Page 3 of 39

1. Executive Summary

Sulfoxaflor {[N-methyloxido[1-[6-(trifluoromethyl)-3-pyridinyl]ethyl] λ4-sulfanylidene] 

cyanamide} is the first member of a new class of insecticides, the sulfoximines. The 

sulfoximines act through a unique interaction with the nicotinic acetylcholine receptor in insects. 

Sulfoxaflor is a highly efficacious agonist of the nicotinic receptor. Furthermore, the structural 

novelty of sulfoxaflor makes it stable in the presence of monooxygenase enzymes that degrade 

neonicotinoids and cause virtually all known cases of resistance in the field of this class of 

insecticides.

A Section 3 registration was requested by Dow AgroSciences for use of the new insecticide 

sulfoxaflor on a variety of food crops, turfgrass (sod farms) and commercially grown 

ornamentals. The proposed uses are the first uses of sulfoxaflor in the United States. Sulfoxaflor 

may be applied through a variety of application methods including air, ground, and chemigation 

at a maximum single application rate of 0.133 lb ai/A (0.266 lb ai/A/year). 

This assessment addresses exposure and risk associated with the proposed end-use products for 

sulfoxaflor when used as directed by occupational workers. There is a potential for occupational 

exposure associated with handler activities (i.e., mixing, loading, and applying) as well as with 

post-application activities (i.e., re-entering treated areas). There are no registered or proposed 

residential uses associated with sulfoxaflor at this time. Based on the use patterns (i.e., 2-4 

applications per season) and resistance management practices, the duration of exposure for the 

proposed food uses is expected to be short- term (1 to 30 days) and intermediate-term (1 to 6 

months). Long-term exposures (greater than 6 months) are not anticipated.

No residential uses, and no commercial/professional uses at residential sites are being requested 

for sulfoxaflor at this time. There is a proposed use on ornamental plants; however, the proposed 

use is only for nurseries and commercial greenhouses. Furthermore, exposure from homeowners 

buying turfgrass (sod) and planting it as a residential turf would be minimal. At this time, there 

are no uses of sulfoxaflor that will result in residential exposures. 

Hazard Profile and Points of Departure (POD)

In mammals, sulfoxaflor targets the neurological and hepatic organ systems. Neurological 

effects include skeletal muscle contraction that can lead to increased neonatal deaths. The rat 

appears to be uniquely sensitive to this effect and the mode of action is likely not relevant to 

humans. Repeated exposure to sulfoxaflor can lead to tumor formation in the liver and preputial 

gland. The Cancer Assessment Review Committee (CARC) has classified sulfoxaflor as 

“Suggestive Evidence of Carcinogenic Potential.” 

Dermal and inhalation exposures are assessed using an oral endpoint, increased neonatal deaths 

observed in the developmental neurotoxicity study at 7.1 mg/kg/day with a NOAEL of 1.8 

mg/kg/day. A route-specific dermal study was available for endpoint selection, however the 

developmental endpoint was chosen because it includes reproductive and developmental 

parameters not measured in the dermal study. The Agency is using 2.4% as the dermal 

absorption factor (DAF) for determining dermal-equivalent doses. Since a subchronic inhalation 
Page 4 of 39

study is not available, toxicity by the inhalation route is considered to be equivalent to toxicity 

by the oral route of exposure. Although the database does not contain an inhalation study, HED 

has determined that this study is not required for sulfoxaflor and is not considered a data gap. 

Therefore, a database uncertainty factor is not required (HASPOC Memo. TXR No. 0056310). 

The residual uncertainty for developmental effects is low and therefore the FQPA Safety Factor 

for children and infants is reduced to 1X. Additionally, the uncertainty factor for extrapolating 

from rat to human was also reduced from 10X to 3X based pharmacodynamic differences 

between the rat and human.

Daily dermal and inhalation doses associated with the proposed uses were combined to 

determine a total margin of exposure (MOE), or risk estimate for occupational workers, because 

the same study (with the same effects) was used for both routes of exposure. The level of 

concern (LOC) for dermal and inhalation exposure estimates is an MOE of 30 (i.e., MOEs 

greater than 30 are not of concern). 

Occupational Handlers Exposure

It is HED policy to use the best available data to assess handler exposure. Sources of generic 

handler data, used as surrogate data in the absence of chemical-specific data, include the 

Pesticide Handlers Exposure Database Version 1.1 (PHED 1.1), the Outdoor Residential 

Exposure Task Force (ORETF) database and the Agricultural Handler Exposure Task Force 

(AHETF) database, or other registrant-submitted occupational exposure studies. Some of these 

data are proprietary (e.g., AHETF data), and subject to the data protection provisions of FIFRA. 

Default assumptions established by HED’s Science Advisory Council for Exposure were used 

for parameters such as body weight, acres treated and amount handled.

The short- and intermediate-term PODs are the same and therefore, only a short-term handler 

exposure was estimated which is considered protective of intermediate-term exposures. All 

combined (dermal + inhalation) occupational handler scenarios resulted in MOEs greater than 

the LOC of 30 at the baseline level of personal protective equipment (PPE; i.e. single layer 

clothing, no gloves and no respirator), and with the use of engineering controls for aerial 

applications.

Occupational Post-application Exposure

Inhalation

Since the proposed uses of sulfoxaflor are for outdoor settings where post-application inhalation 

exposures are expected to be minimal, and because sulfoxaflor has a low vapor pressure (1.05 ×

10-8 mm Hg at 25°C), handler inhalation exposure estimates are considered to be protective of 

occupational post-application inhalation exposure scenarios. A quantitative post-application 

inhalation exposure assessment was not conducted, either for the proposed new uses (i.e., 

outdoor settings) or for the greenhouse use (i.e., indoor settings). Furthermore, the Worker 

Protection Standard for Agricultural Pesticides contains requirements for protecting workers 
Page 5 of 39

from inhalation exposures during and after greenhouse applications through the use of ventilation 

requirements [40 CFR 170.110, (3) (Restrictions associated with pesticide applications)].

Dermal

There is potential for short- and intermediate-term occupational exposure during post-application 

activities. Chemical-specific dislodgeable foliar residue (DFR) studies were submitted by the 

registrant and reviewed by HED (MRID Nos. 47832415, 47832416). The results of the DFR 

studies are summarized in Appendix A. Post-application dermal exposure and risk estimates 

resulted in MOEs greater than the LOC of 30 and are not of concern on Day 0 (i.e., 12 hours 

after application).

Sulfoxaflor is classified as Toxicity Category IV via the dermal route and for skin irritation 

potential. It is not a skin sensitizer. Short- and intermediate-term post-application risk estimates 

were not a concern on day 0 (12 hours following application) for all post-application activities. 

Under 40 CFR 156.208 (c) (2) (iii), active ingredients classified as Acute III or IV for acute 

dermal, eye irritation and primary skin irrigation are assigned a 12-hour REI. Therefore, the 

[156 subpart K] Worker Protection Statement interim REI of 12 hours is adequate to protect 

agricultural workers from post-application exposures to sulfoxaflor. It should be noted that the 

petitioner has proposed a REI of 24 hours for the proposed products based on their interpretation 

of the acute ocular toxicity study of the TransformTM WG formulated product resulting in a 

Toxicity Category II for eye irritation. HED recommends that RD ensure that the proper REI is 

listed on both proposed labels according to the acute toxicity profile of the active ingredient.

Review of Human Research

This risk assessment relies in part on data from studies in which adult human subjects were 

intentionally exposed to a pesticide or other chemical. These data, which include studies from 

the Pesticide Handlers Exposure Database Version 1.1 (PHED 1.1); the Agricultural Handler 

Exposure Task Force (AHETF) database; the Outdoor Residential Exposure Task Force 

(ORETF) database; the Agricultural Re-entry Task Force (ARTF) database; other registrantsubmitted exposure studies (MRID Nos. 47832415, 47832416); are subject to ethics review 

pursuant to 40 CFR 26, have received that review, and are compliant with applicable ethics 

requirements. For certain studies that review may have included review by the Human Studies 

Review Board. Descriptions of data sources as well as guidance on their use can be found at:

http://www.epa.gov/pesticides/science/handler-exposure-data.html and 

http://www.epa.gov/pesticides/science/post-app-exposure-data.html.

2. Hazard Characterization

Sulfoxaflor is the first member of a new class of insecticides, the sulfoximines, whose pesticidal 

mode of action is agonism of the nicotinic acetylcholine receptor. In mammals, sulfoxaflor 

primarily effect s the nervous system and liver. Similar to insects, sulfoxaflor is an agonist of the 

fetal isoform of the intermuscular nicotinic acetylcholine receptor. This interaction results in the 

contraction of skeletal muscles causing limb flexure and bent clavicle in fetuses and decreased 
Page 6 of 39

neonatal survival due to the constriction of the diaphragm muscles. This mode of action (MOA)

is restricted to the early lifestages in the rat (i.e., late gestation and postnatal days 0-4) and is not 

likely to be relevant to humans. The rat appears to be uniquely sensitive to this effect. Repeated 

exposure to sulfoxaflor causes hepatoxicity. 

In addition, tumors were observed in the liver of rats and mice and the preputial gland in rats in 

the chronic rat and mouse studies. The CARC, in accordance with the EPA's Final Guidelines 

for Carcinogen Risk Assessment (March, 2005), determined that there is a “Suggestive Evidence 

of Carcinogenic Potential” for sulfoxaflor. When there is suggestive evidence, the Agency does 

not attempt a dose-response assessment as the nature of the data generally would not support 

one. Therefore, the Agency has determined that quantification of risk using a non-linear 

approach (i.e., reference dose (RfD)) will adequately account for all chronic toxicity, including 

carcinogenicity, that could result from exposure to sulfoxaflor. 

The endpoint used for short- and intermediate-term dermal and inhalation exposure was 

increased neonatal deaths observed in the developmental neurotoxicity study at 7.1 mg/kg/day 

with a NOAEL of 1.8 mg/kg/day. This effect is restricted to exposures during the early 

lifestages in the rat (i.e., late gestation and postnatal days 0-4) and is not likely to be relevant to 

humans. However, it is protective of pregnant workers and, therefore, appropriate for 

occupational exposure scenarios. A route-specific dermal study was available for endpoint 

selection, however the developmental endpoint was chosen because it includes reproductive and 

developmental parameters not measured in the dermal study. Although a route-specific dermal 

study was available for endpoint selection, the developmental endpoint was chosen because it is 

protective of reproductive and developmental parameters not measured in the dermal study. The 

Agency is using 2.4% as the dermal absorption factor (DAF) for determining dermal-equivalent 

doses. The DAF was determined from a comparison of a rat in vivo and rat and human in vitro 

studies. An inhalation study is not available so the Agency is assuming similar toxicity for the 

oral and inhalation routes of exposure (i.e., a 100% inhalation factor).

An acceptable guideline inhalation study is required for all food-use registrations; however in the 

case of sulfoxaflor, the use of an oral study is considered protective for inhalation exposure for 

the following reasons: 

1) The acute inhalation toxicity (Category IV) is lower than the acute oral LD50 

(Category III); 

2) The vapor pressure is low (≤1.4×10-6Pa or 1.05×10-8 mm Hg) at 20°C); 

3) There is adequate characterization of toxicity; 

4) Oral absorption is >90% – substantially higher absorption via the inhalation route 

is not expected; 

5) Oral absorption is rapid; 

6) Sulfoxaflor is not subject to enterohepatic circulation, making the absorbed oral 

dose available systemically; and 

7) Sulfoxaflor is not subject to in vivo metabolism and therefore potential first-pass 

effects are not relevant. 
Page 7 of 39

Therefore, the subchronic inhalation study is waived for sulfoxaflor. The lack of a subchronic 

inhalation study is not considered a data gap and a database uncertainty factor is not required 

(HASPOC Memo. TXR No. 0056310). 

