxaflor on cotton will directly reduce alternative sprays for the target pest, but 
29

also reduce the probability of flaring secondary pests such as spider mites and aphids. This can 

further reduce the number of total insecticide applications on cotton.

The above content (Discussion of Risk Information) was, for the most part, 

prepared by Michael Hare, Ph.D. (Human Health Effects), David Villarreal, Ph.D. 

(Ecological Effects), and David Villarreal, Ph.D. (Environmental Fate), all with the 

Texas Department of Agriculture. 

(8) Coordination with other affected State or Federal agencies.

The Tennessee Wildlife Resource Agency will receive a copy of this request. Any comments 

received will be forwarded to the U.S. EPA.

(9) Notification/support of registrant.

Dow AgroSciences has been notified of this agency’s intent regarding this application and has 

provided a letter of support (Attachment D). They also provided the copy of a proposed section 

18 label with directions for use of this product if this emergency exemption is approved.

(10) Description of proposed enforcement program.

The Tennessee Department of Agriculture (TDA) has adequate authorities for enforcing 

provisions of Section 18 emergency exemptions. TDA will require Dow AgroSciences to prepare 

Section 18 labeling that complies with TDA and EPA requirements for this emergency use, if 

approved, to ensure that product distributed for the exemption is properly labeled.

(11) Repeated uses.

This is the second time that the TDA has requested as applied for this specific exemption. A 

section 18 was previously granted in Tennessee during 2012.

(b) Information required for a specific exemption.

(1) The scientific and common name of the pest or pest complex:

Lygus lineolaris (Palisot de Beauvois), tarnished plant bug 

(2) A discussion of the events which brought about the emergency condition:

Tarnished plant bug has become the number one pest in Tennessee. Prior to the mid 1990’s, 

tarnished plant bugs were generally controlled by insecticides directed at other pests during the 

flowering period of cotton; therefore, economic damage from tarnished plant bugs during 

flowering was relatively uncommon. However, with > 90% of Midsouthern (Arkansas, Louisiana, 

Mississippi, Tennessee) cotton now being planted to transgenic cotton expressing one or more 

toxins derived from Bacillus thuringiensis (Bt) (Williams 2008) and the eradication of the boll 

weevil, Anthonomus grandis grandis Boheman (Coleoptera: Curculionidae), many of the foliar 

applications for other pests during flowering have been eliminated. An increase in federal 

conservation/wetlands reserve programs, wide scale adoption of conservation tillage systems, 
30

and increased diversity of the summer farmscape have created a more favorable environment 

enhancing populations of tarnished plant bugs. The region has also experienced a significant 

reduction in cotton acres. Cotton serves as a sink crop for tarnished plant bugs, and there is an 

increasingly clear inverse correlation between cotton acres and infestation levels of tarnished 

plant bugs. The consequence of these changes is that tarnished plant bug has become the 

dominant, season long pest across this region during the last decade. Because of higher 

populations which persist longer during the season, control costs and crop losses associated with 

tarnished plant bugs have increased substantially. Prior to 2004, fewer than two applications per 

season were typically directed towards this pest. However, applications for tarnished plant bug 

have been increasing steadily, with private consultants reporting the need to treat for plant bugs 

an average of 4-7 times per season with individual fields being sprayed eight or more times (Fig. 

1). Insecticide applications for secondary pests, specifically spider mites and aphids, were also on 

the rise. Notably, applications for these secondary pests have decreased once Transform WG

became widely used, and yields have increased despite the increasing pest pressure (Tables 10 

and 11). These statistics do not fully account for all applications which are, at least in part, 

targeting tarnished plant bug because bollworm and stink bug applications often include tank 

mixes with the goal of targeting a pest complex that includes plant bugs.

In addition, an increase in the frequency of chemical control strategies for this pest has intensified 

selection for resistance. Snodgrass and Gore (2007) has reported resistance to a number of OP’s, 

carbamates, and pyrethroids. Producers were relying heavily on neonicotinoids (thiamethoxam, 

imidacloprid), but now some populations are showing reduced sensitivity to those products. In 

addition, the actual seasonal AI/acre of neonicotinoids further restricts product availability. In 

order to obtain some level of population management, there has been an increase in use rates to 

the highest labeled doses. Tarnished plant bug management in many Midsouthern fields has 

degraded to a point where the only option to reduce yield impacts is the co-application of 

insecticides with different modes of action. As referenced by Luckmann and Metcalf (1982) on 

the stages of crop protection, cotton producers and pest management practitioners are in crisis 

phase with tarnished plant bug. The subsequent step is that of the disaster phase which would 

result in a collapse of the existing pest management system for cotton grown in the Mid-South. 

Exacerbating the current situation are poor commodity prices for 2016 and substantially 

increased control costs for herbicide-tolerant weeds. Budgets are tight, and even small 

improvements in yields or reduced control costs for plant bugs might make the difference 

between a profitable year and a net loss for farmers. Tennessee growers are facing an economic 

crisis, partly due to the tarnished plant bug because control costs and yield loss have nearly tripled 

in the last decade. The most expensive insecticide is the one that does not work, and losing 

Transform WG has imposed a substantial economic burden on Tennessee farmers.

