Request for Section 18 emergency use of Sulfoxaflor (Transform® WG 

Insecticide) to control tarnished plant bug (Lygus lineolaris) in cotton 

fields in the state of Mississippi.

Type of Exemption - Mississippi Section 18; Specific Exemption Request; March 1, 2016

This is an application for a specific exemption to authorize the use of Sulfoxaflor (Transform® 

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

following information is submitted in the format indicated in the proposed rules for Chapter 1, 

Title 40 CFR, Part 166. 

SECTION 166.20(a) 1: IDENTITY OF CONTACT PERSONS

i. The following are the contact persons responsible for the administration of 

the emergency exemption:

John G. Campbell, Director

Mississippi Department of Agriculture & Commerce

Bureau of Plant Industry

P. O. Box 5207

Mississippi State, MS 39762

Tel: 662.325.3390

Email: Johnca@mdac.ms.gov

Jasper L. Cobb, Branch Director 

Mississippi Department of Agriculture & Commerce

Bureau of Plant Industry

P. O. Box 5207

Mississippi State, MS 39762

Tel: 662.325.3390

Email: jasper@mdac.ms.gov

ii. The following qualified experts are also available to answer questions:

University Representative

Dr. Angus Catchot

Mississippi State University

Extension Professor 

Biochemistry, Molecular Biology, Entomology & Plant Pathology 

Box 9775

Mississippi State, MS 39762

Tel: 662.325.2085

Fax: 662.325.8837

Email: acatchot@entomology.mstate.edu 
Registrant Representative

Tami Jones-Jefferson

U.S. Regulatory Leader 

U.S. Regulatroy & Government Affaris – Crop Protection

Dow AgroSciences

9330 Zionsville Road

Indianapolis IN, 46268

Tel: 317.337.3574

Email: tjjonesjefferson@dow.com

Jamey Thomas 

US Regulatory Manager

Dow AgroSciences 

9330 Zionsville Road 

Indianapolis, IN. 46268

Cooperating Agency

Mississippi Cooperative Extension Service 

Mississippi State University

Mississippi State, MS 39762

SECTION 166.20(a) 2: DESCRIPTION OF PESTICIDE REQUESTED

Common Chemical Name (Active Ingredient): Sulfoxaflor

Brand/Trade Name and EPA Reg. No.: Transform® WG Insecticide,

EPA Reg. No. 62719-625

 Formulation: Active Ingredient 50%

SECTION 166.20(a) 3: DESCRIPTION OF PROPOSED USE

i. Sites to be treated:

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) before, during, and after the flowering period when cotton is susceptible to 

pest damage. 

ii. Method of Application:

Applications will be made by foliar application. 

iii. Rate of Application:

1.5 – 2.25 oz/ac (0.047 – 0.071 lb ai/ac). Annual use will not exceed 0.266 lb ai/ac.

iv. Maximum Number of Applications:

No more than four applications per season.
v. Total Acreage to be Treated:

Cotton acreage in Mississippi is projected to be ~450,000 acres in 2016. During 2016, 

Mississippi has the potential need to treat 75% (337,500) of its acreage with 

sulfoxaflor for control of tarnished plant bug

vi. Total Amount of Pesticide to be used:

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

cause economic losses on all Mississippi cotton acres but emergency use will be 

restricted to 337,500 acres in Mississippi during 2016. Therefore, up to four

applications of sulfoxaflor may be required on these acres to reduce the impact of this 

pest. However, no more than 4 applications per growing season. There will be no 

more than 8.5 oz of product used per acre per season. Maximum amount of 

formulated product would be 179,297 lbs or 89,649 lb ai.

vii. Restrictions and Requirements:

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

directions for use and conditions of sale and warranty information. It is a violation of 

federal law to use this product in a manner that is inconsistent with all applicable label 

directions, restrictions and precautions found in the container label and this 

supplemental label. Both the container label and this supplemental section 18 

quarantine exemption label must be in the possession of the user at the time of 

application.

Applicable restrictions and requirements concerning the proposed use and the 

qualifications of applicators using Transform® WG are as follows:

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

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

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

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

sulfoxaflor) per acre per year.

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

the following:

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

treatment, applications should be made within three hours of sunset 

during the flowering period.

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

their farm are advised to implement cooperative standards outlined in 

the Mississippi Honeybee Stewardship Program.

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

exceed thresholds published in MSU-ES Insect Control Guide P2471 (equal to 

or greater than 15 per 100 Sweeps or 3 per 5 row ft on a drop cloth).
viii. Duration of the Proposed Use:

June, 2016 – October, 2016

ix. Earliest Possible Harvest Date:

September 15 in Mississippi, typically.

SECTION 166.20(a) 4: ALTERNATIVE METHODS OF CONTROL IN MISSISSIPPI

Insecticide Resistance: Pyrethroids

Presently, several 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 (Snodgrass 1996, Snodgrass and Scott 2000) since the 

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

in Mississippi because resistance to this class has become widespread and field experiments 

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

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

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

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

1). 

Insecticide Resistance: Organophosphates and Carbamates

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

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

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

and much of the mid-South. For the purpose of measuring tarnished plant bug resistance to the 

Figure 1. An experiment showing the best available control with Brigade (bifenthrin) at the highest labeled rate (6.4 fl 

oz product per acre) in 2008.

9

4.3

19.2

32

0

5

10

15

20

25

30

35

Acephate (0.5) Brigade (4) + Acephate (0.5) Brigade (6.4) Non-treated

No. / 5 ft

b
organophosphates, acephate has been used in bioassays to represent the entire class because it is 

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

levels of resistance to acephate also have high levels of resistance to dicrotophos (Figure 2). 

Figure 2 shows the resistance ratios (yellow bars) Baythroid (pyrethroid), Bidrin (OP), Orthene 

(OP), and Vydate (carbamate) for tarnished plant bugs. This particular population shows high 

levels of cross resistance to all classes of insecticides evaluated. The orange bars show percent 

mortality of tarnished plant bugs caged on cotton plants sprayed with each of the insecticides. In 

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

greater than 48% mortality at field use rates. Additionally, preliminary research suggests that 

there are multiple mechanisms of resistance to the OP’s. There appears to be populations with 

target site insensitivity, and metabolic resistance. Most of the plant bug populations across 

Mississippi express target site insensitivity, which confers cross resistance to the other 

organophosphates and carbamates. Populations that only have metabolic resistance do not always 

exhibit cross resistance with other insecticides and the cross resistance appears to be linked to the 

specific enzymes involved.

In Mississippi, field efficacy with both acephate and dicrotophos has been steadily declining in 

recent years. Table 1 provides a summary of results from insecticide screening trials conducted 

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

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

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

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

period (Table 1). With these levels of control, growers commonly experience field control 

failures with all of the organophosphates currently labeled for tarnished plant bug control in most 

areas of Mississippi. As a result, organophosphates are no longer recommended by MSU-ES 

specialists unless they are applied in a tank mix with another class of insecticide.