The FQPA Safety for the protection of infants and children is reduced to 1X. Although there 

was quantitative susceptibility observed in the DNT, there is no residual uncertainty because the 

effects are well characterized, a clear NOAEL was identified, and the endpoints chosen for risk 

assessment are protective of potential in utero and developmental effects. In addition to 

reducing the FQPA safety factor, HED further reduced the 10X interspecies factor (UFA) to 3X 

for scenarios assessed using the neonatal death endpoint (i.e., dermal and inhalation risk 

assessments). This recommendation is based on mechanistic data which indicate that rats are 

uniquely sensitive to the developmental effects of sulfoxaflor and the human muscle nicotinic 

receptor is not responsive to perturbation by sulfoxaflor. Therefore, from a pharmacodynamic 

stance, the human is not more sensitive than the rat and therefore the pharmacodynamic portion 

of the UFA can be reduced.

Daily dermal and inhalation doses associated with the proposed uses were combined to 

determine a total MOE, or risk estimate for occupational workers, because the same study (with 

the same effects) was used for both routes of exposure. The LOC for dermal and inhalation 

exposure estimates is an MOE of 30 (i.e., MOEs greater than 30 are not of concern).

The acute toxicity for the technical sulfoxaflor (EPA Reg. No. 66330-65) is summarized in Table 

2.1a.

Table 2.1a. Acute Toxicity Profile for Sulfoxaflor.

Guideline 

No.

MRID 

(Annex II Point)

Route/

method

Species/

strain (sex)

Result Classification

870.1100 47832144

(5.2.1)

Oral/

gavage

Rat/

Fischer 344 

(both)

LD50 =1000 

mg/kg

Category III

47832040

(5.2.1)

Oral/

gavage

Mouse/ CD1

(male)

LD50 =750 

mg/kg

Category III

870.1200 47832051

(5.2.2)

Dermal/

topical

Rat/

Fischer 344 

(both)

LD50 >5000 

mg/kg

Category IV

870.1300 47832052

(5.2.3)

Inhalation/

nose only

Rat/

Fischer 344 

(both)

LC50>2.09 mg/L 

(4hr)

Category IV

870.2400 47832055

(5.2.5)

Eye/

instillation

Rabbit/

NZW

(female)

Slight Irritation Category III

870.2500 47832053

(5.2.4)

Dermal/

topical

Rabbit/

NZW

(female)

Minimal 

Irritation

Category IV

870.2600 47832041

(5.2.6)

Dermal/

LLNA

Mouse/ CBA/J

(female)

No Sensitization None

A summary of the sulfoxaflor endpoints used for risk assessment is shown in Table 2.1b.
Page 8 of 39

Table 2.1b. Summary of Toxicological Doses and Endpoints for Sulfoxaflor for Use in Occupational Human Health 

Risk Assessments.

Exposure/ 

Scenario

Point of Departure Uncertainty 

Factors

Level of Concern for 

Risk Assessment

Study and Toxicological Effects

Dermal 

Short-and 

IntermediateTerm

NOAEL= 1.8 mg/kg/day

DAF = 2.5%

UFA=3x

UFH=10x

Occupational LOC 

for MOE = 30

Developmental Neurotoxicity Study

LOAEL = 7.1 mg/kg/day based on 

decreased neonatal survival on 

postnatal day (PND) 0 through 4.

Inhalation 

Short-and 

IntermediateTerm 

NOAEL= 1.8 mg/kg/day

(Inhalation absorption

assumed equivalent to 

oral absorption.)

UFA=3x

UFH=10x

Occupational LOC 

for MOE = 30

Developmental Neurotoxicity Study

LOAEL = 7.1 mg/kg/day based on 

decreased neonatal survival (PND 0-

4).

Cancer (oral, 

dermal, 

inhalation)

Sulfoxaflor is classified as “Suggestive Evidence of Carcinogenic Potential.” Quantification of risk 

using a non-linear approach (i.e., RfD) will adequately account for all chronic toxicity, including 

carcinogenicity.

Point of Departure (POD) = a data point or an estimated point that is derived from observed dose-response data and used to mark 

the beginning of extrapolation to determine risk associated with lower environmentally relevant human exposures. NOAEL = no 

observed adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UFA = extrapolation 

from animal to human (interspecies). UFH = potential variation in sensitivity among members of the human population 

(intraspecies). MOE = margin of exposure. LOC = level of concern. DAF = dermal absorption factor. RfD = reference dose.

3. Use Profile

Sulfoxaflor products are intended to be used as insecticides for the control or suppression of 

aphids, plant bugs, stinkbugs, whiteflies and certain scales, thrips and psyllids in a wide variety 

of crops as well as turf grass and ornamentals. Sulfoxaflor is generally applied 2 to 4 times with 

a minimum 5 to 14 day spray interval, depending on crop/use and pest. The recommended 

maximum single application rate range is 0.012-0.133 lb ai/A. Occupational exposure is 

expected to be short- or intermediate-term in duration based on information provided on the 

proposed labels.

A summary of the proposed uses and directions is provided in Table 3.1.

Two agricultural products are proposed for use on the various crops, turf grass and ornamentals: 

GF-2032 SC and Transform TM WG. 

GF-2032 SC is formulated as a suspension concentrate (SC) which contains 21.8% of the active 

ingredient, sulfoxaflor. Transform TM WG is formulated as a water dispersible granule (WG) 

which contains 50% of the active ingredient, sulfoxaflor. The Personal Protective Equipment 

(PPE) statement on the proposed labels requires applicators and other handlers to wear: longsleeved shirt and long pants, shoes plus socks. Due to the Category II finding in the acute ocular 

toxicity testing of Transform TM WG, the PPE statement on the proposed Transform TM WG label 

adds protective eyewear.

These end use products may be applied through a variety of application methods including: 

aerial, chemigation (for potatoes only), groundboom, airblast, backpack, and hand held 

equipment.
Page 9 of 39

Table 3.1. Summary of Proposed Uses and Directions for Sulfoxaflor.

Crop or Target Formulation

% A.I.

Application Timing, 

Type and Equipment†

Max. Single Application

Rate

(lb ai/A)

Max. 

Seasonal 

Applic. Rate

(lb ai/A

per season)

Max. No. 

Applic.

per Season

PHI (days) Use Directions and 

Limitations

Barley, Triticale, Wheat

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or 

groundboom

0.012 - 0.043 0.090

2 14

PHI = 7 days for forage, 

fodder, or hay; 14 days 

for grain or straw

REI = 24 hours Water Dispersible Granule

50 %

0.013 - 0.047 0.090

Brassica (Cole) Leafy 

Vegetables – Crop Group 

5

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or 

groundboom

0.023 - 0.090 0.266

4 7

PHI = 3 days

REI = 24 hours Water Dispersible Granule

50 %

0.023 - 0.086 0.266

Bulb Vegetables - Crop 

Group 3-07

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or 

groundboom

0.090 0.266

3 7

PHI = 7 days

REI = 24 hours Water Dispersible Granule

50 %

0.086 0.266

Canola (Rapeseed) -

Subgroup 20A

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or 

groundboom

0.012 - 0.043 0.090

2 14 PHI = 14

REI = 24 hours Water Dispersible Granule

50 %

0.013 - 0.047 0.090

Citrus - Crop Group 10

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or airblast

0.023 - 0.133 0.266

4 7

PHI = 1 day

REI = 24 hours Water Dispersible Granule

50 %

0.023 - 0.133 0.266

Cotton

Suspension Concentrate

21.8 %

(2 lb ai/gal) foliar; aerial or 

groundboom

0.012 - 0.090 0.266

4 5

PHI = 14

REI = 24 hours Water Dispersible Granule

50 %

0.013 - 0.086 0.266

Cucurbit Vegetables -

Crop Group 9

Suspension Concentrate

21.8 %

(2 lb ai/gal)

foliar; aerial or 

groundboom

0.023 - 0.090 0.266 4 7

PHI = 1 day

REI = 24 hours

Water Dispersible Granule 0.023 - 0.086 0.266
Page 10 of 39

Table 3.1. Summary of Proposed Uses and Directions for Sulfoxaflor.

Crop or Target Formulation

% A.I.

Application Timing, 

Type and Equipment†

Max. Single Application

Rate

(lb ai/A)

Max. 

Seasonal 

Applic. Rate

(lb ai/A

per season)

Max. No. 

Applic.

per Season

PHI (days) Use Directions and 

Limitations

50 %

Fruiting Vegetables -

Crop Group 8-10

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.022 - 0.090 0.266

4 7

PHI = 1 day

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.086 0.266

Leafy Vegetables, except 

Brassica - Crop Group 4 

& Watercress

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.023 - 0.090 0.266

4 7

PHI = 3 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.086 0.266

Leaves of Root and 

Tuber Vegetables - Crop 

Group 2

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.023 - 0.090 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.086 0.266

Ornamentals –

(Herbaceous & Wood)y 

Growing Outdoors, in 

Nurseries (including 

Conifer Seed Orchards), 

or in Greenhouses

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; 

aerial, airblast, 

groundboom, handheld

equipment

0.043 - 0.133

(0.00133 lb ai/gal) 0.266

2 7

PHI = NA

Water Dispersible Granule REI = 24 hours

50 %

0.047 - 0.133

(0.00133 lb ai/gal) 0.266

Pome Fruits - Crop 

Group 11

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar;

aerial or airblast

0.023 - 0.133 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.133 0.266

Root and Tuber 

Vegetables - Crop Group 

1

Suspension Concentrate

21.8 %, (2 lb ai/gal)

foliar;

aerial or groundboom

(chemigation for potatoes 

only)

0.023 - 0.090 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.086 0.266

Small Fruit Vine 

Climbing, except Fuzzy 

Kiwifruit - Subgroup 13-

07F

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar;

aerial or ground

0.043 - 0.090 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.047 - 0.086 0.266

Low Growing Berry -

Subgroup 13-07G

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.043 - 0.090 0.266

4 7

PHI = 1 day

Water Dispersible Granule REI = 24 hours

50 %

0.047 - 0.086 0.266
Page 11 of 39

Table 3.1. Summary of Proposed Uses and Directions for Sulfoxaflor.

Crop or Target Formulation

% A.I.

Application Timing, 

Type and Equipment†

Max. Single Application

Rate

(lb ai/A)

Max. 

Seasonal 

Applic. Rate

(lb ai/A

per season)

Max. No. 

Applic.

per Season

PHI (days) Use Directions and 

Limitations

Soybean

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.012 - 0.090 0.266

4 7

PHI = 7 days for grain, 

14 days for forage or 

hay

REI = 24 hours

Water Dispersible Granule

50 %

0.013 - 0.086 0.266

Stone Fruits - Crop 

Group 12

Suspension Concentrate

21.8 %, (2 lb ai/gal)

foliar;

aerial or airblast

0.023 - 0.133 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.133 0.266

Succulent, Edible 

Podded, and Dry Beans

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar; aerial or 

groundboom

0.023 - 0.090 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.086 0.266

Tree Nuts - Crop Group 

14 & Pistachio

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar;

aerial or airblast

0.022 - 0.133 0.266

4 7

PHI = 7 days

Water Dispersible Granule REI = 24 hours

50 %

0.023 - 0.133 0.266

Turfgrass - Commercial 

Sod Farms and Grass 

Grown for Seed

Suspension Concentrate

21.8 %, (2 lb ai/gal) foliar;

groundboom or handheld

0.043 - 0.133

(0.00133 lb ai/gal) 0.266

2 7

PHI = NA

Water Dispersible Granule REI = 24 hours

50 %

0.047 - 0.133

(0.00133 lb ai/gal) 0.266

NA = not applicable.

