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Section 18 Application – sulfoxaflor (TransformTM) 

Mississippi Cotton 

Submitted by the Mississippi Department of Agriculture

(a) General information required in an application for a specific, quarantine or public 

health exemption. An application must be submitted in writing by the head of the Federal 

or State agency, the Governor of the State involved, or their official designee. If a 

designee has been delegated authority to request exemptions, written authorization of 

such delegation must accompany the request or be on file with the Agency. In addition, 

the application must contain all applicable information specified in paragraphs (a) (1) 

through (11) of this section.

(1) Identity of contact persons. (i) Unless otherwise specified, the person who submits 

the application will be considered the contact person for all matters relating to 

administration of the emergency exemption.

Tommy McDaniel, Director Pesticide Division

Bureau of Plant Industry

Mississippi Department of Agriculture

705 Stone Blvd. Robert H. McCarty Building

P.O. Box 5207

Mississippi State, MS 39762

Phone: 662 323-9379

Fax:

Email: tommym@mdac.state.ms.us

(ii) University contact:

Angus Catchot, Associate Professor of Extension

Mississippi State University

Department of Entomology

100 Twelve Lane

Mississippi State, MS 39762

Off: 662 325-2085

Cell: 662 418-8163

Email: acatchot@ext.msstate.edu

(2) Description of the pesticide. The application shall contain a description of the 

pesticide(s) proposed for use under the exemption. Such information shall include:

(i) For a federally registered pesticide product:

(A) A copy of the label(s) if a specific product(s) is/are requested; or the formulation(s) 

requested if a specific product is not requested; and

(B) A copy of any additional labeling proposed for the emergency exemption; or
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(ii) For any other pesticide products:

Transform WG (EPA Reg. No. 62719-xxx)

Active ingredient – Sulfoxaflor (50%)

Manufactured by Dow AgroSciences

(A) A confidential statement of formula or reference to one already submitted to the 

Agency; and 

A Confidential Statement of Formula has been previously submitted to EPA with 

the Section 3 registration package for Transform WG (GF2372, active ingredient 

sulfoxaflor). Transform WG is a WDG formulation of the active ingredient 

sulfoxaflor.

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

The proposed label is included as an attachment as Appendix LABEL. See 

attached.

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

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

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

Mississippi for the purpose of controlling the tarnished plant bug, Lygus lineolaris

(Palisot de Beauvois). 

(ii) The method of application:

Foliar applied by air and ground.

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

1.5-2.75 oz product/acre (0.047-0.086 lb AI/acre). Annual use will not exceed 0.266 

lbs active ingredient per acre.

(iv) The maximum number of applications:

Four applications per acre per year.

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

Mississippi planted approximately 425,000 acres of cotton during 2010.

http://www.nass.usda.gov/Charts_and_Maps/graphics/cotnacm.pdf). Mississippi

producers treated ≈98% (396,950 acres) of the total planted acreage for the control 

of tarnished plant bug, Lygus lineolaris (Palisot de Beauvois) during 2010 (data in 

press). During 2009, Mississippi treated 259,555 (96%) of the 286,902 planted 

cotton acres for tarnished plant bug control (http://www.entomology.msstate.edu/ 

resources/tips/cotton-losses/data/). Cotton acreage in Mississippi is projected to 

increase during 2011 ≈20-25% above that in 2010 for a total planted acreage of 
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550,000 acres. During 2011, Mississippi has the potential need to treat 75% 

(≈412,500) of its acreage with sulfoxaflor for control of tarnished plant bug. This

assessment is based on conservative estimates of the 2011 acreage increases 

and 2009-2010 historical treated acres for tarnished plant bug control in 

Mississippi.

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

and product:

Tarnished plant bug, Lygus lineolaris (Palisot de Beauvois), infestations are likely 

to cause economic losses on approximately 467,500 acres in Mississippi during 

2011. Therefore up to four applications of sulfoxaflor will be required on these 

acres to reduce the impact of this pest. The high rate (2.75 oz/acre) can only be 

used in three of those applications to prevent exceeding total annual rate of 8.5 oz 

product or 0.266 AI per acre. Based upon this maximum allocation of 8.5 oz (1.5-

2.75 oz of formulated product per acre per application), treated (total sprayed) 

acreage will require no more than 292,186 pounds of formulated product on 

Mississippi‟s 550,000 acres. 