18

7

3.6 3.6 4.8

0

25

44

39

48

20

8

0

10

20

30

40

50

60

70

80

90

100

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

RR Percent Mortality

Percent/RR

Figure 2. Resistance ratios and control of tarnished 

plant bugs with multiple classes of insecticides. 
Table 1. Average (Standard Error) yields for Acephate and Dicrotophos from trials 

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

2005.

Acephate Dicrotophos

Year % 

Control

Yield

(Lint/A)

% Yield

Reduction

% 

Control

Yield

(Lint/A)

% Yield 

Reduction

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

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

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

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

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

2010 45.8 (2.3) 984575.9 26.6 28.2 (4.3) 970 (77.0) 29.4

P <0.01 <0.01 <0.01 <0.01

Neonicotinoids

The neonicotinoid class of insecticides are recommended for both tarnished plant bug and cotton 

aphid control in Mississippi. The insecticides in this class have historically only shown marginal 

control of tarnished plant bug in most cases. Thiamethoxam is by far the most active insecticide 

in this class. In contrast, acetamiprid is least effective in this group against tarnished plant bug. 

In general, the neonicotinoids provide similar control to that observed with acephate at 1 lb ai/A. 

In an experiment from 2008, all of the treatments reduced tarnished plant bug numbers and 

flower bud injury compared to the non-treated control (except plant bug numbers for Trimax 

Pro) (Table 2). 

Table 2. Percent square damage 5 days after treatment 2 with neonicotinoids and 

neonicotinoid/pyrethroid premixes in 2008.

Treatment Rate (lb ai/A) Mean No. TPB Damage

Centric 0.0625 19b 28 b

Endigo 5.5 fl oz/A 17b 11 c

Trimax Pro 0.062 29ab 37 b

Leverage 5 fl oz/A 22b 21 bc

Orthene 1.0 20b 36 b

Orthene + Brigade 0.5 + 0.1 19b 19 bc

Non-treated --- 34 a 61 a

Although no resistance has been documented and confirmed with field control failures to this 

class of insecticide, in 2015 numerous reports of field control failures with thiamethoxam were 

reported. Control of tarnished plant bug has always been highly variable with the neonicotinoids, 

but monitoring data since 2006 shows elevated resistance ratios with imidacloprid every year 

(Table 3). 
Table 3. Results of monitoring tarnished plant bug susceptibility to neonicotinoids in the 

mid-South.

Imidacloprid Thiamethoxam

Year Mean RR Highest RR Mean RR Highest RR

2006 3.2 7.6 1.0 1.6

2007 3.0 5.0 0.8 1.6

2008 2.9 6.5 0.7 1.2

2009 3.1 5.7 0.9 1.8

2010 2.7 5.8 1.8 9.0

Thiamethoxam has remained more susceptible, but one population in 2010 showed an elevated 

resistance ratio compared to a susceptible population. This may represent the initial stages of 

resistance development to neonicotinoids by tarnished plant bug. Based on reports of field 

control failures with thiamethoxam in 2015, we are planning an increased effort for monitoring 

in 2016. Small plot studies are currently limited, but our data is also indicating a decline in 

efficacy with thiamethoxam (Figure 3).

Figure 3.

Others

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

first is flonicamid (Carbine) a pyridine carboxamide. Although this insecticide does show some 

activity against tarnished plant bugs and provides good control of western tarnished plant bug 

(Lygus hesperus), results have not been promising in the mid-South. The data below shows the 

results for an experiment conducted in Stoneville, MS in 2009. The data show the number of 
nymphs 5 days after the second application of each insecticide in an overall control program. A 

total of 7 insecticide applications were made to the entire field. Five of those applications were 

blanket applications applied across the entire field. Carbine did not reduce tarnished plant bug 

densities below that observed in the non-treated control (Table 4).

Table 4. Results from an experiment conducted in Stoneville, MS in 2009.

Treatment Rate Nymph/5 ft.

Centric 2 oz/A 12.6 B

Bidrin 8 fl oz/A 9.4 B

Acephate 0.75 lb ai/A 5.9 B

Carbine 2.8 oz/A 22.1 A

Non-treated 24.3 A

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

an insect growth regulator, it only controls the immature stages of tarnished plant bug and has no 

activity against adults. Field testing of this insecticide generally showed variable results in terms 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

time frame, susceptible stages of nymphs (1st-3

rd Instars) have time to develop to less susceptible 

stages.

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

nymphs in a controlled experiment in Stoneville, MS.

Treatment Rate Percent Adults

UTC --- 96.7 A

Diamond 2 83.3 AB

Diamond 4 60.0 BC

Diamond 6 58.5 C

Diamond 9 69.7 BC

Diamond 12 47.8 C
Over the last several years, we have discovered better ways to use Diamond in an overall TPB 

management program. Research in Mississippi, Louisiana, and Arkansas has shown that early 

preventative applications can help reduce the impact of tarnished plant bugs in cotton. However, 

the timing of these applications is critical and must target the eggs and early instar stages. The 

difficulty in using eggs as a trigger is that tarnished plant bugs insert their eggs into plant tissue 

and are not visible in the field. This combined with the difficulty in controlling late instar 

nymphs a less than desirable for managing this pest.

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 without effective alternative technologies will allow 

problems with tarnished plant bug management to intensify across Mississippi and the MidSouth states. Chemical control options that provide consistent efficacy have not been available to 

manage this pest prior to the use of Transform. Effective Lygus control in the absence of 

Transform is a serious, unmet need for Mid-South cotton growers and one that requires 

immediate and urgent action. Loss of Transform has now put Mississippi producers back into an 

emergency situation.

These results have shown that regardless of the registered insecticide prior to the use of 

Transform for tarnished plant bug, populations in these States were 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 increased

during that period. Because sulfoxaflor is a novel mode of action and chemical class, 

successfully controlling both insecticide-susceptible and -resistant populations of tarnished plant 

bug, it has become a valuable part of our overall cotton IPM system. Table 6 shows a study 

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

an overall management program. In this trial, a total of 7 applications were made. Each of the 

insecticides being tested was applied four times, but no more than two times in a row. Ratings of 

tarnished plant bug control were made after the underlined treatments. These data show that 

none of the treatment programs provided consistent control of tarnished plant bugs over the 

entire season. As a result, yields for all of the spray programs were very low compared to state 

averages in 2010. This experiment shows that an overall tarnished plant bug program is not 

feasible or economical for producers with the few insecticide classes that are currently labeled in 

the mid-South.
Table 6. Evaluation of tarnished plant bug management programs in Mississippi in 2010.