† The minimum proposed spray volume is 3 gal/A for aerial applications and 5-10/gal/A for row crop applications. Based on information provided by the 

registrant and on the proposed labels, a total spay volume of 100 gal/A was assumed during turfgrass (sod farms) and ornamentals applications using handheld 

equipment.
Page 12 of 39

4. Residential Exposure and Risk Estimates

No residential uses, and no commercial/professional uses at residential sites are being requested 

for sulfoxaflor at this time; therefore, no residential risk assessment has been conducted. There 

are proposed uses on ornamental plants and turfgrass, but those uses are for 

nurseries/commercial greenhouses and for sod farms, respectively.

For sulfoxaflor, HED believes that the post-application exposure for homeowners buying and 

planting ornamental plants or turfgrass (sod) would be minimal based on the exposure data 

available, the time between application and purchase, and the watering-in of turf. At this time, 

there are no uses of sulfoxaflor that will result in residential exposures.

4.1 Spray Drift

Spray drift is always a potential source of exposure to residents nearby spraying operations. This 

is particularly the case with aerial application, but, to a lesser extent could also be a potential 

source of exposure from ground applications of sulfoxaflor. The Agency has been working with 

the Spray Drift Task Force, EPA Regional Offices and State Lead Agencies for pesticide 

regulation and other parties to develop the best spray drift management practices1. On a 

chemical-by-chemical basis, the Agency is now requiring interim mitigation measures for aerial 

applications that must be placed on product labels/labeling. The Agency has completed its 

evaluation of the new database submitted by the Spray Drift Task Force, a membership of U.S. 

pesticide registrants, and is developing a policy on how to appropriately apply the data and the 

AgDRIFT computer model to its risk assessments for pesticides applied by air, orchard airblast 

and ground hydraulic methods. After the policy is in place, the Agency may impose further 

refinements in spray drift management practices to reduce off-target drift with specific products 

with significant risks associated with drift.

Although a quantitative residential post-application inhalation exposure assessment was not 

performed to address pesticide drift from neighboring treated agricultural fields, an inhalation 

exposure assessment was performed for flaggers. This exposure scenario is representative of a 

worst-case inhalation (drift) exposure and may be considered protective of most outdoor 

agricultural and commercial post-application inhalation exposure scenarios.

4.2 Residential Bystander Post-application Inhalation Exposure

Based on the Agency's current practices, a quantitative post-application inhalation exposure 

assessment was not performed for sulfoxaflor at this time primarily because of the low acute 

inhalation toxicity (Toxicity Category IV), low vapor pressure (1.05 × 10-8 mm Hg at 25°C), and 

the low proposed use rate (0.133 lb ai/A). However, volatilization of pesticides may be a source 

of post-application inhalation exposure to individuals nearby pesticide applications. The Agency 

sought expert advice and input on issues related to volatilization of pesticides from its Federal 

Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (SAP) in December 2009, 

and received the SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The Agency is in the 

 

1

See http://www.epa.gov/opp00001/factsheets/spraydrift.htm for more information on spray drift.
Page 13 of 39

process of evaluating the SAP report and may, as appropriate, develop policies and procedures to 

identify the need for and, subsequently, the way to incorporate post-application inhalation 

exposure into the Agency's risk assessments. If new policies or procedures are developed, the 

Agency may revisit the need for a quantitative post-application inhalation exposure assessment 

for sulfoxaflor.

5. Occupational Exposure and Risk Estimates

The proposed uses are on agricultural crops, turf grass and ornamentals; therefore, there is the 

potential for occupational handler and post-application exposure.

HED uses the term handlers to describe those individuals who are involved in the pesticide 

application process. HED believes that there are distinct job functions or tasks related to 

applications and exposures can vary depending on the specifics of each task. Job requirements 

(amount of chemical used in each application), the kinds of equipment used, the target being 

treated, and the level of protection used by a handler can cause exposure levels to differ in a 

manner specific to each application event. 

5.1 Occupational Handler Exposure and Risk Estimates

Two agricultural products are proposed for use on the various crops, turf grass and ornamentals: 

GF-2032 SC (21.8% ai; suspension concentrate; 2 lb ai/gal) and Transform TM WG (50% ai; 

water dispersible granule). 

Both products are proposed for use on: barley, Brassica (cole) leafy vegetables, bulb vegetables, 

canola (rapeseed), citrus, cotton, cucurbit vegetables, fruiting vegetables, leafy vegetables 

(except Brassica), leaves of root and tuber vegetables, low growing berry, okra, ornamentals 

(herbaceous and woody), pome fruits, small fruit vine, soybean, stone fruits, succulent, edible 

podded and dry beans, tree nuts, pistachio, triticale, turfgrass (sod farms), watercress and wheat.

Exposure Scenarios

Based on the anticipated use patterns and current labeling, types of equipment and techniques 

that can potentially be used, occupational handler exposure is expected from the proposed uses. 

The quantitative exposure/risk assessment developed for occupational handlers is based on the 

following scenarios: 

• Mixing/Loading Dry Flowable and Liquids for Groundboom Application,

• Mixing/Loading Dry Flowable and Liquids for Aerial Application,

• Mixing/Loading Dry Flowable and Liquids for Chemigation,

• Mixing/Loading Dry Flowable and Liquids for Airblast Application,

• Applying Sprays with Groundboom Equipment,

• Applying Sprays with Aerial Equipment, 

• Applying Sprays with Airblast Equipment, 

• Flagging for Aerial Applications,

• Mixer/Loader/Applicator for Mechanically-pressurized Handgun Sprayer,
Page 14 of 39

• Mixer/Loader/Applicator for Backpack Sprayer, and

• Mixer/Loader/Applicator for Manually-pressurized Handwand.

Handler exposure is expected to be short- or intermediate-term in duration based on information 

provided on the proposed labels. Since the same endpoint and point of departure were selected 

for short- and intermediate-term durations, short-term exposure and risk estimates are considered 

to be protective of intermediate-term exposure and risk. Long-term exposures are not expected; 

therefore, a long-term assessment was not conducted. No handler exposures are expected from 

applying sprays via chemigation systems.

Occupational Handler Exposure Data and Assumptions

Application Rate

The maximum single application rate on the proposed labels was used to assess all handler 

exposure scenarios. The maximum single application rates for all uses range from 0.012-0.133

lb ai/A. The maximum application rate per acre per year is 0.266 lb ai/A/yr. The number of

applications per year at the maximum single application rate ranged from 2-4 depending on the 

use.

Area Treated

Based on HED’s Exposure Science Advisory Council Policy Number 9.1, the following 

assumptions were used for acres treated or amount handled per day:

• 80-200 acres/day for groundboom application, 

• 350-1,200 acres/day for aerial application,

• 350 acres/day for chemigation, 

• 40 acres/day for airblast application,

• 40-1,000 gals/day for mechanically-pressurized handgun sprayer,

• 40 gals/day for backpack sprayer, and,

• 40 gals/day for manually-pressurized handwand.

Unit Exposures

It is the policy of HED to use the best available data to assess handler exposure. Sources of 

generic handler data, used as surrogate data in the absence of chemical-specific data, include the 

Pesticide Handlers Exposure Database Version 1.1 (PHED 1.1), the Agricultural Handler 

Exposure Task Force (AHETF) database, the Outdoor Residential Exposure Task Force 

(ORETF) database, or other registrant-submitted occupational exposure studies. Some of these 

data are proprietary (e.g., AHETF data), and subject to the data protection provisions of FIFRA. 

The standard values recommended for use in predicting handler exposure that are used in this 

assessment, known as “unit exposures”, are outlined in the “Occupational Pesticide Handler Unit 

Exposure Surrogate Reference Table” (http://www.epa.gov/opp00001/science/handler-exposuretable.pdf), which, along with additional information on HED policy on use of surrogate data, 

including descriptions of the various sources, can be found at: 
Page 15 of 39

http://www.epa.gov/pesticides/science/handler-exposure-data.html. 

Estimates of dermal and inhalation exposure were calculated for various levels of personal 

protective equipment (PPE). Results are presented for “baseline,” defined as a single layer of 

clothing consisting of a long sleeved shirt, long pants, shoes plus socks, no protective gloves, and 

no respirator, as well as baseline with various levels of PPE as necessary (e.g., gloves, respirator, 

etc). The personal protective equipment (PPE) proposed on the Transform TM WG label requires 

applicators and other handlers to wear long-sleeved shirt and long pants, shoes plus socks, and 

protective eyewear. The personal protective equipment (PPE) proposed on the GF-2032 SC

label requires applicators and other handlers to wear long-sleeved shirt and long pants, and shoes 

plus socks.

Exposure Frequency

HED classifies exposures from 1 to 30 days as short-term and exposures 30 days to six months 

as intermediate-term. Exposure duration is determined by many things, including the exposed 

population, the use site, the pest pressure triggering the use of the pesticide, and the cultural 

practices surrounding that use site. For most agricultural uses, it is reasonable to believe that 

occupational handlers will not apply the same chemical every day for more than a one-month 

time frame; however, there may be a large agribusiness and/or commercial applicators who may 

apply a product over a period of weeks (e.g., completing multiple applications for multiple 

clients within a region). 

No data on the number of exposure days per year was provided. Based on the proposed labels’ 

use pattern and directions (e.g., 2-4 applications per season with a minimum 5 to 14 day spray 

interval), only short- and intermediate-term exposures are expected for handlers. 

In the past HED has considered ornamentals and greenhouse uses to have the potential for longterm dermal exposure. However, the pests that are targets for sulfoxaflor have biological and 

life-stage properties that provide for short windows of opportunity for control. To avoid 

development of sulfoxaflor-resistant pests, the sulfoxaflor labels require switching periodically 

to another insecticide. Therefore, based on the proposed use pattern and resistance management 

strategies (i.e., avoid consecutive applications of insecticides with the same mode of action), 

long-term exposure is not expected to occur. 

Absorption Factors

HED has compared data depicting in vivo and in vitro dermal absorption of sulfoxaflor in rats 

with in vitro dermal absorption in human skin to derive a human-equivalent in vivo dermal 

absorption factor of 2.5%. A dermal absorption factor of 2.5 % was used for the exposure 

assessment.

Furthermore, since the short- and intermediate-term inhalation endpoint was based on an oral 

study and no inhalation absorption data are available, toxicity by the inhalation route is 

considered to be equivalent to the estimated toxicity by the oral route of exposure.
Page 16 of 39

Body Weight

An average female adult body weight of 69 kg was used to estimate exposure and risk to 

handlers because the selected dermal and inhalation endpoints were based on developmental 

effects. 

Occupational Handler Exposure and Risk Equations

Potential daily exposures for occupational handlers were calculated using the following 

formulas:

Daily Exposure (mg ai/day) = UE (μg ai / lb ai) * AR (lb ai /A) * AT (A /day) * CF (1E-3 mg/μg)

where:

Daily Exposure = Amount (mg ai/day) that is available for dermal or inhalation exposure,

UE = Unit Exposure (μg ai / lb ai),

AR = Maximum application rate according to proposed label (lb ai/A or lb ai/gal), and

AT = Daily acres treated (A /day) or amount handled.

The daily doses were calculated using the following formula:

Daily Dose (mg ai/kg/day) = [Daily Exposure (mg ai/day) * Absorption Factor (%)]/Body Weight (kg)

where:

Daily Dose = Absorbed dose received from exposure to a pesticide in a given scenario (mg pesticide 

active ingredient/kg body weight/day),

Daily Exposure = Amount (mg ai/day) that is available for dermal or inhalation absorption,

Absorption Factor = A measure of the amount of chemical that crosses a biological boundary such as 

the skin and lungs (%), and

Body Weight = Body weight determined to represent the population of interest in a risk 

assessment (kg).

