Graham Head, Ph. D

Insect Resistance Management Lead

Monsanto Company

December 4, 2013

1

Monsanto Comments to EPA’s 

Scientific Advisory Panel
Overview 

 Summary of 2011-2013 corn rootworm (CRW) 

performance inquiries and their distribution

 Profile of performance inquiries by year and what that tells us

 How 2011 and 2012 CRW performance inquiries were 

managed through Best Management Practices (BMPs)

 Implementation of BMPs on all performance inquiry fields

 The broader IRM strategy

2 Monsanto comments to the SAP
Following up on Rootworm Damage Reports 

3

Performance 

Inquiry

• Investigative 

Steps

Unexpected 

Damage

• Trigger

• Investigative 

Steps

Population of 

Concern

• Trigger

• Remedial action

• Investigative 

Steps

Resistant 

Population

• Trigger

• Remedial action

Monsanto comments to the SAP
2011 Performance Inquiries 

4 Monsanto comments to the SAP
5

2012 Performance Inquiries 

Monsanto comments to the SAP
6

2013 Performance Inquiries 

Monsanto comments to the SAP
Performance Inquiries from 2011-2013 

 Similar number of performance inquiries each year but 

geographical distribution has varied from year-to-year

 Total acreage impacted about 50,000 acres (<0.2% of the 

product acres) 

 Almost all performance inquiries continue to involve single 

trait technologies (>95%)

7 Monsanto comments to the SAP
0

50

100

150

200

250

CO IA IL KS MN NE SD

First year continuous corn Second year continuous corn Third year continuous corn

History of Performance Inquiry Fields (2012): Associated with multiple years of continuous corn 

8
Performance Inquiry Fields: Typically involve a portion of a single field on a farm 

9 Monsanto comments to the SAP
Performance Inquiry Trends 

and Strategy for BMPs 

 Typically affect a single field per farm with a history of at 

least three years of corn-on-corn planting

 Indicative of performance inquiries arising independently 

from a similar set of conditions, rather than spreading from a 

number of focal points

 Supports a management approach that focuses on problem 

fields and considers both IRM and CRW population control

10 Monsanto comments to the SAP
Growers instructed to use one of three options on 

performance inquiry fields 

BMP options chosen to meet requirements for 

responding to “populations of concern” but 

conservatively were implemented on all performance 

inquiry fields

 Rotate to soybeans or alternative crop

 Plant Genuity® SmartStax® RIB CompleteTMcorn

 Continue to manage beetles

 Plant YieldGard VT Triple® or Genuity® VT Triple PROTM and either:

1) Use a soil-applied insecticide at planting to control larvae

2) Chemigate Brigade or Lorsban to control larvae

3) Use Brigade to control beetles and reduce egg laying

11 Monsanto comments to the SAP
BMPs on Performance Inquiry Fields 

in 2012 and 2013 

12

Best Management Practices Adopted 

Crop Year 2012

Rotate 

Genuity SmartStax

Non-Cry3Bb1 Corn

VT3 + Insecticide

Best Management Practices Adopted 

Crop Year 2013

Rotate 

Genuity SmartStax

Non-Cry3Bb1 Corn

VT3 + Insecticide

Monsanto comments to the SAP
13

2011 Performance Inquiries with 

SmartStax RIB in 2012 

0

0.

0.

0.

0.

0.

0.

Mean(NIS)

CO IA IL KS MN NE SD

Monsanto comments to the SAP
2011 Performance Inquiries with 

VT3/VT3P + Insecticide in 2012 

14

0

0.

1

1.

2

Mean(NIS)

CO IA IL KS MN NE

Site State/Province

Monsanto comments to the SAP
Performance and Follow-up of BMPs 

 >95% of BMPs resulted in excellent control and minimal 

CRW populations; these fields are being treated as reset

 Where BMPs did not provide satisfactory control, fields are 

being rotated to alternative crops (if at all possible) or nonCry3Bb1 products 

 Similarly, any new performance inquiry fields that involve 

SmartStax are being rotated to alternative crops (if at all 

possible) or non-Cry3Bb1 products; other new performance 

inquiries are addressed with any of the full set of BMPs

15 Monsanto comments to the SAP
IRM strategy for high CRW fields 

 The same set of BMPs are being recommended for all cornon-corn plantings in high pressure areas

 Continuing to increase availability of pyramided 

technologies (SmartStax RIB hybrids) in high CRW 

pressure areas

 Robust solution to compliance issues: in 2013, all Monsanto 

Bt products (single and pyramided traits) were available in 

RIB format in the Corn Belt

16 Monsanto comments to the SAP