(vii) All applicable restrictions and requirements concerning the proposed use which may 

not appear on labeling:

All applicable restrictions and requirements will appear on the package label and 

Section 18 label:

 Pre-harvest Interval: Do not apply within 14 d of harvest.

 Minimum Treatment Interval: Do not make applications less than 5 d apart.

 Do not make more than one application on pre-bloom cotton.

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

 Do not make more than two consecutive applications per crop.

 Do not apply more than a total of 8.5 oz of Transform WG (0.266 lb AI of 

sulfoxaflor) per acre per year.

(viii) The duration of the proposed use:

June – September of the 2011 cotton growing season 

(ix) Earliest possible harvest dates:

August 25, 2011

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

explanation of why the pesticide(s) currently registered for the particular use proposed in 

the application is not available in adequate supplies and/or effective to the degree 

needed to control the emergency. If the applicant states that an available registered 

pesticide is ineffective for the given situation, the statement must be supported by field 

data which demonstrate ineffectiveness of registered pesticides, or, if such data are 

unavailable, statements by qualified agricultural experts, extension personnel, university 

personnel or other persons similarly qualified in the field of pest control;
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Several IPM strategies are recommended for controlling tarnished plant bug in 

cotton. Non-chemical tactics include area-wide control of non-crop alternate hosts 

and selected host plant resistance traits. These only serve to suppress 

populations and are not effective as stand-alone practices. Chemical control 

strategies remain the primary tool used to manage this pest. Presently, numerous 

insecticides are recommended against tarnished plant bug, but varying levels of 

resistance has been documented to nearly every class of these compounds 

among Mid-South (Arkansas, Louisiana, Mississippi, Tennessee) populations of 

this insect. Populations have demonstrated resistance to pyrethroids and some 

organophosphates for several years (Snodgrass and Gore 2007), but many 

populations remained susceptible to neonicotinoid insecticides including 

thiamethoxam and imidacloprid (Snodgrass et al. 2008). Acephate has been the 

most widely used and effective insecticide for control of plant bugs in cotton but 

efficacy continues to decrease in Mississippi and much of the mid South. Three 

years of study by Copes et al. (2010) clearly shows that acephate efficacy is 

rapidly eroding across Louisiana (Figure 2, Copes et al. 2010).

Even though acephate expressed partial efficacy against tarnished plant bugs in 

Mississippi, higher rates (0.75 to 1.25 lb AI/acre) were necessary each year from 

2007-2009 to maintain the infestations below the action threshold. The highest 

rate actually exceeded the labeled rate that could be used. These field efficacy 

results are supported by laboratory data from Snodgrass which show significant 

levels of OP resistance in tarnished plant bug populations throughout the hills 

and delta in Arkansas, Louisiana, and Mississippi. During the past two years, 

populations in these states also have been expressing lower susceptibility to 

neonicotinoid products, but no high levels of resistance have been documented. 

(Snodgrass 2010 abstract, See Appendix A).

Cook et al. (2007) showed that standard insecticide use strategies can reduce 

tarnished plant bug numbers, but none are consistently effective and can maintain 

sub-economic injury levels for the season. During 2009, a regional (Arkansas, 

Louisiana, Mississippi, and Tennessee) full-season insecticide screen was used to 
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evaluate a list of products for control of tarnished plant bug. Six sprays were 

applied to the Louisiana trial which was designed to simulate moderate to high 

pest infestation levels, typical of the situation in many Louisiana and Mid-South 

cotton fields (Figure 1, Sharp et al. 2010 and B. R. Leonard unpublished).

 

Using seasonal means of tarnished plant bug nymphs as a metric for insecticide 

efficacy, all treatments significantly reduced numbers relative to a non-treated 

control. However, only Endigo and Diamond successfully reduced numbers 

below the action threshold (line marked with AT) used to gauge the need for 

additional treatments to stop yield losses. In addition, all of the bars highlighted 

with an asterisk (*) illustrate that six applications of those treatments exceeded 

the total allowable seasonal AI/acre. Only Vydate and Intruder AI‟s were not 

exceeded. Yield losses have become severe in these situations in spite of 

multiple insecticide sprays. Currently, the only chemical strategy recommended 

is to co-apply two insecticides and rotate among chemical classes. 