Margin of Exposure: Non-cancer inhalation risks for each application handler scenario are 

calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to 

the daily dose of concern. The daily dermal and inhalation dose received by occupational 

handlers were compared to the appropriate POD (i.e., NOAEL) to assess the risk to occupational 

handlers for each exposure route. All MOE values were calculated using the following formula:

MOE = POD (typically a NOAEL in mg/kg/day)/Daily Dose (mg/kg/day)

where:

MOE = Margin of Exposure is the value used by HED to represent risk or risk estimates (unitless),

POD = Point of Departure (mg/kg/day),

NOAEL = No Observed Adverse Effect Level (mg/kg/day) (i.e., dose level in a toxicity study, where no 

observed adverse effects occurred in the study), and

DD = Daily Dose (mg/kg/day) is the absorbed dose received from exposure to a pesticide in a given 

scenario.

Dermal and inhalation risks were combined in this assessment, since the toxicological effects for 

these exposure routes were similar. Dermal and inhalation risks were combined using the 

following formula:
Page 17 of 39

Total MOE = Point of Departure (mg/kg/day)/Combined (Dermal + Inhalation) Dose (mg/kg/day)

Occupational Handler Exposure and Risk Estimates

Tables 5.1a and 5.1b present the estimated short- and intermediate-term dermal and inhalation 

risk estimates for occupational handlers (i.e., mixer/loaders, applicators, flaggers). All 

occupational handler scenarios for the proposed uses resulted in estimated MOEs that are greater 

than 30 (i.e., not of concern) at the baseline level of PPE (i.e., baseline clothing, no gloves and 

no respirator) and engineering controls (i.e., enclosed cockpit) for aerial applications. The 

estimated combined (dermal + inhalation) MOEs are all higher than HED’s level of concern of 

an MOE of 30, with the lowest MOE of 80 identified for handlers conducting mixer/loader 

activities with dry flowable for aerial applications. 

The Agency has evaluated scenarios that may be limited in nature such as flagging during aerial 

applications because engineering controls (i.e., Global Positioning Satellite technology) are now 

predominantly used as indicated by the 1998 National Agricultural Aviation Association 

(NAAA) survey of their membership. It appears, however, flaggers are still used in 

approximately 10 to 15 percent of aerial application operations. In cases like these, the Agency 

strongly encourages the use of the engineering control system but will continue to evaluate risks 

for flaggers and any other population where a clear exposure pathway exists until the potential 

for exposure is eliminated. The Agency is aware that NAAA is conducting another survey on 

exposure issues and will consider those results as are timely and appropriate.

HED has no data to assess exposure for pilots using open cockpits. The only data available 

represent exposure for pilots in enclosed cockpits. Therefore, pilot exposure and risk estimates 

are determined assuming use of engineering control (i.e., enclosed cockpits) and baseline attire 

(i.e., long-sleeve shirt, long pants, shoes, and socks); pilots are not required to wear protective 

gloves. With this level of protection, there are no risk estimates of concern for aerial applicators 

treating melons, peppers and soybeans with fluazinam in accordance with the proposed label.
Page 18 of 39

Table 5.1a. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (Transform TM WG).

Exposure 

Scenario

Crop or Target (Crop Group #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

Mixer/Loader

Dry Flowable for 

Groundboom 

Application 

(AHETF)

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress),

Leaves Root/Tuber Veg. (CG 2),

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.227

(Baseline)

0.00896

(No respirator)

0.086 80 A 0.00057 3,200 0.00089 2,000 1,200

Ornamentals, Turf grass (Sod Farm) 0.227

(Baseline)

0.00896

(No respirator)

0.133 80 A 0.00088 2,100 0.00140 1,300 800

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.227

(Baseline)

0.00896

(No respirator)

0.047 200 A 0.00077 2,300 0.00120 1,500 900

Cotton, Soybean 0.227

(Baseline)

0.00896

(No respirator)

0.086 200 A 0.0014 1,300 0.00220 810 490

Dry Flowable for 

Aerial 

Application 

(AHETF) 

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.227

(Baseline)

0.00896

(No respirator)

0.086 350 A 0.00250 730 0.00390 460 280

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.227

(Baseline)

0.00896

(No respirator)

0.133 350 A 0.00380 470 0.00600 300 180

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.277

(Baseline)

0.00896

(No respirator)

0.047 1200 A 0.00460 390 0.00730 250 150

Cotton, Soybean 0.277

(Baseline)

0.00896

(No respirator)

0.086 1200 A 0.00850 210 0.01340 130 80

Dry Flowable for 

Chemigation 

(AHETF)

Potatoes 0.227

(Baseline)

0.00896

(No respirator)

0.086 350 A 0.00250 730 0.00390 460 280

Dry Flowable for 

Airblast

Application

(AHETF)

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.227

(Baseline)

0.00896

(No respirator)

0.133 40 A 0.00044 4,100 0.00069 2,600 1,600

Applicator

Sprays for 

Groundboom 

Application 

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

0.0786

(Baseline)

0.00034

(No respirator)

0.086 80 A 0.00020 9,200 0.000034 53,000 7,800
Page 19 of 39

Table 5.1a. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (Transform TM WG).

Exposure 

Scenario

Crop or Target (Crop Group #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

(AHETF) (Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible 

Podded, Dry Beans

Ornamentals, Turf grass (Sod Farm) 0.0786

(Baseline)

0.00034

(No respirator)

0.133 80 A 0.00030 5,900 0.000052 34,000 5,100

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.0786

(Baseline)

0.00034

(No respirator)

0.047 200 A 0.00027 6,700 0.000046 39,000 5,700

Cotton, Soybean 0.0786

(Baseline)

0.00034

(No respirator)

0.086 200 A 0.00049 3,700 0.000085 21,000 3,100

Sprays for Aerial 

Application 

(PHED)

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.086 350 A 0.000055 33,000 0.000030 61,000 21,000

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.133 350 A 0.000084 21,000 0.000046 39,000 14,000

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.047 1200 A 0.00010 18,000 0.000056 32,000 11,000

Cotton, Soybean 0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.086 1200 A 0.00019 9,600 0.0001 18,000 6,200

Sprays for 

Airblast

Application

(AHETF)

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

1.77

(Baseline)

0.00471

(No respirator)

0.133 40 A 0.00340 530 0.00036 5,000 480

Flagger

Flagging for 

Aerial 

Application

All Low Acreage Crops 0.011

(Baseline)

0.00035

(No respirator)

0.133 350 A 0.00019 9,700 0.00024 7,600 4,200
Page 20 of 39

Table 5.1a. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (Transform TM WG).

Exposure 

Scenario

Crop or Target (Crop Group #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

(PHED)

Flagging for 

Aerial 

Application

(PHED)

All High Acreage Crops 0.011

(Baseline)

0.00035

(No respirator)

0.086 350 A 0.00012 15,000 0.00015 12,000 6,700

Mixer/Loader/Applicator

Mechanicallypressurized 

Handgun 

Sprayer

Ornamentals, Greenhouses

3.5

(Baseline)

(PHED)

0.120 

(No respirator)

(PHED)

0.00133 1,000 gal/day 0.00169 1,100 0.00231 780 450

Turfgrass (Sod farms)

1.96

(Baseline) 

(ORETF)

0.042

(No respirator)

(ORETF)

0.133 5 A 0.00047 3,800 0.00040 4,400 2,100

Backpack 

Sprayer

Ornamentals

13.2

(Baseline)

(AHETF)

0.140 

(No respirator)

(AHETF)

0.00133 40 gal/day 0.00025 7,200 0.00011 16,000 5,000

Turfgrass (Sod farms)

8.26

(Baseline)

(MRID 

44339801)

0.00258 

(No respirator)

(MRID 

44339801)

0.00133 40 gal/day 0.00016 11,000 0.000002 900,000 11,000

Manuallypressurized 

Handwand

(PHED)

Ornamentals, Turfgrass (Sod farms) 100

(Baseline)

0.030 

(No respirator) 0.00133 40 gal/day 0.00193 930 0.000023 78,000 920

1. Occupational Pesticide Handler Unit Exposure Surrogate Reference Table (OPHED; March, 2012).

2. Application Rate is based on the proposed label.

3. Acres Treated per Day is based on Exposure SAC SOP #9: Standard Values for Daily Acres Treated.

4. Dermal Dose = [Dermal Unit Exposure (mg/lb ai) x Application Rate (lb ai/A) x Acres Treated (A/day) x % DAF (2.5%)]/%)/BW (69 kg).

5. Dermal MOE = Dermal NOAEL (1.8 mg/kg/day)/Dermal Dose (mg/kg/day); LOC = 30.

6. Inhalation Dose = [Inhalation Unit Exposure (mg/lb ai) x Application Rate (lb ai/A) x Acres Treated (A/day)]/)/BW (69 kg). 

7. Inhalation MOE = NOAEL (1.8 mg/kg/day)/Inhalation Dose (mg/kg/day); LOC = 30.

8. Combined MOE = NOAEL (1.8 mg/kg/day)/Combined Dose (mg/kg/day); LOC = 30.
Page 21 of 39

Table 5.1b. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (GF-2032 SC).

Exposure 

Scenario

Crop or Target (CG #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

Mixer/Loader

Liquids for 

Groundboom 

Application 

(AHETF)

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.220 0.000219 0.090 80 A 0.00057 3,100 0.000023 79,000 3,000

Ornamentals, Turf grass (Sod Farm) 0.220 0.000219 0.133 80 A 0.00085 2,100 0.000034 53,000 2,000

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.220 0.000219 0.043 200 A 0.00069 2,600 0.000027 66,000 2,500

Cotton, Soybean 0.220 0.000219 0.090 200 A 0.00140 1,300 0.000057 32,000 1,200

Liquids for 

Aerial 

Application 

(AHETF) 

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.220 0.000219 0.090 350 A 0.00250 720 0.00010 18,000 690

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.220 0.000219 0.133 350 A 0.00370 490 0.00015 12,000 470

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.220 0.000219 0.043 1200 A 0.00410 440 0.00016 11,000 420

Cotton, Soybean 0.220 0.000219 0.090 1200 A 0.00860 210 0.00034 5,300 200

Liquids for 

Chemigation 

(AHETF)

Potatoes 0.220 0.000219 0.090 350 A 0.00250 720 0.00100 18,000 690

Liquids for 

Airblast

Application

(AHETF)

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.220 0.000219 0.133 40 A 0.00042 4,200 0.000017 110,000 4,100

Applicator

Sprays for 

Groundboom 

Application 

(AHETF)

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

0.0786

(Baseline)

0.00034

(No respirator)

0.090 80 A 0.00021 8,800 0.000035 51,000 7,500
Page 22 of 39

Table 5.1b. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (GF-2032 SC).

Exposure 

Scenario

Crop or Target (CG #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

Ornamentals, Turf grass (Sod Farm) 0.0786

(Baseline)

0.00034

(No respirator)

0.133 80 A 0.00030 5,900 0.000052 34,000 5,100

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.0786

(Baseline)

0.00034

(No respirator)

0.043 200 A 0.00024 7,300 0.000042 42,000 6,300

Cotton, Soybean 0.0786

(Baseline)

0.00034

(No respirator)

0.090 200 A 0.00051 3,500 0.000089 20,000 3,000

Sprays for Aerial 

Application 

(PHED)

Brassica (Cole) Leafy Veg., Bulb Veg. 

(CG 3-07), Cucurbit Veg. (CG 9), 

Fruiting Veg. (CG 8), Leafy Veg. 