3) A discussion of the anticipated risks to endangered or threatened species, beneficial 

organisms, or the environment that would be remedied by the proposed use of the pesticide;

See above discussion. Sulfoxaflor is expected to replace alternative products that are used at 

higher rates and represent greater risk to the environment and beneficial organisms. See 

Attachment C (Tennessee Endangered and Threatened Species List 2015).

(4) A discussion of the anticipated significant economic loss, together with data and other 

information supporting the discussion that addresses one or more of the following, as 

appropriate:
31

(i) Yield or utilized yield reasonably anticipated in the absence of the emergency and 

expected losses in quantity due to the emergency;

(ii) The information in paragraph (b) (4) (i) of this section plus prices reasonably anticipated in 

the absence of the emergency and changes in prices and/or production costs due to the 

emergency;

(iii) The information in paragraph (b) (4) (ii) of this section plus operating costs reasonably 

anticipated in the absence of the emergency;

The information below demonstrates the substantial economic impact that plant bugs are 

having in the Mid-South and Tennessee. These data also demonstrate that since Transform has 

become available for use in cotton, producers have benefited greatly both in terms of revenue 

and increased yield protection. Furthermore, during the four year period that Transform has 

been used, there have been no reports of bee kills associated with this product. Many growers 

in regions with only moderate resistance levels have also benefitted from the safety toward 

beneficial insect populations in the field. Overall, Transform has become one of the foundation 

products in our IPM cotton program.

Table 10. Foliar insecticide costs, yield loss, and the total costs (costs + loss) of managing tarnished 

plant bug in Tennessee over the past 12 season. Control costs for tarnished plant bugs has nearly 

tripled in the last decade. These data represent averages across all of Tennessee, and thus, dilute 

the impact observed in some areas or fields that are more affected by tarnished plant bug.

Year Yield Foliar Costs % Yield Cost + Loss

($/acre) Loss ($/acre)

2012-2015 928 $31.09 3.20 $52 

2008-2011 848 $14.79 2.01 $27 

2004-2007 777 $12.22 0.93 $18 

% Change 19.4 154.4 244.1 188.9

*Assumes gross $0.70/lb lint value (includes equities and seed check).

Table 11. Yield, yield losses, and the number of insecticide applications for plant bug (PB) and 

also for secondary pests (e.g., spider mites and cotton aphids) in the Midsouth and Tennessee. In 

recent years, yield losses caused by plant bugs have almost doubled despite more insecticide 

applications. Note that since Transform WG was introduced (2012), average yields have increased 

in the region by over 20% and in Tennessee by about 10%. Also applications and yield loss caused 

by spider mites and aphids have decreased during this same time frame.

Sources:

Cotton Insect Losses, http://www.entomology.msstate.edu/resources/cottoncrop.asp
32

NASS Yields, http://www.nass.usda.gov/Statistics_by_State/Tennessee/

It is relatively easy to project that the loss of Transform WG for Tennessee cotton producers could 

result in increased crops losses and more and less effective pesticide applications for plant bugs 

and secondary pests that could exceed 20% of their net revenue, this in an economic environment 

where commodity prices already make profitability questionable (and this is true of other major 

row crops including corn and soybean).

(iv) Any other information explaining the economic consequences of the emergency.

Summary of the Current Situation Facing West Tennessee Producers: Tennessee producers are 

spraying more than ever for tarnished plant bugs. Growers in Tennessee can expect similar or 

higher pest populations during the 2016 season. The absence of new products to manage 

tarnished plant bug has seriously impaired the economic viability of cotton across in parts of 

Tennessee and much of the Mid-South. Use of currently available products is not economically 

and environmentally sustainable. Resistance to pyrethroid insecticides, some organophosphates, 

and now neonicotinoids have left Tennessee with essentially few alternative insecticides to 

control plant bugs. As previously discussed, resistance and resistance management, the likelihood 

of flaring secondary pests, label restrictions, and other factors limit the utility of these products. 

Because sulfoxaflor (Transform WG) is a novel mode of action with no known resistance, it will 

greatly enhance the producer’s ability to manage tarnished plant bugs. Prior to the label being 

revoked, Transform WG sulfoxaflor had become part of a holistic IPM program for cotton growers.

References used to support previous statements and Section 18 request:

Babcock, J. M, C. B. Gerwick, J. X. Huang, M. R. Loso, G. E. Nakamura, S. P. Nolting, R. B. Rogers, T. 

C. Sparks, J. D. Thomas, G. B. Watson and Y. Zhu. 2010. Biological Characterization of Sulfoxaflor, 

a Novel Insecticide. Pest Mgmt. Sci. 67: 328-334.