In some areas across Mississippi and the Mid-South region, tarnished plant bug 

infestations have reached outbreak levels and become uncontrollable. In 

Mississippi during 2007, producers averaged approximately 7-10 insecticide 

applications for this pest (Catchot 2007). The highest insecticide application 

frequency in Mississippi prior to 2007 was 5.2 sprays per year and occurred 

during 2004 in that state. Mississippi producers averaged 6.5 applications during 

2007 (Williams 2008) for this pest, but some areas received 10-14 treatments. 

Current trends with insecticide resistance and lack of effective alternative 

technologies will allow problems with tarnished plant bug management to 

intensify across Mississippi and the Mid-South states. Chemical control options 

that provide consistent efficacy are not available to manage this pest. Effective 
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Lygus control is a serious, unmet need for Mid-South cotton growers and one that 

requires immediate and urgent action. This has now become an emergency 

situation.

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

plant bug populations in these States have become significantly more difficult to 

control using common recommended insecticides (Lorenz et al. 2009; Moore et al. 

2010). As a result, the numbers of applications and use rates needed to control 

tarnished plant bug have increased. With a novel mode of action and chemical 

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

resistant populations of tarnished plant bug, thereby improving the overall cotton 

IPM system. This would be a tremendous economic opportunity for cotton 

growers, and more environmentally-friendly alternative to the sustained frequency 

of the currently used products. 

As expected, the excessive use of some products for tarnished plant bug are now 

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

some areas. This is of great concern to many producers and pest management 

practitioners. Organophosphate, carbamate and pyrethroid insecticides can 

impact natural beneficial arthropod populations and flare secondary insects. 

Acephate is commonly used for Lygus control and can flare aphids and mites. 

Pyrethroid insecticides may flare aphids and mites, as well. Sulfoxaflor should 

reduce the frequency of selected insecticides use, especially acephate, 

dicrotophos, and oxamyl. The ecological and toxicological profile of sulfoxaflor is 

considered to be more favorable than the ecological and toxicological profiles of 

these insecticides. Limited data currently suggest that sulfoxaflor is not likely to 

flare aphids and mites. 

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

provide adequate control or would not be economically or environmentally feasible.

Several IPM strategies are recommended for controlling tarnished plant bug in 

cotton (Gore et al. 2008). Non-chemical tactics include area-wide control of noncrop alternate hosts and selected host plant resistance traits. Proper selection of 

varieties and managing the optimum planting period are being to produce a rapid 

fruiting and early maturing crop; thereby reducing the time the crop is susceptible

to this pest. Careful insecticide application timing based upon revised spray 

action thresholds are used to precisely target populations before they reach 

outbreak levels. All of these practices are currently in place and are being used 

by cotton producers. However, these strategies only serve to suppress 

populations and are not effective as stand-alone practices. Effective chemical 

control practices are still necessary to provide tarnished plant bug management 

in cotton. 

(5) Effectiveness of proposed use. 

The application shall contain data, a discussion of field trials, or other evidence which 

provide the basis for the conclusion that the proposed pesticide treatment will be 

effective in dealing with the emergency.
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Sulfoxaflor (DAS test code GF-2372, proposed trade name TransformTM) has been 

evaluated in laboratory and field trials for the past several years. Recent 

publications by Babcock et al. (2010, See Appendix B) and Zhu et al. (2010, See 

Appendix C) clearly define the biology and biochemistry of sulfoxaflor and 

demonstrate a novel mode of action against sap feeding insects including those 

in the order Heteroptera. Insects in the genus Lygus are included this order. 

Sulfoxaflor-induced mortality was similar between insecticide-resistant and –

susceptible strains of several Homoptera and Heteroptera. No cross-resistance 

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

of modes of action. The effectiveness of sulfoxaflor against insecticidesusceptible populations of tarnished plant bug, Lygus lineolaris (Palisot de 

Beauvois) was comparable to those of other labeled classes of insecticides. 

These research projects support a novel mode of action for sulfoxaflor including 

those insecticides with similar chemical structures (neonicotinoids). 