(Except Brassica CG 4 & Watercress), 

Leaves Root/Tuber Veg. (CG 2), 

Root/Tuber Veg. (CG 1), Small Fruit 

Vine (Sub CG 13-07F), Low Growing 

Berry (Sub 13-07G), Succulent, Edible

Podded, Dry Beans

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.090 350 A 0.000057 32,000 0.000031 58,000 25,000

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.133 350 A 0.000084 21,000 0.000046 39,000 19,000

Barley, Tricale, Wheat, Canola (Sub 

CG 20A)

0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.043 1200 A 0.000093 19,000 0.000051 35,000 12,000

Cotton, Soybean 0.005

(Engineering 

Controls -

Enclosed 

cockpit)

0.000068

(Engineering 

Controls -

Enclosed 

cockpit)

0.090 1200 A 0.00020 9,200 0.00011 17,000 6,000

Sprays for 

Airblast

Application

(AHETF)

Citrus (CG 10), Pome Fruits (CG 11), 

Ornamentals, Stone Fruits (CG 12), 

Tree Nuts (CG 14 & Pistachio)

1.77

(Baseline)

0.00471

(No respirator)

0.133 40 A 0.00340 530 0.00036 5,000 480

Flagger

Flagging for 

Aerial 

Application

(PHED)

All Low Acreage Crops 0.011

(Baseline)

0.00035

(No respirator)

0.133 350 A 0.00019 9,700 0.00024 7,600 4,200
Page 23 of 39

Table 5.1b. Short- and Intermediate-term Occupational Handler Exposure and Risk Estimates for Proposed Uses of Sulfoxaflor (GF-2032 SC).

Exposure 

Scenario

Crop or Target (CG #) Dermal Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Inhalation Unit 

Exposure1

(mg/lb ai)

(Mitigation 

Level)

Max Single 

App Rate

(lb ai/A or lb 

ai/gal)

2

Area Treated or 

Amount Handled 

Daily 3

Dermal Inhalation Combined MOE8

Dose (LOC=30) 4

(mg/kg/day)

MOE5 Dose6

(mg/kg/day)

MOE7

Flagging for 

Aerial 

Application

(PHED)

All High Acreage Crops 0.011

(Baseline)

0.00035

(No respirator)

0.090 350 A 0.00013 14,000 0.00016 11,000 6,300

Mixer/Loader/Applicator

Mechanicallypressurized 

Handgun 

Sprayer

Ornamentals, Greenhouses

3.5

(Baseline)

(PHED)

0.120 

(No respirator)

(PHED)

0.00133 1,000 gal/day 0.00169 1,100 0.00231 780 450

Turfgrass (Sod farms)

1.14

(Baseline) 

(ORETF)

0.0019

(Baseline) 

(ORETF)

0.133 5 A 0.00047 3,800 0.00040 4,400 2,100

Backpack 

Sprayer

Ornamentals

13.2

(Baseline)

(AHETF)

0.140 

(No respirator)

(AHETF)

0.00133 40 gal/day 0.00025 7,200 0.00011 16,000 5,000

Turfgrass (Sod farms)

8.26

(Baseline)

(MRID 

44339801)

0.00258 

(No respirator)

(MRID 

44339801)

0.00133 40 gal/day 0.00016 11,000 0.000002 900,000 11,000

Manuallypressurized 

Handwand

(PHED)

Ornamentals, Turfgrass (Sod farms) 100

(Baseline)

0.030 

(No respirator) 0.00133 40 gal/day 0.00193 930 0.000023 78,000 920

1. Occupational Pesticide Handler Unit Exposure Surrogate Reference Table (OPHED; March, 2012).

2. Application Rate is based on the proposed label.

3. Acres Treated per Day is based on Exposure SAC SOP #9: Standard Values for Daily Acres Treated.

4. Dermal Dose = [Dermal Unit Exposure (mg/lb ai) x Application Rate (lb ai/A) x Acres Treated (A/day) x % DAF (2.5%)]/%)/BW (69 kg).

5. Dermal MOE = Dermal NOAEL (1.8 mg/kg/day)/Dermal Dose (mg/kg/day); LOC = 30.

6. Inhalation Dose = [Inhalation Unit Exposure (mg/lb ai) x Application Rate (lb ai/A) x Acres Treated (A/day)]/)/BW (69 kg). 

7. Inhalation MOE = NOAEL (1.8 mg/kg/day)/Inhalation Dose (mg/kg/day); LOC = 30.

8. Combined MOE = NOAEL (1.8 mg/kg/day)/Combined Dose (mg/kg/day); LOC = 30.
Page 24 of 39

5.2 Occupational Post-Application Exposure and Risk Estimates

HED uses the term post-application to describe exposures that occur when individuals are 

present in an environment that has been previously treated with a pesticide (also referred to as reentry exposure). Such exposures may occur when workers enter previously treated areas to 

perform job functions, including activities related to crop production, such as scouting for pests 

or harvesting. Post-application exposure levels vary over time and depend on such things as the 

type of activity, the nature of the crop or target that was treated, the type of pesticide application, 

and the chemical’s degradation properties. In addition, the timing of pesticide applications, 

relative to harvest activities, can greatly reduce the potential for post-application exposure.

5.2.1 Occupational Post-Application Inhalation Exposure and Risk Estimates

Based on the Agency's current practices, a quantitative post-application inhalation exposure 

assessment was not performed for sulfoxaflor at this time primarily because it has a low vapor 

pressure (1.05 × 10-8 mm Hg at 25°C) and it is applied at low application rates (0.133 lb ai/A). 

However, volatilization of pesticides may be a potential source of post-application inhalation 

exposure to individuals nearby to pesticide applications. The Agency sought expert advice and 

input on issues related to volatilization of pesticides from its Federal Insecticide, Fungicide, and 

Rodenticide Act Scientific Advisory Panel (SAP) in December 2009. The Agency received the 

SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). 

Although a quantitative occupational post-application inhalation exposure assessment was not 

performed, an inhalation exposure assessment was performed for occupational handlers. This 

assessment resulted in risk estimates that did not exceed HED’s level of concern at baseline 

inhalation PPE. Handler exposure resulting from application of pesticides outdoors is likely to 

result in higher exposure than post-application exposure. Therefore, it is expected that these 

handler inhalation exposure estimates would be protective of most occupational post-application 

inhalation exposure scenarios.

Furthermore, the Worker Protection Standard for Agricultural Pesticides contains requirements 

for protecting workers from inhalation exposures during and after greenhouse applications 

through the use of ventilation requirements [40 CFR 170.110, (3) (Restrictions associated with 

pesticide applications)].

5.2.2 Occupational Post-Application Dermal Exposure and Risk Estimates

Occupational workers who enter treated fields to perform post-application activities such as hand 

weeding and scouting may be exposed to sulfoxaflor residues. Based on the use pattern, workers 

may be exposed to short- and intermediate-term exposure durations. 

Dislodgeable Foliar Residue Data: It is HED’s policy to use the best available data to assess 

post-application exposure. The registrant submitted dislodgeable foliar residue (DFR) studies in 

support of the proposed agricultural uses. These studies were reviewed by HED (MRID No. 

47832415 on Treated Wheat; MRID No. 47832416 on Treated Broccoli). Both studies 
Page 25 of 39

demonstrated that dislodgeable foliar residue values declined over time for all sites and both 

formulations. The available DFR data were matched to the proposed agricultural crops (except 

cotton; see below) as surrogate data based on available information about foliage type, region of 

use, use pattern, etc. (see ExpoSAC Minutes dated 06/30/11). The results of the DFR studies are 

summarized in Appendix A. Dermal post-application exposure resulting from application of 

sulfoxaflor was estimated using the best available surrogate DFR predicted Day-0 residue value 

from treated wheat (0.0210 ug/cm2) and treated broccoli (0.115 ug/cm2) calculated by a firstorder dissipation kinetics and decay model. Maximum single application rates were used in this 

assessment. Day-0 DFR values were adjusted by application rate. 

Dislodgeable residue data were not submitted for cotton. Calculation of dermal post-application 

exposure resulting from application of sulfoxaflor to cotton during harvesting activities (e.g., 

module builder, picker operator, raker, tramper) requires an estimate of the "dislodgeable" 

residue on the cotton bolls. Since that information was unavailable, exposure was estimated 

using cotton field trial residues (see Appendix C). Additionally, since the proposed PHI for 

cotton is 14 days, the Day-14 residue value from the cotton field trials is considered adequate to 

estimate dermal post-application exposures and risks during harvesting activities. Adjusted to 

the proposed maximum seasonal application rate, the Day-14 residue is 0.000129 mg ai/g cotton. 

Note also that the cotton field trial residue data reflect solvent-extractable residues, which are 

likely to be significantly greater than dislodgeable cotton boll residue during harvesting 

activities. Therefore, use of the residue data from the cotton field trials, even after being reduced 

to account for the difference in application rate, results in a conservative estimate for the daily 

dose.

Turf transferable residue (TTR) data were not submitted for turfgrass (sod farms); therefore, 

default TTR values were used to assess dermal post-application exposure and risk.

Transfer Coefficients: Sources of generic post-application exposure data, used as surrogate data 

in the absence of chemical-specific data, are derived from Agricultural Reentry Task Force 

(ARTF) exposure monitoring studies, and, as proprietary data, are subject to the data protection 

provisions of FIFRA. The standard values recommended for use in predicting post-application 

exposure that are used in this assessment, known as “transfer coefficients, Tc” are presented in 

the “Science Advisory Council for Exposure (ExpoSAC) Policy 3” 

(http://www.epa.gov/pesticides/science/exposac_policy3.pdf), which, along with additional 

information about the ARTF data, can be found at: http://www.epa.gov/pesticides/science/postapp-exposure-data.html.

Dermal exposures during post-application activities were estimated using standard default and 

surrogate contact activity values (Appendix B), chemical-specific DFR (Appendix A) for all 

agricultural crops except cotton, default TTR for sod farms, and field trial data for cotton 

(Appendix C).

Post-Application Exposure and Risk Estimates

A summary of the post-application exposure and risk estimates for all proposed crops except 

cotton is provided in Table 5.2.2. Only risk estimates for the highest contact activity per crop 
Page 26 of 39

group are shown below; not all the TCs used in the assessment apply to each of the specific crops

requested. Post-application dermal exposure and risk estimates resulted in MOEs greater than 30 

and are not of concern. 

A summary of the post-application exposure and risk estimates from use of sulfoxaflor on cotton 

during harvesting activities is provided in Table 5.2.3. Post-application dermal exposure and risk 

estimates resulted in MOEs greater than 30 and are not of concern. 
Page 27 of 39

Table 5.2.2. Post-Application Exposure and Risk Estimates for use of Sulfoxaflor.