Copes, J. T., G. L. Snodgrass, J. Sharp, B. R. Leonard, D. R. Ring, and D. Blouin. 2010. Acephate 

resistance is widespread in Louisiana tarnished plant bug populations. La. Agric. 53: 14-15.

Gore, J., G. Andrews, J. Robbins, A. Catchot, F. Musser, J. Smith, G. Snodgrass, R. Jackson, C. Abel, 

D. Dodds, G. Lorenz, S. Akin, G. Studebaker, R. Leonard, R. Bagwell, S. Stewart, and K. Tindall. 

2008. Strategies for managing tarnished plant bugs in cotton. Miss. State Univ. White Paper 

Recommendations Report, 4 pp., released April 2008. 

Lorenz, G, T. Barber, S. D. Stewart, A. Catchot, J. Gore and D. Cook. 2009. Evolving pest 

management in cotton. Proc. Beltwide Cotton Conf. 1395.

Luckmann W. H. and R. L. Metcalf. 1982. Why pest management, pp. 1-33? In R. Metcalf and W. 

Luckmann eds. Introduction to Pest Management. John Wiley and Sons, New York, NY. 

Moore, J. L., J. H. Temple, J. T. Hardke, K. Emfinger, P. P. Price, J. T. Copes, J. W. Sharpe, E. Burris 

and K. A. Fontenot. 2010. Proc. Beltwide Cotton Conf. 817-819. 

Sharp, J. W., J. T. Copes, B. R. Leonard, E. Burris, P. P. Price, J. H. Temple and J. T. Hardke. 2010.

Can we rely on any single insecticide for season long tarnished plant bug control in Louisiana 
33

cotton, p. 1170. In Proceedings, 2010 Beltwide Cotton Conferences, National Cotton Council, 

Memphis, TN.

Snodgrass, G. L. 1996. Insecticide resistance in field populations of the tarnished plant bug 

(Heteroptera: Miridae) in cotton in the Mississippi Delta. J. Econ. Entomol. 89: 783-790.

Snodgrass, G. L. and W. P. Scott. 2000. Seasonal changes in pyrethroid resistance in tarnished 

plant bug (Heteroptera: Miridae) populations during a three-year period in the delta area of 

Arkansas, Louisiana, and Mississippi. J. Econ. Entomol. 93: 441-446.

Snodgrass, G. L. and J. Gore. 2007. Status of insecticide resistance for the tarnished plant bug, pp. 

56-59. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Snodgrass, G. L., J. Gore, C. A. Abel, and R. Jackson. 2008. Predicting field control of tarnished 

plant bug (Heteroptera: Miridae) populations with pyrethroid insecticides by use of glass-vial 

bioassays. Southwestern Entomologist 33: 181-189.

Snodgrass, G. L., C. A. Abel, R. E. Jackson, and J. Gore. 2008. A Bioassay for Determining Resistance 

Levels in Tarnished Plant Bug Populations to Neonicotinoid Insecticides. Southwestern 

Entomologist 33: 173-180. 

Stewart, S. and A. McClure. 2016. Insect control recommendations for field crops. University of 

Tennessee Extension, PB 1768, 

http://www.utcrops.com/cotton/cotton_insects/InsectBook.htm. 

Williams, M. R. 2008. Cotton insect losses. In Proc. Beltwide Cotton Res. Conf., National Cotton 

Council, Memphis, TN. (but also available at

http://www.entomology.msstate.edu/resources/cottoncrop.asp). 

Williams, M. R. 2004-2014. Cotton insect losses. In Proc. Beltwide Cotton Res. Conf., National 

Cotton Council, Memphis, TN. (but also available at

http://www.entomology.msstate.edu/20resources/cottoncrop.asp).

Willrich-Siebert, M., L.C Walton, R.B. Lassiter, R.A. Haygood, J.D. Thomas, and J.S. Richburg. 2010. 

Performance of Dow AgroSciences’ Sulfoxaflor insecticides against tarnished plant bug, Lygus 

lineolaris, in Mid-South cotton, pp. 1204. . In Proc. Beltwide Cotton Res. Conf., National Cotton 

Council, Memphis, TN.

Zhu, Y., J. Adamczyk, T. Rinderer, J. Yao, R. Danka, R. Luttrell, and J. Gore. 2015. Spray toxicity and 

risk potential of 42 commonly used formulations of row crop pesticides to adult honey bees 

(Hymenoptera: Apidae). J. Econ. Entomol. 108:2640-2647.

Zhu, Y., M. R. Loso, G. B. Watson, T. C. Sparks, R. B. Rogers, J. X. Huang, C. B. Gerwick, J. M. 

Babcock, D. Kelley, V. B. Hegde, B. M. Nugent, J. M. Renga, I. Denholm, K. Gorman, G. DeBoer, J. 

Hasler, T. Meade, and J. D. Thomas. 2011. Discovery and Characterization of Sulfoxaflor: A Novel 

Sap-Feeding Insecticide. J. Agric. Food Chem. 59(7): 2950-2957.