Numerous field trials were performed during 2008-2010 across the Mid-South 

States against tarnished plant bug and are in the process of being published. The 

first field results were reported by Smith et al. (2010, See Appendix D) for 

Mississippi trials and show levels of efficacy comparable to or significantly better 

than standards (acephate, Bifenthrin, thiamethoxam) on one or more sample 

periods against tarnished plant bug nymphs. For Louisiana during 2009-2010, 

Hardke (2011, Submitted to Entomological Society of America‟s Arthropod 

Management Tests, See Appendix E) summarized the results of field trials for 

sulfoxaflor performance against tarnished plant bug. In the 2009 trials, effective 

rates and application frequencies were defined compared to standard products. In 

a co-application trial with a pyrethroid-resistant population, sulfoxaflor 

outperformed Endigo and Bifenthrin (alone) on one or more post-treatment 

evaluation dates. Based upon total insects during 2010, sulfoxaflor at the upper 

rate and in combination with novaluron demonstrated significantly better control 

of tarnished plant bugs than acephate and efficacy equivalent to a combination a 

pyrethroid and thiamethoxam (Endigo). Reports of additional field trials from 

Arkansas, Mississippi, and Tennessee are in preparation and will serve to support 

the Louisiana results. 

A multi-state (AR, LA, MS, TN) summary of field trials against “high pressure” 

tarnished plant bug infestations on cotton during 2008-2010 is reported in 

Appendix F. These results demonstrated sulfoxaflor at one or more rates 

demonstrated control of plant bugs (high population levels) superior to the OP, 

dicrotophos. The residual efficacy of sulfoxaflor was greater than that for both 

dicrotophos and thiamethoxam. Efficacy was similar to a co-application of a 

pyrethroid + neonicotinoid. In a comparison of cotton yields among treatments for 

these trials, sulfoxaflor was similar to that of acephate (Acephate is broader

spectrum and may have provided some yield increase from additional caterpillar 

pest control). Pest management practitioners recognize that sulfoxaflor should 

not be used as a single, season-long treatment, so chemical control strategies 

with co-applications and/or rotation for sequential treatments are the logical use 

pattern.

When sulfoxaflor was evaluated as a component of this type of strategy, those 

use patterns with sulfoxaflor maintained tarnished plant bug populations below 

the action threshold for the duration of the trial; whereas a standard strategy was 
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unable to provide satisfactory control. In a commercial field, the standard 

treatments (without sulfoxaflor) would have required additional applications to 

reduce populations. In the season-long trials, strategies relying on sulfoxaflor 

significantly increased cotton yield above the standard-treated and non-treated 

plots. Willrich et al. (2010, see Appendix G) further summarized results for 2008-

2009 as an abstract and reported sulfoxaflor‟s acute toxicity for knockdown of 

tarnished plant bug infestations at ≤ 5 d and residual control extending for ≥ 7 d. 

In addition, cotton treated with sulfoxaflor produced lint yields equal to or 

superior than cotton treated with acephate (1.0 lb AI/acre) across 16 trials.

All available data indicates that sulfoxaflor is an alternative product to the 

insecticides currently used to manage tarnished plant bug on cotton. It will be an 

excellent tool for Mississippi and Mid-South cotton IPM programs by improving 

efficacy, reducing input costs, and increasing yields. This compound has a 

selective spectrum of activity, has not flared other pests, can be used as a

rotational partner with other chemistries, and has demonstrated value against 

insecticide-resistant populations. It is likely that sulfoxaflor will be the backbone 

of chemical control strategies for tarnished plant bug and is desperately needed 

in this emergency situation. 

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

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

such residues and shall contain an estimate of the maximum amount of the residue likely 

to result from the proposed use, together with the information on which such estimates 

are based.

For the Section 18, cotton is the crop to be treated. Applications made in 

accordance with the Section 18 label directions will not exceed a residue in cotton 

of 0.17 ppm (Proposed MRL 0.20 ppm; 0.0015 ppm for cotton-oil, is 0.15 ppm for 

seeds). EPA will establish a temporary tolerance for this use.

(7) Discussion of risk information. 

The sulfoxaflor registration application submitted to EPA July 31, 2010 by Dow

AgroSciences has addressed the potential risks to human health, endangered or 

threatened species, beneficial organisms, and the environment expected to result 

from the proposed use, together with references to data and other supporting 

information.