Crop Group Proposed 

Uses/Crop Group

Proposed 

Maximum 

Application 

Rate†

(lb ai/A)

Activity1 TC2

(cm2/hr)

Days 

After 

Treatment

Adjusted 

Dislodgeabl

e Foliar 

Residue / 

Turf 

Transferable 

Residue3

(ug/cm2)

Daily 

Dose 

(mg/kg/d)4

MOE5

DFR Data on Treated Wheat (MRID No. 47832415)

Field / Row 

Crop, 

Low/Medium

Barley, Tricale, 

Wheat; Canola

(SG 20A)

0.047 Scouting 1,100 0 0.022 0.0000007 2,600,000

Cotton 0.090 Scouting 210 0 0.042 0.0000003 7,000,000

Soybean 0.090 Scouting 1,100 0 0.042 0.0000014 1,300,000

Succulent Edible 

Podded and Dry 

Beans

0.090 Irrigation 

(Hand Set)

1,900

0 0.042 0.0000023 770,000

DFR Data on Treated Broccoli (MRID No. 47832416)

Vegetable, head 

and stem 

Brassica

Brassica (Cole) 

Leafy Vegetables

(CG5)

0.090 Hand Weeding 4,200 0 0.115 0.00001 130,000

Vegetable, 

"Root"

Bulb Vegetables 

(CG 3-07) 0.090 Hand Weeding 4,200 0 0.115 0.00001 130,000

Leaves of Root 

and Tuber 

Vegetables (CG

2);

Root and Tuber 

Vegetables (CG

1)

0.090 Irrigation

(Hand Set) 1,900 0 0.115 0.000006 280,000

Tree Fruit, 

Evergreen Citrus (CG 10) 0.133 Thinning Fruit 3,600 0 0.170 0.00002 100,000

Vegetable, 

Cucurbit

Cucurbits 

Vegetables (CG

9)

0.090 Irrigation

(Hand Set) 1,900 0 0.115 0.00001 280,000

Vegetable, 

Fruting

Fruiting 

Vegetables (CG

8)

0.090 Irrigation

(Hand Set) 1,900 0 0.115 0.00001 280,000

Vegetable, 

Leafy

Leafy Vegetables 

except Brassica –

(CG 4) &

Watercress)

0.090 Irrigation

(Hand Set) 1,900 0 0.115 0.000006 280,000

Nursery/

Greenhouse

(Unassigned)

Ornamentals

0.133 Irrigation

(Hand Set) 1,900 0 0.170 0.00001 190,000

Tree, "Fruit", 

Deciduous

Pome Fruits (CG

11); Stone Fruits 

(CG12)

0.133 Thinning Fruit 3,600 0 0.170 0.00002 100,000

Vine/Trellis Small Fruit Vine 

Climbing except 

fuzzy kiwifruit –

(SG 13-07F)

0.090 Turning, Girdling 19,300 0 0.115 0.0001 28,000

Berry, Low Low Growing 

Berry (SG 13-

07G)

0.090 Irrigation

(Hand Set) 1,900 0 0.115 0.000006 280,000

Tree, “Nut” Tree Nuts (CG

14) & Pistachio) 0.133 Hand Harvesting 1,400 0 0.170 0.000007 260,000

Default TTR Approach‡
Page 28 of 39

Table 5.2.2. Post-Application Exposure and Risk Estimates for use of Sulfoxaflor.

Crop Group Proposed 

Uses/Crop Group

Proposed 

Maximum 

Application 

Rate†

(lb ai/A)

Activity1 TC2

(cm2/hr)

Days 

After 

Treatment

Adjusted 

Dislodgeabl

e Foliar 

Residue / 

Turf 

Transferable 

Residue3

(ug/cm2)

Daily 

Dose 

(mg/kg/d)4

MOE5

Turf, Sod Turfgrass, Sod 

farms 0.133

Maintenance, 

Harvesting, Slab

Transplanting/Planting

6,700 0 0.002 0.0000004 4,700,000

† Maximum single application rates were used in this assessment. 

‡ Turf Transferable Residue = TTRt(μg/cm2) = AR (lb ai/acre) × F × (1-D)t× 4.54E8 μg/lb × 2.47E-8 acre/cm2; Where, AR = 

Application Rate, F = Fraction of ai retained on foliage (0.2; unitless), D = Fraction of residue that dissipates daily (0.1; unitless).

1. Only risk estimates for the high contact activities are shown.

2. Transfer Coefficients from HED Policy No. 3.0., March 2012 (see Appendix B). Only the dose and risk estimates for the 

highest contact activities are shown above.

3. Dislodgeable Foliar Residue (DFR) from Treated Wheat = 0.0210 ug/cm2is based on predicted day 0 residue value 

calculated from chemical-specific data (MRID No. 47832415) and then adjusted by application rate. Dislodgeable Foliar 

Residue (DFR) from Treated Broccoli = 0.115 ug/cm2is based on predicted day 0 residue value calculated from chemicalspecific data (MRID No. 47832416) and then adjusted by application rate. Representative site, surrogate DFR data and crop 

selection were determined using available information about foliage type, region of use, use pattern, etc. (see ExpoSAC 

Minutes dated 06/30/11).

4. Dermal Dose (mg/kg/day) = [DFR or TTR (ug/cm2) x TC (cm2/hr) x hr/day (8 hrs/day) x (0.001 μg/mg) x DAF (2.5%)]/ 

BW 69 kg).

5. Dermal MOE = NOAEL (1.8 mg/kg/day)/Dermal Dose (mg/kg/day); LOC = 30.
Page 29 of 39

Table 5.2.3. Post-Application Exposure and Risk Estimates for use of Sulfoxaflor on Cotton during Harvesting Activities.

Crop

Proposed 

Maximum 

Seasonal 

Application 

Rate

(lb ai/A)

Activity TC1

(g cotton/hr)

Days After 

Treatment

Residue from 

Cotton Field 

Trial 2

(mg ai/g 

cotton)

Daily Dose 

(mg/kg/d)3 MOE4

Cotton 0.266

Harvesting 

Mechanical 

(Module Builder)

900

14 0.000129

0.00034 5,300

Harvesting 

Mechanical (Picker 

Operator; Raker)

2400 0.00089 2,000

Harvesting 

Mechanical 

(Tramper)

5050 0.00189 950

1. Transfer Coefficients from HED Policy No. 3.0., Non-Foliar Transfer Coefficient Table, March 2012 (p 122). 

2. Residue Value from Cotton Field Trial (Table 9) adjusted to Max. Seasonal Application Rate (mg ai/g cotton) = 

(0.182 mg ai/kg cotton) (0.001 mg/g) ((0.266 lb ai/A)/(0.375 lb ai/A)) = 0.000129 mg ai/g cotton.

3. Dermal Dose (mg/kg/day) = [Cotton Field Trial Residue Value adjusted (mg ai/g cotton) x TC (g cotton/hr) x hr/day (8 

hrs/day) x DAF (2.5%)]/ BW (69 kg).

4. Dermal MOE = NOAEL (1.8 mg/kg/day)/Dermal Dose (mg/kg/day); LOC = 30.

Restricted Entry Interval (REI)

Sulfoxaflor is classified as Toxicity Category IV via the dermal route and for skin irritation 

potential. It is not a skin sensitizer. Short- and intermediate-term post-application risk estimates 

were not a concern on day 0 (12 hours following application) for all post-application activities. 

Under 40 CFR 156.208 (c) (2) (iii), ai’s classified as Acute III or IV for acute dermal, eye 

irritation and primary skin irrigation are assigned a 12-hour REI. Therefore, the [156 subpart K] 

Worker Protection Statement interim REI of 12 hours is adequate to protect agricultural workers 

from post-application exposures to sulfoxaflor. It should be noted that the petitioner has 

proposed a REI of 24 hours for the proposed products based on their interpretation of the acute 

ocular toxicity study of the TransformTM WG formulated product resulting in a Toxicity 

Category II for eye irritation. HED recommends that RD ensure that the proper REI is listed on 

both proposed labels according to the acute toxicity profile of the active ingredient.
Page 30 of 39

APPENDICES

Appendix A: Summary of the Dislodgeable Foliar Residues (DFR) Studies.

Secondary Review: Dissipation of Dislodgeable Foliar Residues of Sulfoxaflor from Treated 

Wheat; MRID No. 47832415.

The study “Dissipation of Dislodgeable Foliar Sulfoxaflor Residues from Treated Wheat” was 

submitted by Dow AgroSciences LLC, in support of the registration of sulfoxaflor.

This study was designed to determine the dissipation of dislodgeable foliar residues (DFR) of 

sulfoxaflor formulated as a 22.5% ai suspension concentrate (XDE-240 SC) and a 49.9% water 

dispersible granular (500 WDG) applied via groundboom to wheat at two trial sites: Porterville, 

CA and Chula, GA. Each trial site consisted of one control plot and two treatment plots (one for 

each formulation). Each treatment plot received two foliar broadcast spray applications of the 

test substance at a single application rate of 50 g ai/ha (0.0446 lb ai/A/application), for a total 

application rate of 100 g ai/ha (0.89 lb ai/A) for the two applications. The re-treatment interval 

was 14 days. Applications were made in a spray volume of approximately 19.8-20.8 gallons per 

acre and an adjuvant was added to the spray mixture for all applications. 

Samples were collected prior to each application, as soon as the spray dried after each 

application (0 to 8 hours), and at intervals of 1, 2, 4, 7, 10, 14, 21, 28, and 35 days after the final 

treatment (28 and 35 day samples were collected only at the GA site). At each sampling interval, 

single samples were collected from the control plot and triplicate samples were collected from 

the treated plots. Field-fortified samples prepared using wheat samples from the untreated 

control plot were prepared on Days 1 and 14 after the last application at the California site and 

on Days 1, 14, and 28 after the last application at the Georgia site. 

The Registrant provided DFRs in μg/cm2, corrected for an average procedural recovery of 91%. 

Versar also calculated DFRs in μg/cm2, but did not correct the results for either procedural 

recoveries or field fortification recoveries as average recoveries were >90%. For calculation 

purposes, DFR values reported as between the limit of quantitation (LOQ) and the limit of 

detection (LOD) were assigned a value of 1⁄2 LOQ and DFR values less than the LOD were 

assigned a value of 1⁄2 LOD. The LOQ was 0.20 ng/mL (0.0001 μg/cm2) and the limit of LOD 

was 0.075 ng/mL (0.000038 μg/cm2).

Average DFR values declined rapidly at all sites. The maximum average DFR values of 0.037 to 

0.119 μg/cm2 were observed either immediately after the first application or treatment (0DAT1) 

or second application (0DAT2). Residue levels dropped significantly within the first 10 days 

after the second application and were <LOQ or close to the LOQ by the end of the sampling 

period. The maximum percent of the application rate which was dislodgeable also occurred at 

0DAT1 or 0DAT2 and ranged from 7.35% to 24.3%. The 24.3% value occurred at the 500 

WDG California site after the second application. The value was significantly higher than the 

value after the first application at the same site (8.9%), in addition to all other sites. No 

explanation was provided for the high DFR values at the 0DAT2 interval at the 500 WDG

California trial.
Page 31 of 39

The magnitude of sulfoxaflor residues and the dissipation of sulfoxaflor between the 240 SC and 

500 WDG formulations and the trial locations were similar, with the exception of the 0DAT2 

DFRs at the 500 WDG California trial.

Versar assumed first-order dissipation kinetics to generate dissipation curves for sulfoxaflor. 

Versar conducted the linear regression analysis using the natural logarithm of the individual 

foliar residue values collected immediately after the second application through the last day of 

sampling or when all residues were <LOQ (22DAT2 for California trials and 20DAT2 for 

Georgia trials). Based on linear regression of the natural log transformed data, Versar’s 

calculated half-lives for sulfoxaflor wheat leaves were 3.46 days (R2= 0.719) for the 240 SC 

California site, 3.10 days (R2= 0.959) for the 240 SC Georgia site, 3.46 days (R2= 0.584) for the 

500 WDG California site and 2.85 days (R2= 0.966) for the 500 WDG Georgia site. A 

comparison of the actual and predicted values shows that the actual values were higher than the 

predicted values for the 0DAT2, 1DAT2, and/or 2DAT2 intervals for all trials, with significant 

differences observed for the California site. 

Rainfall (2.3 inches) occurred on the day prior to the 10DAT2 sampling interval at the Georgia 

site. Residues had already declined significantly by ; therefore, it is not expected that the results 

were significantly impacted by the rainfall. The Registrant calculated half-lives for the Georgia 

plots using only the 0DAT2 through 7DAT2 data to determine the affect of the rainfall event on 

9DAT2 at this site. As compared to the entire sampling period after the second application, the 

half-life values reduced slightly to 2.4 days (R2= 0.952) for the 240 SC trial and 2.7 days (R2= 

0.973) for the 500 WDG trial.