Treatment 5 DAT 1

% Control

13 DAT 1

% Control

7 DAT 2

% Control

14 DAT 2

% Control

7 DAT 3

% Control

7 DAT 4

% Control

Lint 

Yield

Vydate 0.33 lb fb Centric 2.5 oz fb

Orthene 0.75 lb fb

Orthene 0.75 lb fb

Diamond 6 oz fb

Orthene 0.75 lb fb

Orthene 0.75 lb

69 54 50 0 57 0 549

Vydate 0.33 lb fb Centric 2.5 oz fb 

Diamond 9 oz fb

Diamond 9 oz fb

Orthene 0.75 lb fb

Diamond 9 oz fb

Diamond 9 oz

60 72 0 31 62 73 482

Vydate 0.33 lb fb Centric 2.5 oz fb 

Bidrin 6 oz fb

Bidrin 6 oz fb

Diamond 6 oz fb

Bidrin 6 oz fb

Bidrin 6 oz

53 36 0 0 38 0 343

Vydate 0.33 lb fb Centric 2.5 oz fb 

Vydate 10 oz fb

Vydate 10 oz fb

Diamond 6 oz fb

Vydate 10 oz fb

Vydate 10 oz

31 0 75 0 72 0 343

Vydate 0.33 lb fb Centric 2.5 oz fb 

Centric 2 oz fb

Centric 2 oz fb

Diamond 6 oz fb

Centric 2 oz fb

Centric 2 oz

21 16 0 0 72 0 405

Vydate 0.33 lb fb Centric 2.5 oz fb 

Endigo 5 oz fb

Endigo 5 oz fb

Diamond 6 oz fb

Endigo 5 oz fb

Endigo 5 oz

19 12 0 0 26 67 567

Vydate 0.33 lb fb Centric 2.5 oz fb 

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz fb

Diamond 6 oz fb

Trimax Pro 1.5 oz fb

Trimax Pro 1.5 oz

0 0 0 0 31 23 358

Vydate 0.33 lb fb Centric 2.5 oz fb 

Carbine 2.5 oz fb

Carbine 2.5 oz fb

Diamond 6 oz fb

Carbine 2.5 oz fb

Carbine 2.5 oz

0 40 0 0 18 0 405

Vydate 0.33 lb fb Centric 2.5 oz fb 

Leverage 360 3.2 oz fb

Leverage 360 3.2 oz fb

Diamond 6 oz fb

Leverage 360 3.2 oz fb

Leverage 360 3.2 oz

0 0 0 0 15 0 397

Vydate 0.33 lb fb Centric 2.5 oz fb 

Intruder 1.1 oz fb

Intruder 1.1 oz fb

Diamond 6 oz fb

Intruder 1.1 oz fb

Intruder 1.1 oz

0 12 0 0 42 0 372

Vydate 0.33 lb fb Centric 2.5 oz fb 

Brigade 5.12 oz fb

Brigade 5.12 oz fb

Diamond 6 oz fb

Brigade 5.12 oz fb

0 24 0 17 38 0 312
Brigade 5.12 oz

Check NA NA NA NA NA NA 225

*Ratings start after 4th application

It has been clearly documented in the past that excessive use of non-selective and disruptive 

products for tarnished plant bug can induce additional pest problems (spider mites and cotton 

aphids) in some areas. In Mississippi there is a strong correlation between the numbers of 

applications targeting tarnished plant bugs and other pests such as cotton aphids and spider mites 

(Figure 4). 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 

use will reduce the frequency of selected insecticides used, especially acephate, dicrotophos, and 

oxamyl. The ecological and toxicological profile of sulfoxaflor is considered to be more 

favorable than the ecological and toxicological profiles of these insecticides. Data currently 

suggest that sulfoxaflor will not flare aphids and mites and will be safer to pollinators than 

alternatives.

Figure 4.

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

adequate control or would not be economically or environmentally feasible.

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

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

host plant resistance traits. Proper selection of varieties and managing the optimum planting 

period are being used to produce a rapid fruiting and early maturing crop; thereby reducing the 

time the crop is susceptible to this pest. Careful 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 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

1 3.1 5.2 4.9 3.2 7.5 5.5 6.5 6

Spider Mites

Cotton Aphid

Mite/Aphid Applications

Figure 3. Correlations between tarnished plant bug applications and

applications for other cotton pests. 

Lygus Applications

r = 0.9634

r = 0.8401
plant bug management in cotton. As highlighted above the current situation in Mississippi has 

produced severe economic burdens on cotton producers. Mississippi and other mid-South states 

have experienced greater reductions in cotton acres compared to other cotton producing regions 

of the country. The recent increase in cost of tarnished plant bug control is an important reason 

for the decrease in cotton acres in the mid-South. Currently, tarnished plant bugs have 

widespread resistance to the pyrethroids, organophosphates, and carbamates. In the case of the 

organophosphates, resistance is partially dominant. A recent study by Snodgrass and Gore 

showed that because the trait is not recessive, resistance levels do not decline during the winter. 

Also, relevant genetics data suggests that gene flow can occur between populations that are up to 

approximately 10 miles apart. These factors have contributed to the rapid spread of resistance in 

the Mississippi, Arkansas, and Louisiana. Also, this makes predicting where the resistance 

levels will be highest from year to year extremely difficult. The widespread resistance to 

pyrethroids, organophosphates, and carbamates renders these insecticides nearly useless for 

economical cotton production without effective alternatives. In years prior to Transform use, 

field use rates have more than doubled and control continued to decline with available products. 

This put a tremendous pressure on the neonicotinoid class. Of that class, thiamethoxam had by 

far been the most effective in the class for tarnished plant bug control, however there is now 

elevated concern due to widespread reports of field failures in 2015. Consequently, two to four 

pre-flower applications in cotton target both tarnished plant bugs and cotton aphids. Centric 

(thiamethoxam) has been the insecticide of choice in this situation because it provided better 

control of the whole pest complex than other neonicotinoids at that time of the year. The most 

common rate used at that time of year is 2 oz formulated product per acre (0.05 lbs ai/A). The 

maximum seasonal use rate for Centric is 5.0 oz (0.125 lb ai thiamethoxam). Therefore, two 

applications of Centric at 2 oz/A (0.05 lbs ai per acre per application) during the pre-flowering 

period does not leave enough active ingredient for later applications of either Centric or Endigo 

(thiamethoxam + lambda-cyhalothrin). The only other labeled insecticides available are Carbine 

(flonicamid) and Diamond (novaluron). Table 4 above shows typical results observed with 

Carbine in Mississippi and other mid-South states for tarnished plant bug. Diamond is the only 

other insecticide available for late season tarnished plant bug control. As mentioned previously, 

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

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

Also, application timing is critical with this insecticide and applications are often sprayed too 

late to provide the most effective levels of control. Therefore, the use of Transform will and has 

provided significant economic benefits for cotton growers in Mississippi and are demonstrated in

the tier 1 and tier 2 analysis provided. Furthermore, the use of Transform since 2012 has replaced 

products that are well known to be more toxic to honeybees therefore increasing the overall 

safety to bees in Mississippi (Zhu et al.)