Studies done with sulfoxaflor indicate there is no reason to expect that any 

increased risk from this use on cotton would occur either to beneficial organisms 

or to the environment compared with the current regimen of insecticides used on 

cotton today. The products that sulfoxaflor would replace are acephate and 

dicrotophos among others. Sulfoxaflor has a softer profile on beneficial 

organisms and endangered species than the insecticides it will replace.

Human Health (provided by registrant) The Tier 1 acute dietary exposure 

assessment (i.e., MRL-level residues, 100% crop treated) and a refined chronic 

dietary exposure assessment (i.e., average residues from field trials with 

processing factors, or as estimated for meat, milk, poultry and eggs) demonstrate 

dietary (food + water) exposures that are below the aPAD and cPAD, respectively, 
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for all subpopulations. Thus, this dietary exposure assessment demonstrates a 

reasonable certainty of no harm associated with the proposed use of sulfoxaflor.

Sulfoxaflor exhibits low acute mammalian toxicity (EPA Toxicity Categories III-IV). 

No effects occurred in any genotoxicity study. Results from subchronic and 

chronic toxicity studies revealed the liver to be the primary target organ with 

effects of limited concern or no relevance to humans. Acute bolus doses caused 

transient signs of cholinergic toxicity, but neurotoxicity did not occur at high 

doses in a dietary subchronic study, or in a developmental neurotoxicity study. 

Reproduction and developmental studies identified a marginal delay in puberty 

onset in males with no apparent sequelae. Peri-post natal effects occurred in rats 

but not in rabbits and were shown not to be relevant to humans. Carcinogenicity 

studies in rats and mice demonstrated that the rodent liver effects resulted in 

tumors following a lifetime of exposure, but the underlying mechanism is well 

known and has been found to be of little or no concern to humans. In rats but not 

mice, high doses of sulfoxaflor increased the size of naturally occurring testicular

tumors, which, in turn, led to several secondary effects in associated tissues. 

Based on these results, the principal target organ for sulfoxaflor is the liver, the 

most common target organ for the toxicity of pesticides. Sulfoxaflor has no 

genotoxic potential, has little to no concern from a reproduction perspective, and 

has low concern for carcinogenicity. When used as directed, sulfoxaflor 

represents a low hazard to humans. 

Endangered Species

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

US Fish and Wildlife Service website. (see attachment, Appendix H). None of 

these species would be impacted by applications of sulfoxaflor to control plant 

bugs, due to very low toxicity to these organisms and/or the fact that they do not 

occur in the Mississippi cotton ecosystem. 

Beneficial Organisms

The acute and long-term environmental toxicology studies of sulfoxaflor 

conducted to fulfill the requirements of the US EPA as indicated in Subpart G 40 

CFR §158.630 are to provided by Registrant. Regarding aquatic species, 

sulfoxaflor exhibits very low acute toxicity to fish, freshwater crustaceans 

(Daphnia), oysters, algae, and aquatic vascular plants. Species sensitive to 

sulfoxaflor include midge larvae, Chironomus species (sediment-dwelling 

insects), and the mysid shrimp Americamysis bahia (a saltwater free-swimming 

crustacean). Sulfoxaflor exhibited effects on growth in long-term, early-life-stage 

toxicity tests in the freshwater fish fathead minnow and the saltwater fish 

sheepshead minnow, slight effects on reproduction at a high concentration of 100 

mg/L in a life-cycle test on Daphnia magna, and effects on time to first brood in 

mysid shrimp in a life cycle study. Sulfoxaflor may be considered by US EPA 

standards to be „slightly‟ to „moderately‟ toxic to birds in acute oral toxicity 

studies. Sulfoxaflor did not exhibit any effects on reproduction in birds. 

Sulfoxaflor exhibited acute toxicity to honey bees in the direct contact toxicity 

test. However, aged residue toxicity tests in which honey bees were exposed to 

field-aged residues on alfalfa leaves indicated significant reduction of acute 

toxicity to acceptable levels after at least 3 hours of aging. At labeled use rates, 
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sulfoxaflor exhibited no phytotoxicity in seedling emergence and vegetative vigor 

tests in 10 crop species.