HED concurs with Versar’s primary review of the sulfoxaflor DFR Study on wheat. This study 

review was presented and discuss at the HED Science Advisory Council for Exposure on June 

30, 2011. The council agreed that foliar residue values for the 240 SC formulation (California = 

0.047 ug/cm2(0DAT2); Georgia = 0.030 ug/cm2(0DAT2)) and the 500 WSG (California = 

0.119 ug/cm2(0DAT2); Georgia = 0.026 ug/cm2(0DAT2)) collected immediately after the 

second application, would be used for calculating predicted day 0 residue values using first-order 

dissipation kinetics and decay model. The predicted day 0 residue values of 0.0175 ug/cm2

(240 SC Georgia) and 0.0210 ug/cm2(500 WDG Georgia) should be used to estimate 

occupational postapplication exposure and risk. A summary of the key inputs/results is 

presented in the table below.

Table A.1. Summary of DFR Values and Linear Regression Analysis Results for Treated Wheat with Sulfoxaflor.

Parameter 240 SC Formulation

California Georgia

Application Rate (lb ai/A)

Target Appl. Rate = 0.0446 lb ai/A

0.0438 (first application)

0.0452 (second application)

0.0446 (first application)

0.0446 (second application)

Measured Actual Average Day 0 Residue (μg/cm2)

0.047 (first application)

0.047 (second application)

0.037 (first application)

0.030 (second application)

Predicted Day 0 Residue (μg/cm2) 0.009524 0.01755

Slope -0.2003 -0.2234

Half-life (days) 3.46 3.10

R

2

0.719 0.959

Parameter 500 WDG Formulation

California Georgia
Page 32 of 39

Table A.1. Summary of DFR Values and Linear Regression Analysis Results for Treated Wheat with Sulfoxaflor.

Parameter 240 SC Formulation

California Georgia

Application Rate (lb ai/A)

Target Appl. Rate = 0.0446 lb ai/A

0.0439 (first application)

0.0440 (second application)

0.0446 (first application)

0.0446 (second application)

Measured Actual Average Day 0 Residue (μg/cm2)

0.045 (first application)

0.119 (second application)

0.049 (first application)

0.026 (second application)

Predicted Day 0 Residue (μg/cm2) 0.01163 0.02103

Slope -0.2001 -0.2435

Half-life (days) 3.46 2.85

R

2

0.584 0.966

Note: Linear regression analysis based on DFRs after second application.

Secondary Review: Dissipation of Dislodgeable Foliar Residues of Sulfoxaflor from Treated 

Broccoli; MRID No. 47832416.

The study “Dissipation of Dislodgeable Foliar Sulfoxaflor Residues from Treated Broccoli” was 

submitted by Dow AgroSciences LLC, in support of the registration of sulfoxaflor. 

This study was designed to determine the dissipation of dislodgeable foliar residues (DFR) of 

sulfoxaflor formulated as a 22.5% active ingredient (ai) suspension concentrate (XDE-240 SC) 

from treated broccoli at two trial sites: Porterville, CA and Omega, GA. Each trial site consisted

of one control plot and one treatment plot. The treatment plots received three groundboom 

broadcast spray applications of the test substance to the foliage. The single application rate was 

100 g ai/ha (0.0892 lb ai/A/application), for a total application rate of 300 g/ha (0.27 lb ai/A) for 

the three applications. The re-treatment interval between each application was 7 days. 

Applications were made as foliar broadcast spray applications at a spray volumes of 

approximately 19.9-20.9 gallons per acre and an adjuvant was added to the spray mixture for all 

applications. 

Samples were collected from: 1) one control and three treated samples prior to each application, 

2) as soon as the spray dried after each application (0 to 8 hours), and 3) at intervals of 1, 2, 3/4, 

7, 10, 14, 20/21, 27, and 35 days after the final treatment (27 and 35 day samples were only 

collected at the GA site). Field-fortified samples using samples from the untreated control plot 

were prepared on Days 1 and 14 after the last application at the California site and on Days 1, 14, 

and 27 after the last application at the Georgia site.

The Registrant provided DFRs in μg/cm2, corrected for an average procedural recovery of 93%. 

Versar also calculated DFRs in μg/cm2, but did not correct the results for either procedural 

recoveries or field fortification recoveries as average recoveries were >90%. For calculation 

purposes, DFR values reported as between the limit of quantization (LOQ) and the limit of 

detection (LOD) were assigned a value of 1⁄2 LOQ, and DFR values less than the LOD were 

assigned a value of 1⁄2 LOD. The LOQ was 0.20 ng/mL (0.0001 μg/cm2) and the LOD was 0.075 

ng/mL (0.000038 μg/cm2).

For the California site, the maximum average DFR values occurred after the 0-day sampling 

interval: 0.147 μg/cm2(14.8% of application) at 0-day after first treatment (0DAT1), 0.120 

μg/cm2(11.9% of application) at 0DAT2, and 0.147 μg/cm2(14.4% of application) at 0DAT3. 
Page 33 of 39

Residues were still above the LOQ prior to the third application (0.0067 μg/cm2). After the third 

application, the average DFR declined to 0.0017 μg/cm2by 21DAT3.

For the Georgia site, the maximum average DFR values after each treatment occurred at the 0-

day sampling interval: 0.319 μg/cm2(31.9% of application) at 0DAT1, 0.191 μg/cm2(19.1% of 

application) at 0DAT2, and 0.139 μg/cm2(13.9% of application) at 0DAT3. Residues were still 

above the LOQ prior to the third application (0.00057 μg/cm2). After the third application, the 

average DFR declined rapidly to 0.13 μg/cm2at 1DAT3 and residues were <LOQ by 10DAT3.

Versar assumed first-order dissipation kinetics to generate dissipation curves for sulfoxaflor. 

Versar conducted the linear regression analysis using the natural logarithm of the individual 

foliar residue values collected immediately after the third application through the last day of 

sampling or when all residues <LOQ (21DAT3 for California trial and 10DAT3 for Georgia 

trial). Based on linear regression of the natural log transformed data, Versar’s calculated halflives for sulfoxaflor treated broccoli leaves were 2.9 days (R2

= 0.917) for the California site and 

1.2 days (R2= 0.93) for the Georgia site. A comparison of the actual and predicted values 

determined after the third application shows that the actual values were higher than the predicted 

values for the 0DAT3, 1DAT3, 2DAT3, and 4DAT3 sampling intervals at the California site and 

at the 0DAT3 interval for the Georgia site.

Irrigation was applied at the rate of 3 inches per acre to the broccoli plots on days 7 and 14 

following the third application at the California site. Rain in excess of one inch (1.22 inches) 

occurred at the Georgia site on 2DAT3, following the sampling on this day. This rainfall event 

may have affected the amount of residue available for dislodging on subsequent sampling days. 

Residues had declined significantly by the 2DAT3 interval (13.9% at 0DAT3 to 0.67% at 

2DAT3). Significant rainfall (2.58 inches) also occurred at the Georgia site on 28DAT3.

HED concurs with Versar’s primary review of the sulfoxaflor DFR Study on broccoli. This 

study review was presented and discuss at the HED Science Advisory Council for Exposure on 

June 30, 2011. The council agreed that foliar residue values (California = 0.147 ug/cm2, and 

Georgia = 0.139 ug/cm2) collected immediately after the third application (0DAT3) at each test 

site, would be used for calculating predicted day 0 residue values using first-order dissipation 

kinetics and decay model. The predicted day 0 residue value of 0.115 ug/cm2(from 

California) should be used to estimate occupational postapplication exposure and risk. A 

summary of the key inputs/results is presented in the table below.

Table A.2. Summary of DFR Values and Linear Regression Analysis Results for Treated Broccoli with Sulfoxaflor. 

Parameter 240 SC Formulation

California Georgia

Application Rate (lb ai/A)

Target Appl. Rate = 0.0892 lb ai/A

0.0889 (first application)

0.0900 (second application)

0.0911 (third application)

0.0892 (first application)

0.0892 (second application)

0.0892 (third application)

Measured Actual Average Day 0 Residue 

(μg/cm2)

0.147 (first application 0DAT1)

0.120 (second application 0DAT2)

0.147 (third application 0DAT3)

0.319 (first application 0DAT1)

0.191 (second application 0DAT2)

0.139 (third application 0DAT3)

Predicted Day 0 Residue (μg/cm2) 0.115 0.0329

Slope -0.236 -0.591

Half-life (days) 2.9 1.2
Page 34 of 39

Table A.2. Summary of DFR Values and Linear Regression Analysis Results for Treated Broccoli with Sulfoxaflor. 

Parameter 240 SC Formulation

California Georgia

R

2

0.917 0.935

Note: Linear regression analysis based on DFRs collected after the third application.
Page 35 of 39

Appendix B. Anticipated Post-Application Activities and Dermal Transfer Coefficients.

Table B.1. Anticipated Post-Application Activities and Dermal Transfer Coefficients.†

Proposed Crop Crop Group Transfer Coefficients Activities EPA MRID No.

Field / row crop, 

low/medium

Barley, Wheat 70 cm2/hr Hand weeding 42851302, 42689103, 

42689104

1,100 cm2/hr Scouting 45005904, 45005908

Canola (Subgroup 

20A)

1,100 cm2/hr Scouting 45005904, 45005908

Cotton 70 cm2/hr Hand weeding 42851302, 42689103,

42689104

210 cm2/hr Scouting 42851302

900 g cotton/hr Harvesting Mechanical 

(Module Builder)

42701601

2400 g cotton/hr Harvesting Mechanical 

(Picker Operator; Raker)

42701601

5050 g cotton/hr Harvesting Mechanical 

(Tramper)

42701601

Soybean 70 cm2/hr Hand weeding 42851302, 42689103, 

42689104

1,100 cm2/hr Scouting 45005904, 45005908

Succulent Edible 

Podded and Dry 

Beans

70 cm2/hr Hand weeding 42851302, 42689103, 42689104

210 cm2/hr Scouting 42851302, 42974501

1100 cm2/hr Scouting 45005904, 45005908

1900 cm2/hr Irrigation (hand set) 45224801

Vegetable, head and 

stem Brassica

Brassica (Cole) 

Leafy Vegetables

230 cm2/hr Transplanting 45344501, 45469501, 45469502

330 cm2/hr Scouting 42974501

1400 cm2/hr Hand Weeding 45530102

1900 cm2/hr Irrigation (hand set) 45224801

4200 cm2/hr Weeding, Hand 45005906, 45005907, 45191701

Vegetable, "Root" Bulb Vegetables 

(Crop Group 3-07)

330 cm2/hr Scouting 42974501

1400 cm2/hr Hand Weeding 45530102

1900 cm2/hr Irrigation (hand set) 45224801

4200 cm2/hr Weeding, Hand 45005906, 45005907, 45191701

Leaves of Root 

and Tuber 

Vegetables (Crop 

Group 2)

70 cm2/hr Weeding, Hand 42851302, 42689103, 42689104

210 cm2/hr Scouting 42851302, 42974501

230 cm2/hr Transplanting 45344501, 45469501, 45469502

1100 cm2/hr Harvesting, Hand 43013003, 40966503, 40966502, 

45530103

1900 cm2/hr Irrigation (hand set) 45224801

Root and Tuber 

Vegetables (Crop 

Group 1)

70 cm2/hr Weeding, Hand 42851302, 42689103, 42689104

210 cm2/hr Scouting 42851302, 42974501

1100 cm2/hr Harvesting, Hand 43013003, 40966503, 40966502, 

45530103

1900 cm2/hr Irrigation (hand set) 45224801

Tree Fruit, Evergreen Citrus (Crop 

Group 10)

100 cm2/hr Hand weeding 43297602

230 cm2/hr Transplanting 45344501, 45469501, 45469502

580 cm2/hr Hand Pruning 45175102, 45480302

1400 cm2/hr Hand Harvesting 42830002, 40975308, 40966501, 

45138202, 45175101, 45432301,

45432302

3600 cm2/hr Thinning Fruit 42428101

Vegetable, Cucurbit Cucurbits 

Vegetables (Crop 

Group 9)

90 cm2/hr Scouting 45005909

230 cm2/hr Transplanting 45344501, 45469501, 45469502

550 cm2/hr Turning 45480301, 45491902

1900 cm2/hr Irrigation (hand set) 45224801

Vegetable, Fruting Fruiting 

Vegetables (Crop 

70 cm2/hr Weeding, Hand 42851302, 42689103, 42689104

90 cm2/hr Scouting 45005909
Page 36 of 39

Table B.1. Anticipated Post-Application Activities and Dermal Transfer Coefficients.†

Proposed Crop Crop Group Transfer Coefficients Activities EPA MRID No.