SECTION 166.20(a) 5: EFFECTIVENESS OF PROPOSED USE

Value of Transform in an Overall IPM Approach for Tarnished Plant Bug in Cotton

Multiple experiments have been conducted throughout Mississippi to evaluate an overall 

integrated pest management approach for tarnished plant bug in cotton and the importance of 

various insecticides in that approach. Inconsistent control with most of the currently labeled 

insecticides due to documented resistance highlighted above has forced growers to adopt 

multiple best management practices to economically manage tarnished plant bug. Although these 
best management practices have improved tarnished plant bug management, insecticides remain 

an important component. In particular, the registration of sulfoxaflor in 2012 (Section 18 in 2012 

and Section 3 in 2013-15) increased the adoption of the overall IPM approach. 

Sulfoxaflor rapidly became the foundation for the IPM approach because of its high level of 

efficacy against tarnished plant bug and the relative safety for beneficial insects (Fig. 5). Even at 

very high use rates (100 g ai/ha=3.0 oz/A), significantly more beneficial arthropods were 

conserved compared to the pyrethroid (Warrior) and the organophosphate (Orthene). Similar 

results were observed by Kerns et al. (2011) where densities of convergent lady beetles for 

sulfoxaflor were not significantly different than Carbine. Both the Carbine and sulfoxaflor had 

significantly lower densities than the untreated control which was most likely due to the 

reduction in prey (cotton aphid) in the treated plots. 

Figure 5. Impact of various rates of sulfoxaflor and other insecticides on natural enemy 

populations in cotton in California.

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

sprays with high rates of organophosphates and pyrethroids (usually applied as a tank mix) 

targeting tarnished plant bug reduce natural enemy populations and “flare” other pests such as 

twospotted spider mite or cotton aphid. A study conducted in Stoneville, MS in 2013 compared 

Effect of GF-2032 on natural enemies

in cotton, WRC, Fresno, CA, 2008

0

2

4

6

8

10

12

Treatments

GF2032 @ 12.5 g. ai/ha GF2032 @ 25 g. ai/ha GF2032 @ 38 g. ai/ha GF2032 @ 50 g. ai/ha

GF2032 @ 75 g. ai/ha GF2032 @ 100 g. ai/ha Assail @ 56 g. ai/ha Warrior CS @ 28 g. ai/ha

Carbine @ 100 g ai/ha Orthene 90S @ 1 lb ai/a Lorsban 4E @ 1 lb ai/ha UTC Season-long average natural enemies in 10 sweep net passes

ab ab

b

ab

b ab

ab

d

ab

cd

bc

P = 0.0009 a
overall management programs. The treatments included cotton grown with all classes except 

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

one to two applications were needed for twospotted spider mite in the treatments where 

sulfoxaflor was not used (Figure 6). Additionally, the treatments that did not include sulfoxaflor 

each needed to be sprayed separately for cotton aphid (Figure 6). A portion of this is due to 

sulfoxaflor’s ability to control cotton aphids, but preservation of beneficial insects also 

contributed. In summary, the use of sulfoxaflor for tarnished plant bug management can reduce 

the number of insecticide applications targeting other pests because of the lower toxicity to 

beneficial arthropods. Overall, yields and economic returns were greater where all classes of 

insecticides were included.

Figure 6. Impact of insecticide use programs for tarnished plant bug management on the number 

of insecticide sprays for twospotted spider mite and cotton aphid. 

The tarnished plant bug IPM program has been important for increasing the profitability of 

cotton programs in Mid-South cotton. However, diversity in the available classes of insecticides 

available to manage tarnished plant bug is critical to make the overall IPM approach successful. 

In particular, insecticides that provide high levels of efficacy against tarnished plant bug that do 

not flare other pests provide the foundation for the overall cotton IPM program. Two insecticides 

have proven to be very important in this respect. Research throughout the Mid-South has shown 

that a single application of the insect growth regulator, novaluron, can provide long term benefits 

for tarnished plant bug management. However, novaluron does not control adult plant bugs and it 

consistently flares cotton aphids. As a result, sulfoxaflor is the ideal insecticide to use as one to 

two applications immediately following the novaluron application. Additionally, the registration 

of sulfoxaflor provided growers with a legitimate insecticide rotation strategy to make the 

tarnished plant bug IPM program successful. 

Twospotted Spider Mite

Spider Mites (0=None, 1=Low, 2=Spray, 3=Very High)

0

0.5

1

1.5

2

2.5

25-Jun 5-Jul 15-Jul 25-Jul 4-Aug 14-Aug 24-Aug 3-Sep

Neonics (1) No Neonics (2) Transform (0) Rating (0-3)

= Spray triggered for spider mite

Cotton Aphid

Cotton Aphid (0=None, 1=Low, 2=Spray, 3=Very High)

0

0.5

1

1.5

2

2.5

3

25-Jun 5-Jul 15-Jul 25-Jul 4-Aug 14-Aug 24-Aug 3-Sep

Neonics (1) No Neonics (1) Transform (0) Rating (0-3)

=Spray triggered for cotton aphid
The figures below (Figure 7) show insecticide rotation strategies recommended by the 

Mississippi State University Extension Service for managing tarnished plant bug in cotton. The 

graph on the left shows the rotation strategy with sulfoxaflor available to producers and the 

graph on the right is without sulfoxaflor. It is plain to see from these graphs, that when 

sulfoxaflor is not available, growers do not have enough insecticides available to provide a 

legitimate rotation strategy to effectively implement a realistic IPM program. Since its 

registration in 2013, sulfoxaflor has become the most important insecticide providing a 

foundation for the overall IPM program for tarnished plant bug and the loss of this insecticide 

will severely limit the success of integrated pest management for all arthropod pests of cotton in 

the Mid-South because it will result in increased use of broad spectrum insecticides.

Figure 7. Insecticide rotation strategies to manage tarnished plant bug when sulfoxaflor is 

available (left) and when it is not available (right).

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

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

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

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

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

insecticide applications, and greater economic returns compared to the standard approach (Fig. 

8).

Insecticide Application Windows Planting

1st Square

1st Flower Peak Flower Cutout

~May 1 ~June 1 ~July 1 ~July 21 ~Aug 25

Diamond

Transform “Best” Fit

Neonics

OP’s and Pyrethroids

Everything

Tarnished Plant Bug

Cotton Aphid

Insecticide Application Windows Planting

1st Square

1st Flower Peak Flower Cutout

~May 1 ~June 1 ~July 1 ~July 21 ~Aug 25

Neonics Diamond

OP’s and Pyrethroids

Everything

Tarnished Plant Bug

Cotton Aphid
Figure 8. Economic returns for a tarnished plant bug IPM program compared to a Standard 

approach in the Delta and Hills regions of Mississippi averaged across 2014 and 2015. The BMP 

treatments included sulfoxaflor as a foundation of the overall IPM program. It was occasionally 

used in the standard approach mainly to manage cotton aphid.