Resulting Environment From Use

Mississippi‟s farmscape should experience a reduction in the numerous 

insecticide applications used to control tarnished plant bug. This reduction will 

be even more important considering that many of those replaced applications will 

be for organophosphates and/or carbamates. The availability of sulfoxaflor on 

cotton will directly reduce alternative sprays for the target pest, but also indirectly 

reduce probability of flaring secondary pests. This can further reduce the number 

of total sprays (all products) on cotton.

8) Coordination with other affected State or Federal agencies. If the proposed use of the 

pesticide is likely to be of concern to other Federal or State agencies, the application 

shall indicate that such agencies have been contacted prior to submission of the 

application, and any comments received from such agencies shall be submitted to EPA.

The following state agencies have been contacted:

Mississippi‟s Bureau of Plant Industry

(9) Acknowledgment by registrant. The application shall contain a statement by the 

registrants of all pesticide products proposed for use acknowledging that a request has 

been made to the Agency for use of the pesticide under this section. This 

acknowledgment shall include a statement of support for the requested use, including 

the expected availability of adequate quantities of the requested product under the use 

scenario proposed by the applicant(s); and the status of the registration in regard to the 

requested use including appropriate petition numbers, or of the registrant's intentions 

regarding the registration of the use.

Dow AgroSciences is the registrant for sulfoxaflor. Dow AgroSciences supports 

the use of sulfoxaflor for a Section 18 emergency use on cotton for the control of 

Lygus in the states of Mississippi, Arkansas, Louisiana, and Tennessee as a 

regional emergency use (See Appendix I). At this time, Dow AgroSciences 

predicts that it will be able to supply adequate quantities of sulfoxaflor for the 

emergency use on cotton in the designated region. 

Dow AgroSciences has submitted sulfoxaflor for a Section 3 registration on July 

31, 2010, including use on cotton. A complete residue package has been 

submitted to EPA for cotton on July 31, 2010. In addition, sulfoxaflor is part of a 

Global Joint Review with two other countries, Canada and Australia. Estimated 

time for a full Section 3 registration in the US is January 1, 2012.

(10) Description of proposed enforcement program. Prior to approval, the applicant shall 

provide an explanation of the authority of the applicant or related State or Federal 

agencies for ensuring that use of the pesticide under the proposed exemption would 

comply with any special requirements imposed by the Agency and a description of the 

program and procedures for assuring such compliance.

(Currently N/A - sulfoxaflor is not yet registered in US)
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Provisions provided under the Section 18 Emergency Exemption 

(11) Repeated uses. Applications for the use of a pesticide at a site for which the 

applicant has previously been exempted under section 18 shall contain an interim report 

summarizing the results of the specific, quarantine, or public health exemption previously 

issued, if the application is submitted prior to the time the final report for the previous 

exemption is due. The interim report shall contain that information specified in §166.32 

to the extent available at the time the application is made.

This is the first year this use has been requested under a Section 18 of FIFRA.

(b) Information required for a specific exemption. An application for a specific exemption 

shall provide all of the following information, as appropriate, concerning the nature of the 

emergency:

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

Lygus lineolaris (Palisot de Beauvois), tarnished plant bug 

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

Prior to the mid-1990‟s, tarnished plant bugs were generally controlled by 

insecticides directed at other pests during the flowering period of cotton; 

therefore, economic damage from tarnished plant bugs during flowering was 

relatively uncommon. However, with >80% of Mid-South (Arkansas, Louisiana, 

Mississippi, Tennessee) cotton now being planted to transgenic cotton 

expressing one or more toxins derived from Bacillus thuringiensis (Bt) (Williams 

2008) and the eradication of the boll weevil, Anthonomus grandis grandis

Boheman (Coleoptera: Curculionidae), many of the foliar applications for other 

pests during flowering have been eliminated. An increase in federal 

conservation/wetlands reserve programs, wide scale adoption of conservation 

tillage systems, and increased diversity of the summer farmscape with crop 

rotations have created a more favorable environment enhancing tarnished plant 

bug population development. Recently, this region has experienced a significant 

reduction in cotton acres and subsequent increase in field corn which also has 

exacerbated this emergency situation. The tarnished plant bug has adapted to 

some grass crops with reproduction on field corn which provides a non-sprayed 

on-farm refuge for immigration to “fewer” cotton acres; thereby concentrating the 

population. The consequence of these Southern production system changes is 

that tarnished plant bug has become the dominant season-long pest across this 

region during the last decade. Just due to higher populations which persist longer 

during the season, control costs and crop losses associated with tarnished plant 

bugs have increased dramatically. Typically, fewer than two applications per 

season were directed towards this pest prior to the mid-1990‟s. By 2007, an 

average of 7.5 insecticide applications targeted this pest the Delta region of 

Mississippi (Williams 2008). 