Group 8) 210 cm2/hr Scouting 42851302, 42974501

230 cm2/hr Transplanting 45344501, 45469501, 45469502

550 cm2/hr Tying/Training, Hand 

Harvesting

45480301, 45491902

1100 cm2/hr Harvesting, Hand 43013003, 40966503, 40966502, 

45530103

1900 cm2/hr Irrigation (hand set) 45224801

Vegetable, Leafy Leafy Vegetables 

except Brassica –

(Crop Group 4)& 

Watercress

70 cm2/hr Weeding, Hand 42851302, 42689103, 42689104

210 cm2/hr Scouting 42851302, 42974501

230 cm2/hr Transplanting 45344501, 45469501, 45469502

1100 cm2/hr Harvesting, Hand 43013003, 40966503, 40966502, 

45530103

1900 cm2/hr Irrigation (hand set) 45224801

Nursery/Greenhouse

(Unassigned)

Ornamentals 230 cm2/hr Harvesting, Hand 45344501, 45469501, 45469502

1900 cm2/hr Irrigation (hand set) 45224801

Tree, "Fruit", 

Deciduous

Pome Fruits (Crop 

Group 11)

100 cm2/hr Orchard Maintenance, 

Propping, Hand Weeding

43297602

230 cm2/hr Transplanting 45344501, 45469501, 45469502

580 cm2/hr Scouting, Hand Pruning, 

Training

45175102, 45480302

1400 cm2/hr Harvesting, Hand 42830002, 40975308, 40966501, 

45138202, 45175101, 45432301, 

45432302

3600 cm2/hr Thinning Fruit 42428101

Stone Fruits (Crop 

Group 12)

100 cm2/hr Orchard Maintenance, 

Propping, Hand 

Weeding, Thinning 

Fruit, Bird Control 

43297602

230 cm2/hr Transplanting 45344501, 45469501, 45469502

580 cm2/hr Scouting, Hand Pruning, 

Training

45175102, 45480302

1400 cm2/hr Harvesting, Hand 42830002, 40975308, 40966501, 

45138202, 45175101, 45432301, 

45432302

3600 cm2/hr Thinning Fruit 42428101

Vine /Trellis Small Fruit Vine 

Climbing (except 

fuzzy kiwifruit –

Subgroup 13-07F)

230 cm2/hr Transplanting 45344501, 45469501, 45469502

640 cm2/hr Scouting, Hand Pruning, 

Hand Weeding, 

Propagating, Bird 

Control, Trellis Repair, 

Tying/Training

45005910

1900 cm2/hr Irrigation (hand set) 45224801

5500 cm2/hr Leaf Pulling, 

Tying/Training, Hand 

Harvesting

43223907, 40985601

10100 cm2/hr Leaf Pulling, 

Tying/Training, Hand

Harvesting

45491901

19300 cm2/hr Turning, Girdling 40975304

Berry, Low Low Growing 

Berry (Subgroup 

13-07G)

70 cm2/hr Hand Weeding, Hand

Pruning (shears),

Canopy Management

42851302, 42689103, 42689104

210 cm2/hr Scouting 42851302, 42974501

230 cm2/hr Transplanting 45344501, 45469501, 45469502

1100 cm2/hr Hand Harvesting

(ranking), 

Scouting

43013003, 40966503, 40966502

45530103, 45005904, 45005908

1900 cm2/hr Irrigation (hand set) 45224801
Page 37 of 39

Table B.1. Anticipated Post-Application Activities and Dermal Transfer Coefficients.†

Proposed Crop Crop Group Transfer Coefficients Activities EPA MRID No.

Tree, “Nut” Tree Nuts (Crop 

Group 14 & 

Pistachio)

100 cm2/hr Orchard Maintenance, 

Poling, Hand Weeding

43297602

190 cm2/hr Harvesting, Mechanical 

(shaking)

41848604

230 cm2/hr Transplanting 45344501, 45469501, 45469502

580 cm2/hr Scouting 45175102, 45480302

1400 cm2/hr Harvesting, Hand (net) 42830002, 40975308, 40966501

45138202, 45175101, 45432301

45432302

Turf/Sod Turfgrass, 

Sodfarms

6700 cm2/hr Maintenance, 

Harvesting, Slab

Transplanting/Planting

45432303

†The information in the table is based on proprietary and non-proprietary data.

Appendix C. Summary of Residue Data from Cotton Field Trials with Sulfoxaflor.

Table C.1. Summary of Residue Data from Cotton Field Trials with Sulfoxaflor.

a

Commodity EPb Total appl. rate

lb a.i./A

PHI 

(day) n

Sulfoxaflor Residue (ppm)

Min Max HAFTc Median

(STMdR)

Mean

(STMR) Std. Dev.

Cotton,

(gin 

byproducts)

240

SC 0.346-0.375 14-15 42 0.037 4.20 4.03 0.476 0.869 1.12

Cotton, 

(undelinted 

seed)

240

SC 0.346-0.375 14-15 44 <0.010 0.182 0.176 0.019 0.037 0.038

a

 The LOQ (0.010 ppm) was used for all residue values reported as <LOQ in all calculations (mean, median, etc.). 

Data are on a per-sample basis and do not reflect per-trial averaging. 

b

 EP = End-use Product; Test item was GF-2032 240 g/L SC formulation.

c HAFT = Highest Average Field Trial.
Page 38 of 39

Appendix D. Crop Groupings.

• Brassica (Cole) Leafy Vegetables - crop group 5 includes broccoli, broccoli raab, Brussels 

sprouts, cabbage, cauliflower, cavalo, Chine broccoli (gai lon), Chinese cabbage (bok choy), 

Chinese cabbage (napa), Chinese mustard cabbage (gai choy), collards, kale, kohlrabi, mizuna, 

mustard greens, mustard spinach, rape greens, white flowering broccoli.

• Bulb Vegetables - crop group 3-07 includes beltsville bunching onion, bulb daylily, bulb 

fritillaria, bulb garlic, bulb lily, bulb onion, bulb shallot, Chinese bulb onion, Chinese fresh leaf 

chive, elegans hosta, fresh leaf chive, fresh leaf shallot, fresh onion, garlic, great-headed bulb 

garlic, green onion, kurrat, lady's leek, leek, leaf fritillaria, macrostem onion, pearl onion, potato 

bulb onion, serpent bulb garlic, tree onion tops, Welsh onion, wild leek and cultivars, varieties, 

and/or hybrids of these.

• Canola (Rapeseed) - subgroup 20A includes borage, canola, crambe, cuphea, echium, flax 

seed, gold of pleasure, hare's ear mustard, lesquerella, lunaria, meadowfoam, milkweed, mustard 

seed, oil radish, poppy seed, rapeseed, sesame, sweet rocket, and cultivars, varieties, and/or 

hybrids of these.

• Citrus - crop group 10 includes citrus citron, grapefruit, kumquat, lemon, lime, orange, 

tangelo, tangerine, and hybrids of these.

• Cucurbit Vegetables - crop group 9 includes balsam apple, balsam pear, bitter melon, casaba, 

chayote, Chinese cucumber, Chinese okra, crenshaw melon, crookneck squash, cucumber, 

cucuzza, edible gourds, golden pershaw melon, hechima, honey balls, honeydew melon, hyotan, 

mango melon, muskmelons (cantaloupe, honeydew, etc.), Persian melon, pineapple melon, 

pumpkin, Santa Claus melon, scallop squash, snake melon, spaghetti squash, straightneck 

squash, summer squash, true cantaloupe, vegetable marrow, watermelon, winter squash, and 

other varieties and/or hybrids of these.

• Fruiting Vegetables - crop group 8-10 includes bell pepper, eggplant, groundcherry, hot 

pepper, pepino, pepper (except black), pimento, sweet pepper, tomatilo, tomato.

• Leafy Vegetables, except Brassica - crop group 4 & Watercress includes amaranth, arugula, 

cardoon, celery, celtuce, chervil, Chinese celery, Chinese spinach, corn salad, cos (romaine), 

dandelion, dock, edible-leaved chrysanthemum, endive (escarole), finochio, Florence fennel, 

garden cress, garden purslane, garland chrysanthemum, head lettuce, leaf lettuce, leafy amaranth, 

New Zealand spinach, orach, parsley, radicchio (red chicory) rhubarb, spinach, sweet anise, 

sweet fennel, Swiss chard, tampala, upland cress, vine spinach, winter cress, winter purslane, 

yellow rocket.

• Leaves of Root and Tuber Vegetables - crop group 2 includes bitter cassava, black salsify, 

broccoli raab, carrot, celeriac (celery root), chicory, dasheen (taro), edible burdock, garden beet, 

hanover salad, oriental radish (daikon), parsnip, raab, raab salad, radish, rutabaga, sugar beet, 

sweet cassava, sweet potato, tanier, true yam, turnip, turnip-rooted chervil.
Page 39 of 39

• Pome Fruits - crop group 11 includes apples, crabapple, loquat, quince, mayhaw, pears, 

quince.

• Root and Tuber Vegetables - crop group 1 includes arracacha, arrowroot, bitter black salsify, 

bitter cassava, carrot, celeriac, chayote (root), chicory, Chinese artichoke, chufa, daikon, 

dasheen, edible burdock, edible, canna, garden beet, ginger, ginseng, horseradish, Jerusalem 

artichoke, leren, lobok, lo pak, oriental radish, parsnip, potato, radish, red Chinese radish, red 

Japanese radish, rutabaga, salsify, skirret, Spanish salsify, sugar beet, sweet cassava, sweet 

potato, tanier, true yam, turmeric, turnip, turnip-rooted chervil, turnip-rooted parsley, yam, yam 

bean, white Chinese radish, white Japanese radish, winter radish, and other cultivars or hybrids 

of these).

• Small Fruit Vine Climbing, except Fuzzy Kiwifruit - subgroup 13-07F includes amur river 

grape, gooseberry, grape, hardy kiwifruit, maypop, schisandra berry, and cultivars, varieties, 

and/or hybrids of these.

• Low Growing Berry - subgroup 13-07G includes bearberry, bilberry, lowbush blueberry, 

cloudberry, cranberry, lingonberry, muntries, partridgeberry, strawberry, and cultivars, varieties, 

and/or hybrids of these.

• Stone Fruits - crop group 12 includes apricot, nectarine, peach, plum, prune, sweet cherry, tart 

cherry.

• Succulent, Edible Podded, and Dry Beans includes adzuki bean, asparagus bean, bean, 

blackeyed pea, broad bean, chickpea, Chinese longbean, cowpea, fava bean, field bean, garbanzo 

bean, grain lupine, green lima bean, jackbean, kidney bean, lablab bean, lima bean, moth bean, 

mung bean, navy bean, pinto bean, rice bean, runner bean, snap bean, soybean (immature seed), 

sweet lupine, sword bean, tepary bean, wax bean, white lupine, white sweet lupine, yardlong 

bean.

• Tree Nuts - crop group 14 & Pistachio includes almonds, cashew, chestnut, filbert (hazelnut), 

macadamia nut, pecan, walnut.