In general, tarnished plant bug management relies on an overall integrated pest management 

approach in the Mid-South to maintain economically sustainable cotton production. Insecticides 

remain the most important component of this IPM approach and sulfoxaflor rapidly became the 

most important insecticide because of its high level of efficacy against tarnished plant bug and its 

low likelihood of flaring other pests such as twospotted spider mite and cotton aphid. These 

characteristics have resulted in sulfoxaflor providing significant economic benefits in terms of 

improved yield protection and decreased number of insecticide applications (reported later in 

the document).

Additional Use and Efficacy Data

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 in 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. These research projects 

support a novel mode of action for sulfoxaflor including those insecticides with similar chemical 

structures (neonicotinoids). 

Integrated Pest Management for TPB

$1,005.18

$537.37

$0.00

$200.00

$400.00

$600.00

$800.00

$1,000.00

$1,200.00

Best Management Standard
Numerous field trials are highlighted below showing the impact of sulfoxaflor use in areas where 

high levels of resistance to pyrethroids and organophosphates are common. In the first example, 

Transform was used at two rates in a program approach and rotated with Orthene. These two 

treatments were compared to a standard insecticide rotation strategy that did not include 

Transform. The two treatments that included Transform at either 0.045 or 0.067 lbs ai/A 

provided significantly better control of tarnished plant bugs (Table 7). Additionally, yields were 

significantly higher for the Transform treatments compared to the standard program.

Table 7. Percent control and yields from a tarnished plant bug program trial conducted 

in Wayside, MS in 2010.

Treatment Seasonal Mean 

TPB 

Seasonal Mean 

TPB % Control

Lint Yield

Transform 0.045 lb fb 

Transform 0.045 lb fb 

Orthene 1 lb fb

Transform 0.045fb

Transform 0.045

46.8 c 84 a 1266 a

Transform 0.067 lb fb 

Transform 0.067 lb fb 

Orthene 1 lb fb

Transform 0.067 lb fb 

Transform 0.067

42.1 c 85 a 1267 a

Orthene 0.5 lb +

Diamond 9 oz fb

Bidrin 0.5 lb fb

Endigo 0.08 lb fb

Orthene 0.75 lb +

Karate 0.04 lb fb

Orthene 1.0 lb

128.3 b 56 b 1019 b

Untreated Check 292.3 a NA 664 c

1Means followed by the same letter are not significantly different (P<0.05).

In the second example, a single application of Transform was made and compared to Endigo, 

Orthene, and Bidrin (Table 8). Both rates of Transform provided significantly better control of 

tarnished plant bugs than the other treatments. Also, yields were significantly higher where a 

single application of Transform was used in an overall management program (Table 9).

Table 8. Percent control and yields from a tarnished plant bug trial following a single 

application in Wayside, MS in 2010.

Treatment Seasonal Mean 

TPB

Seasonal Mean 

TPB % Control

Lint Yield

Transform 0.045 lb 57.5 b 60 a 1158.4 a

Transform 0.067 lb 62.3 b 57 a 1065.4 a

Orthene 1 lb 104 37 b 895.6 bc

Endigo 0.08 102.6 38 b 849.3 bc

Bidrin 0.05 lb 142.9 0 b 787.5 c

Untreated 143 NA 772.1 c
Table 9. Impact of tarnished plant bug management in cotton with different classes of 

insecticides on cotton yields in 2009. These data show yields from an experiment in 

Stoneville, MS where two applications of the treatments were made in an overall tarnished 

plant bug management program.

Treatment Rate 

(lb 

ai/A)

Nymphs 

(Total 

No.)1

Nymphs

(Season 

Mean)1

Yield 

(lbs 

lint/A)1

Percent 

Yield2

Sulfoxaflor 0.045 27.3 c 5.45 c 872.7 a 100%

Acephate 1.0 49.5 b 9.90 b 675.6 b 77%

Centric 0.047 50.0 b 10.0 b 688.8 b 79%

Nontreated

--- 116.3 a 23.25 a 517.4 c 59%

1Means followed by the same letter are not significantly different (P<0.05).

2

The percent yield is calculated based on the highest yielding treatment (e.g. Acephate yielded 

23% lower than Sulfoxaflor).

Tables 10 and 11 show Transform compared to other registered products used for tarnished plant 

bug control. These trials were conducted in producer fields prior to any organophosphate 

applications and were crop destructed following treatment. Transform whether applied alone or 

mixed with a pyrethroid provided significantly better control than the alternatives in both years 

except for acephate in 2010.

Table 10. Standard efficacy test comparing Transform to standard insecticides in the 

Mississippi Delta in 2010.

Treatment Seasonal Mean 

TPB Adults and 

Nymphs

Transform 0.045 lb 

+ Bifenthrin 4.27 

oz

13.3 e

Transform 0.067 lb 14.0 de

Transform 0.067 lb 

+ Bifenthrin 4.27 

oz

16.8 de

Endigo 0.08 27.5 bc

Bidrin 0.05 lb 35.0 b

Orthene 1 lb 23.0 cd

Untreated 135.8 a

P = 0.0001
Table 11. Standard efficacy test comparing Transform to standard insecticides in the 

Mississippi Delta in 2009.

2009 Transform Efficacy Test 

Compared to Common Standards for 

Tarnished Plant Bug

Product Seasonal Mean 

TPB Adults and

Nymphs

Transform 0.067 lb 8.5 d

Orthene 1 lb 16.3 c

Bifenthrin 6.4 oz 20.3 c

Centric 2.5 oz 33.5 c

Bidrin 0.05 lb 35.0 b

Transform 0.067 lb 

+ Bifenthrin 6.4 oz

8.0 d

Untreated 82.0 a

P = 0.0001

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

used to manage tarnished plant bug on cotton. It has proven to 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. Sulfoxaflor has become the backbone of chemical 

control strategies for tarnished plant bug and is desperately needed in this emergency situation. 

Even in regions where resistance levels are not as high as the Mississippi Delta, sulfoxaflor has 

been widely adopted by producers because of safety to pollinators and other beneficial insects. 

This product has allowed growers to further implement IPM programs due to the safety profile. 

Additionally, since its use in 2012 in cotton there has not been a single incident reported with 

managed bees.

SECTION 166.20(a) 6: EXPECTED RESIDUE LEVELS IN FOOD

Acute Assessment

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

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

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

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

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

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

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

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

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

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

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

for surface water and 69.2 ppb for ground water. For the watercress scenario, the EDWCs for 
surface water are 91.3 ppb after one application, 182.5 ppb after two applications and 273.8 ppb 

after three applications. 