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

pest has intensified selection for resistance. Snodgrass and Gore (2007) has 
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reported resistance to a number of OP‟s, carbamates, and pyrethroids. Producers 

were relying heavily on neonicotinoids (thiamethoxam, imidacloprid), but now 

some populations are expressing reduced sensitivity to those products. In 

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

availability. In order to obtain some level of population management, there has 

been an increase in rates to the highest dose labeled for a single application. 

Tarnished plant bug management in many Mid-South fields has degraded to a 

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

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

the stages of crop protection, cotton producers and pest management 

practitioners are in crisis phase with tarnished plant bug. The subsequent step is 

that of the disaster phase which would result in a collapse of the existing pest 

management system for Mid-South cotton. 

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

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

pesticide; and

See above discussion. Sulfoxaflor is expected to replace significant quantities of 

alternative products that are used at higher rates and represent greater risk to the 

environment and beneficial organisms.

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

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

as appropriate:

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

expected losses in quantity due to the emergency;

In a review of pest significance by regions, the tarnished plant bug has had the 

most severe impact on Mid-South cotton during the past 5 years. In these areas, 

specifically in the delta regions of Arkansas, Louisiana, and Mississippi, it has 

been ranked the number one most yield limiting pest over the last several years 

(Williams 2008). In 2007, control cost for tarnished plant bug in the Mid-South was 

at least three-fold greater than the national average control cost (Figure 3). 
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Figure 3. Average cost of control per acre for plant bugs (Lygus spp.) in each cotton 

producing state during 2007.

Tarnished plant bug is a pest that is not a restricted problem on local acreage. 

During the past 5 years, this pest infested greater than 90% of the planted acreage 

in Mississippi (Table 1). Direct losses from this pest in Mississippi indicate a ~1-

4-% yield loss in spite of spending an average of >$5 mill/year for control. This 

should be considered a conservative estimate because currently there is no 

alternative strategy which can be used to eliminate crop damage and cotton yield 

losses from tarnished plant bug. Based on Mississippi‟s 2010 historical insect 

losses and yield data, producers spent $4.5MM with an estimated yield loss of 

$56.00/Acre for this pests alone and as high as $93.00 per acre loss in 2010. 

These data are outlined in the chart/Excel file below and published on the website: 

http://www.entomology.msstate.edu/resources/tips/cotton-losses/ data/. 
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Table 1. Historical perspective of economic losses for cotton production associated with the tarnishe plant bug

MS Acre Bale $ Lost Application Cost Chemical Cost Totals

Year Acres Planted Treated Acres Bales Lost Yield Loss $ Lost to Lygus/Acre App Cost Total Chem $ Total $ loss

2010 425,000 396,950 42,907 3.87% $93.80 $1,984,750.00 $4,533,169.00 $39,864,936.00

2009 296,344 259,555 19,996 2.60% $72.81 $1,297,775.00 $2,964,118.10 $21,575,528.00

2008 362,611 302,249 9,122 1.06% $42.32 $1,511,245.00 $3,451,683.58 $12,791,177.68

2007 666,000 555,000 21,458 1.01% $48.14 $2,775,000.00 $6,338,100.00 $26,717,700.00

2006 1,200,000 1,040,557 25,063 0.65% $22.93 $5,202,785.00 $11,883,160.94 $23,859,972.01

5 YA 589,991 510,862.20 23,709.20 1.84% $56.00 $2,554,311.00 $5,834,046.32 $24,961,862.74
15

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

anticipated in the absence of the emergency and changes in prices and/or production 

costs due to the emergency;

The trends previously described (Section b4i) clearly show the recent (5 years) 

significance of the problem and magnitude of costs and yield losses associated 

with tarnished plant bugs in cotton.

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

reasonably anticipated in the absence of the emergency;

The trends previously described (Section b4i) clearly show the recent (5 years) 

significance of the problem and magnitude of costs and yield losses associated 

with tarnished plant bugs in cotton.