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

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

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

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

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

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

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

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

neurotoxicity. 

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

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

assessment. 

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

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

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

be established for meat, milk, poultry, and eggs.

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

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

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

1-2 years old and females 13-49 years old, the population groups receiving the greatest exposure.

Chronic Assessment

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

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

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

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

treated and average residue levels from field trials were used.

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

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

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

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

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

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

and was used to assess the chronic dietary exposure scenario.

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

small portion of the RfD (<0.001%) and therefore, should not cause any additional risk to 
humans via chronic dietary exposure. Consumption of sorghum by sensitive sub-populations 

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

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

insignificant.

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

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

estimates that are below levels of concern. 

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

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

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

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

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

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

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

dietary exposure has already been assessed, no further assessment of intermediate-term risk is 

necessary.

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

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

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

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

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

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

cancer risk is also below levels of concern.

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

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

request.

The content in the above Section 166.20(a)(6): “Expected Residues For Food Uses” was 

prepared by Michael Hare, Ph.D., Texas Department of Agriculture.

SECTION 166.20(a) 7: DISCUSSION OF RISK INFORMATION

Human Health Effects – Michael Hare, Ph.D.

Ecological Effects – David Villarreal, Ph.D.

Environmental Fate – David Villarreal, Ph.D.

Human Health

Toxicological Profile

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

nicotinic acetylcholine receptor (nAChR) in insects and, to a lesser degree, mammals. The 
nervous system and liver are the target organs, resulting in developmental toxicity and 

hepatotoxicity.

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

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

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

prevented normal breathing in neonates and increased mortality. The skeletal abnormalities 

occurred at high doses while decreased neonatal survival occurred at slightly lower levels.

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

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

studies compared to short-term studies.

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

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

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

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

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

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

are unlikely to be relevant to humans.

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

neurotoxicity study in rats. Decreased motor activity was also observed in the mid- and highdose groups. Since the neurotoxicity was observed only at a very high dose and many of the 

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

these effects are due to activation of the nAChR.

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

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

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

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

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

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

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

tumors were not treatment-related, and the preputial gland tumors only occurred at the high dose 

in one sex of one species, the evidence of carcinogenicity was weak. 

Ecological Toxicity

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

is a new variety of insecticide as a member of the sulfoxamine subclass of neonicotinoid 

insecticides. It is considered an agonist of the nicotinic acetylcholine receptor and exhibits 

excitatory responses including tremors, followed by paralysis and mortality in target insects. 

Sulfoxaflor consists of two diastereomers in a ratio of approximately 50:50 with each 

diastereomer consisting of two enantiomers. Sulfoxaflor is systemically distributed in plants 

when applied. The chemical acts through both contact action and ingestion and provides both 

rapid knockdown (symptoms are typically observed within 1-2 hours of application) and residual 
control (generally provides from 7 to 21 days of residual control). Incident reports submitted to 

EPA since approximately 1994 have been tracked via the Incident Data System. Over the 2012 

growing season, a Section 18 emergency use was granted for application of sulfoxaflor to cotton 

in four states (MS, LA, AR, TN). No incident reports have been received in association with the 

use of sulfoxaflor in this situation.

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

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

common carp). Mortality was 5% or less at the highest test treatments in each of these studies. 

Treatment-related sublethal effects included discoloration at the highest treatment concentration 

(100% of fish at 400 mg a.i./L for bluegill) and fish swimming on the bottom (1 fish at 400 mg 

a.i./L for rainbow trout). No other treatment-related sublethal effects were reported. For an 

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

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

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

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

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

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

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

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

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

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

and/or treatment-related effects were reported for hatching success, fry survival and mean 

weight.

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

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

EC50 is >400 mg a.i./L, the highest concentration tested. For Eastern oyster, new shell growth 

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

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

the most acutely sensitive invertebrate species tested with sulfoxaflor based on water column 

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

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

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

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

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

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

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

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

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

survival, growth or reproduction at the lower test concentrations. The 21-day NOAEC and 

LOAEC were determined to be 50 and 100 mg a.i./L, respectively.
The chronic effects of sulfoxaflor to mysid shrimp were determined in a flow-through system 

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

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

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

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

of 1.0 mg a.i./L within 7 days; no treatment-related effects on F0/F1 mortality, F0 reproduction 

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

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

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

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

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

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

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

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

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

sulfoxaflor is classified as practically nontoxic to birds, with 5-d LC50 values of >5620 mg/kgdiet for mallard ducks and bobwhite quail. The NOAEL from these studies is 5620 mg/kg-diet as 

no treatment related mortality of sublethal effects were observed at any treatment. Similarly, the 

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

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

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

mg/kg-diet (bobwhite quail, highest concentration tested). No treatment-related adverse effects 

were observed at any test treatment in these studies.

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

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

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

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

toxicity is consistent with the cyano-substituted neonicotinoids where similar cleavage of the 

cyanide group appears to eliminate their insecticidal activity. The acute oral toxicity of 

sulfoxaflor to adult bumble bees (Bombus terrestris) is similar to the honey bee; whereas its 

acute contact toxicity is about 20X less toxic for the bumble bee. Sulfoxaflor did not demonstrate 

substantial residual toxicity to honey bees exposed via treated and aged alfalfa (i.e., mortality 

was <15% at maximum application rates). 

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

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

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

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

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

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

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

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

maximum rate proposed in the US resulted in no discernible decline in mean colony strength by 
17 days after the first application. Longer-term results were not available from this study nor 

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

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

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

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

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

contact or pollen and nectar.

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

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

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

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

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

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

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

to terrestrial plants at or above its proposed maximum application rates. 

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

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

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

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

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

made before 7 am or after 7 pm or when the temperature is below 55◦F at the site of application.

Environmental Fate

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

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

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

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

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

Henry’s Law constant= 1.2 x 10-11 atm m3 mole-1, respectively at 25 °C). Partitioning coefficient 

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

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

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

not expected to partition into the sediment due to low Koc (7-74 mL/g).

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

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

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

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

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

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

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

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

88 days. Under anaerobic soil conditions, the parent compound was metabolized with half-lives 
of 113 to 120 days while under anaerobic aquatic conditions the chemical was more persistent 

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

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

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

formation of other minor degradates.

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

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

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

TX). The chemical can be characterized by very high to high mobility (Kfoc ranged from 11-72 

mL g-1). Rapid soil degradation is expected to limit chemical amounts that may potentially leach 

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

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

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

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

aquatic systems is expected to persist while that reaching the soil system is expected to degrade 

quickly with slight chance for it to run-off.

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

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

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

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

sulfoxaflor, that reaches the soil system, is expected to degrade.

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

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

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

organisms such as fish. Sulfoxaflor is resistant to hydrolysis and photolysis but transforms 

quickly in soils. In contrast, sulfoxaflor reaching aquatic systems by drift is expected to degrade 

rather slowly. Partitioning of sulfoxaflor to air is not expected to be important due to the low 

vapor pressure and Henry’s Law constant for sulfoxaflor. Exposure in surface water results from 

the drifted parent compound, and only minor amounts are expected to run-off only when rainfall 

and/or irrigation immediately follow application. The use of this insecticide is not expected to

adversely impact Louisiana ecosystems when used according to the Section 18 label. Of course, 

caution is needed to prevent exposure to water systems because of toxicity issues to aquatic 

invertebrates. As stated on the Section 3 label, this product should never be applied directly to 

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

Also, the label includes the statement “Do not contaminate water when disposing of equipment 

rinsate.”

Endangered and Threatened Species in Mississippi

No impacts are expected on endangered and threatened species by this very limited use of this 

insecticide as delineated in the Section 18 application. Sulfoxaflor demonstrates a very favorable 

ecotoxicity and fate profile as stated above and should not directly impact any protected 

mammal, fish, avian, or plant species. This product does adversely affect insects and aquatic 

invertebrates, especially bees, but the limited exposure to these species should not negatively 
affect endangered and threatened species in Mississippi when all applications label precautions 

are followed and preformed. 

The above content in Section 166.20(a)(7): Discussion of Risk Information was, for the most 

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

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

Department of Agriculture. The parts of the above content in this section, with references to 

Mississippi, were prepared by MDAC-BPI.

SECTION 166.20(a) 8: COORDINATION WITH OTHER AGENCIES IN MISSISSIPPI

The Mississippi Department of Wildlife, Fisheries, and Parks will be notified of this request. 

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

SECTION 166.20(a) 9: NOTIFICATION/SUPPORT OF REGISTRANT

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

offered a letter of support. They have also provided a copy of a label with the use directions for 

this use (although this use is dependent upon the approval of this section-18 by EPA).

SECTION 166.20(a) 10: ENFORCEMENT PROGRAM IN MISSISSIPPI

The Mississippi Department of Agriculture and Commerce (MDAC) has adequate authorities for 

enforcing provisions of Section 18 emergency exemptions. MDAC will require Dow 

AgroScience to prepare Section 18 labeling that complies with MDAC and EPA requirements 

for this emergency use, if approved, to ensure that product distributed for the exemption is 

properly labeled. 

SECTION 166.20(a) 11: REPEAT USES

This is the second time MDAC has applied for this specific exemption.

SECTION 166.20(b) 1: NAME OF THE PEST

Lygus lineolaris (Palisot de Beauvois), tarnished plant bug 

SECTION 166.20(b) 2: DISCUSSION OF EVENTS OR CIRCUMSTANCES WHICH 

BROUGHT ABOUT THE EMERGENCY SITUATION

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. 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) 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 and widespread reports of thiamethoxam crop failures were reported in 2015. 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 MidSouth fields has degraded to a point where the only option to reduce yield impacts is coapplication of products with different modes of action, since 2012 sulfoxaflor has filled this gap. 

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 resorting back to the disaster phase which would result in a collapse of 

the existing pest management system for Mid-South cotton and losing the IPM based approach to 

plant bug management that all regions of the state have come to rely on since 2012 when 

Transform was first introduced as a Section 18 and then with a full section 3 in 2013. As 

mentioned, there has not been a single documented case of bee loss in cotton with 4 years of use 

with sulfoxaflor in any region of Mississippi.

SECTION 166.20(b) 3: DISCUSSION OF ANTICIPATED RISKS TO ENDANGERED 

OR THREATENED SPECIES, BENEFICIAL ORGANISMS, OR THE ENVIRONMENT 

REMEDIED BY PROPOSED USE

As previously stated, it is not anticipated that there should be any anticipated risk to endangered 

or threated species, beneficial organisms, or the environment if all applications are made in 

accordance to the section 18 use directions. 

 See Attachment –2015 Mississippi Threatened and Endangered Species List
SECTION 166.20(b) 4: DISCUSSION OF SIGNIFICANT ECONOMIC LOSS

TIER 1 ANANLYSIS

Table 12. Tier one analysis of emergency situation (Pre Transform Use) compared to non-emergency 

(Post Transform Use) for tarnished plant bug (TPB) in cotton in Mississippi.

1

Source: http://www.nass.usda.gov/Statistics_by_State/Mississippi/

2

Source: http://entomology.msstate.edu/resources/cottoncrop.asp

Table 12 shows a comparison of yields from the emergency period (Pre Transform) and the nonemergency period (Post Transform) for the state of MS. Since the Transform became available it 

is clear that yields have increased (21%) and overall plant bug applications have decreased by 

13%. This information supports the criteria for emergency exemption under Tier 1 analysis for 

the state of MS.

Pre Transform Use In Mississippi Post Transform Use in Mississippi

Year Yield1Acres1TPB2

Sprays

Year Yield1Acres1TPB2

Sprays

2008 911 360000 4.9 2012 1014 470000 5

2009 672 295000 5.4 2013 1203 287000 5

2010 993 410000 5.4 2014 1232 420000 4

2011 952 605000 6 2015 1021 315000 4.9

Percent Change Pre and Post Transform Use 21% -11% -13%
TIER 2 ANANLYSIS

Table 13. Yields from emergency (Baseline, Pre Transform) and non-emergency (Post 

Transform) periods and associated increased control cost related to tarnished plant bug.

Price $0.62 

Yield/Acre

TPB 

Cost Revenue

Gross 

Revenue

Prior to Transform 

Availability 2008 911.00 $42.32 $564.82 $522.50

2009 672.00 $54.16 $416.64 $362.48

2010 993.00 $57.14 $615.66 $558.52

2011 952.00 $78.89 $590.24 $511.35

Avg 2008-09 882.00 $58.13 $546.84 $488.71

During Transform 

Availability 2012 1014.00 $64.61 $628.68 $564.07

2013 1203.00 $60.44 $745.86 $685.42

2014 1232.00 $42.11 $763.84 $721.73

2015 1021.00 $46.56 $633.02 $586.46

Avg 2012-15 1117.50 $53.43 $692.85 $639.42

Change 2012-15 235.50 -$4.70 $146.01 $150.71

% Change '08-'09 vs '12-'15 -21.1% 8.8% -21.1% -23.6%

1

Source: http://www.nass.usda.gov/Statistics_by_State/Mississippi/

2

Source: http://entomology.msstate.edu/resources/cottoncrop.asp

Table 13 shows percent yield loss for the state of MS from emergency period (Pre Transform 

2008-2011) to non-emergency (Post Transform, 2012-2015) period was reduced by 21.1%. 