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

The absence of new products to manage tarnished plant bug has seriously 

impaired the economic viability of cotton across Mississippi and the rest of the 

Mid-South region. Use of the available products in the recommended chemical 

control strategy is not economically feasible, sustainable, or environmentally 

friendly. During the anticipated conditional Section 18 registration period (2011), 

sulfoxaflor has the potential to mitigate the substantial financial losses, and 

become part of a holistic IPM program for cotton growers. 

References used to support previous statements and Section 18 request:

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

Nolting, R. B. Rogers, T. C. Sparks, J. D. Thomas, G. B. Watson and Y. Zhu. 

Biological Characterization of Sulfoxaflor, a Novel Insecticide. 2010. Pest Mgmt. 

Sci. (In press, See Appendix C).

Catchot, A. 2007. Mississippi Crop Situation. No. 21. http://www.msucares.com 

/newsletters/pests/cis/index.html.

Cook, D. R., B. R. Leonard, E. Burris, and D. R. Burns. 2007. Tarnished plant bug 

management in Northeast Louisiana, pp. 1704-1710. In Proc. Beltwide Cotton 

Prod. Res. Conf., National Cotton Council, Memphis, TN. 

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

2010. Acephate resistance is widespread in Louisiana tarnished plant bug 

populations. La. Agric. 53: 14-15.

Gore, J., G. Andrews, J. Robbins, A. Catchot, F. Musser, J. Smith, G. Snodgrass, 

R. Jackson, C. Abel, D. Dodds, G. Lorenz, S. Akin, G. Studebaker, R. Leonard, R. 

Bagwell, S. Stewart, and K. Tindall. 2008. Strategies for managing tarnished plant 

bugs in cotton. Miss. State Univ. White Paper Recommendations Report, 4 pp. 

released April 2008. 
16

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

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

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

Metcalf and W. Luckmann eds. Introduction to Pest Management. John Wiley and 

Sons, New York, NY. 

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

Sharpe, E. Burris and K. A. Fontenot. 2010. Proc. Beltwide Cotton Conf. 817-819. 

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

T. Hardke. 2010. Can we rely on any single insecticide for season long tarnished 

plant bug control in Louisiana cotton, p. 1170. In Proceedings, 2010 Beltwide 

Cotton Conferences, National Cotton Council, Memphis, TN.

Smith, J. F., L. N. Owen, and A. L. Catchot. 2010. Efficacy of foliar insecticides 

against tarnished plant bug on cotton (TEST 2), 2009. http://www.entsoc.org/

Protected/AMT/members only/AMT35/F/F27.pdf.

Snodgrass, G. L. 2010. Status of Insecticide Resistance: Tarnished Plant Bug. 

Proceedings, Cotton Incorporated Seminar, Memphis, TN (November 9-11, 2010)

See Appendix A.

Snodgrass, G. L. and J. Gore. 2007. Status of insecticide resistance for the 

tarnished plant bug, pp. 56-59. In Proc. Beltwide Cotton Res. Conf., National 

Cotton Council, Memphis, TN.

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

Determining Resistance Levels in Tarnished Plant Bug Populations to 

Neonicotinoid Insecticides. Southwestern Entomologist 33: 173-180. 

Williams, M. R. 2008. Cotton insect losses, pp. 927-929. In Proc. Beltwide Cotton 

Res. Conf., National Cotton Council, Memphis, TN.

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

J.S. Richburg. 2010. Performance of Dow AgroSciences‟ Sulfoxaflor insecticides 

against tarnished plant bug, Lygus lineolaris, in Mid-South cotton, pp. 1204. . In

Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, TN.

Zhu, Y., M. R. Loso, G. B. Watson, T. C. Sparks, R. B. Rogers, J. X. Huang, C. B. 

Gerwick, J. M. Babcock, D. Kelley, V. B. Hegde, B. M. Nugent, J. M. Renga, I. 

Denholm, K. Gorman, G. DeBoer, J. Hasler, T. Meade, and J. D. Thomas. 2010.

Discovery, Biology and Biochemistry of Sulfoxaflor: A Novel Sap-Feeding 

Insecticide. J. Agric. Food Chem. (Accepted for publication, See Appendix C).