Control cost per acre for tarnished plant bug increased decreased by 8.8% during period when 

Transform was used prior to when it was not. Overall loss of gross revenue between the 

emergency period and the non-emergency period is 23.6%. These data clearly demonstrate a loss 

greater than 20% gross revenue considering the emergency period (Pre Transform) and the nonemergency period (Post Transform) for the state of Mississippi. There is no doubt that the 

producers in the state of MS would be back in an emergency situation without this product in 

2016.

SUMMARY 

Sulfoxaflor (Transform) has been used by producers in Mississippi since 2012 in cotton for 

control of tarnished plant bugs. The above referenced information on the tier analysis required by 

EPA for emergency exemption clearly demonstrates that all criteria are met for both tier 1 and 

tier 2 analyses for sulfoxaflor in the state of MS. These data also demonstrate that since 

Transform has become available for use in cotton, MS producers have benefited greatly both in 

terms of gross revenue and increased yield protection, as well as reducing the overall number of 
tarnished plant bug applications. Furthermore, during the 4 year period that Transform has been 

used, there have been no reports of bee kills associated with this product. Additionally, many 

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

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

foundation products in our IPM cotton program. Furthermore, studies by Whalen et al. indicate 

that in mid-south agroecosystems cotton is not a preferred foraging host.

Attachments:

2016 Proposed Transform Section 18 Label

Dow Letter of Support for Transform emergency exemption 

Mississippi State University Extension letter of support for Transform emergency exemption

Mississippi Beekeepers Association letter of support for Transform emergency exemption

2015 Mississippi Threatened and Endangered Species List

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.

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. 

Kerns, D. L., B. J. Kesey, B. A. Baugh, and D. R. Patman. 2011. Evaluation of insecticides 

against cotton aphids and convergent lady beetle larvae in cotton, 2010. Arthropod Manag. Tests 

36:F44.

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, K. A. Fontenot, and B.R. Leonard. 2010. Summary of Insecticide Efficacy Trials for 

Control of Tarnished Plant Bugs in Louisiana Proc. Beltwide Cotton Conf. 817-819. 
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.

Whalen, A., A.L. Catchot, J. Gore, D. Cook, S. Stewart, and G. Lorenz. 2015. Populations of 

Foraging Honeybees in Mid-South Crops. Mid-South Entomologist. p. 53 v. 8. 

Williams, M. R. 2008. Cotton insect losses, pp. 927-929. 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).

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

toxicity and risk potential of 42 commonly used formulations of row crop pesticides to adult 

honey bees (Hymenoptera: Apidae). J. Econ. Entomol. 

108:2640-2647.
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

file: R396-082 Transform WG Sec 18 MS Cotton 22Feb16d.doc

Transform® WG

EPA Reg. No. 62719-XXX

Registration Notes:

Proposed Section 18.

This Section 18 labeling is provided in two components: (1) The base label and label booklet

containing all of the information needed to use this product, except crop-specific use directions; and (2)

crop-specific use directions which must be approved by EPA which allow use in a specific state.

Component (1) allows the product to be shipped to locations where it can be used in anticipation of EPAapproval of crop-specific use directions in component (2).

®

Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Base label):

Transform® WG

INSECTICIDE

For Control of Lygus Bugs in Cotton

ATTENTION

• Section 18 Specific Exemption

• For Distribution and Use Only in States with a Valid Section 18 Label

This product cannot be used without a valid state-specific Section 18 label which

must be in the possession of the user at the time of application.

Active Ingredient:

sulfoxaflor ........................................................ 50%

Other Ingredients ................................................... 50%

Total .................................................................... 100%

Contains 50% active ingredient on a weight basis.

Keep Out of Reach of Children

DANGER PELIGRO

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do

not understand the label, find someone to explain it to you in detail.)

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR

Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the Directions for Use

section for information about this standard.

Precautionary Statements

Hazard to Humans and Domestic Animals

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed

Do not get in eyes or on clothing.

Personal Protective Equipment (PPE)

Applicators and other handlers must wear:

• Long-sleeved shirt and long pants

• Shoes plus socks

• Protective eyewear

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this

product’s concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning/maintaining

PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE

separately from other laundry.

User Safety Recommendations

Users should:

• Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet.

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

clothing.

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As

soon as possible, wash thoroughly and change into clean clothing.

First Aid

If in eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact

lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or

doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip a

glass of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center

or doctor. Do not give anything by mouth to an unconscious person.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Have the product container or label with you when calling a poison control center or doctor, or going for

treatment. You may also contact 1-800-992-5994 for emergency medical treatment information.

Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are

still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following

application. Toxicity is reduced when spray droplets are dry.

Risk to managed bees and native pollinators from contact with pesticide spray or residues can be

minimized when applications are made before 7:00 am or after 7:00 pm local time or when the

temperature is below 55oF at the site of application.

Refer to the Directions for Use for crop specific restrictions and additional advisory statements to protect

pollinators.

Do not apply directly to water, to areas where surface water is present or to intertidal areas below the

mean high water mark. Do not contaminate water when disposing of equipment washwaters.

Storage and Disposal

Do not contaminate water, food, or feed by storage and disposal.

Pesticide Storage: Store in original container only.

Pesticide Disposal: Return any unopened, unused container of this unregistered product to the

manufacturer or distributor, or dispose of it in accordance with Resource Conservation and Recovery Act

regulations, following the expiration of the emergency exemption.

Container Handling: Nonrefillable container. Do not reuse or refill this container.

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows:

Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with

water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store

rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure

two more times. Pressure rinse as follows: Empty the remaining contents into application equipment or

a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later

use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at

least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available

or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by

state and local authorities.

Refer to label booklet for Directions for Use.

Notice: Read the entire label. Use only according to label directions. Before using this product, read

Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at end of label booklet. If

terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-992-5994.
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Est. _________

®

Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Produced for

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268

NET WEIGHT ____
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Cover, shipping container):

Transform® WG

INSECTICIDE

For Control of Lygus Bugs in Cotton

ATTENTION

• Section 18 Specific Exemption

• For Distribution and Use Only in States with a Valid Section 18 Label

This product cannot be used without a valid state-specific Section 18 label which

must be in the possession of the user at the time of application.

Active Ingredient:

sulfoxaflor ........................................................ 50%

Other Ingredients ................................................... 50%

Total .................................................................... 100%

Contains 50% active ingredient on a weight basis.

Keep Out of Reach of Children

DANGER PELIGRO

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do

not understand the label, find someone to explain it to you in detail.)

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR

Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the Directions for Use

section for information about this standard.

Refer to inside of label booklet for additional precautionary information including Directions for

Use.

Notice: Read the entire label. Use only according to label directions. Before using this product, read

Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at end of label booklet. If

terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-992-5994.

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Est. _________

®

Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Produced for

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268

NET WEIGHT ____
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

(Page 1 through end):

Precautionary Statements

Hazard to Humans and Domestic Animals

DANGER

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed

Do not get in eyes or on clothing.

Personal Protective Equipment (PPE)

Applicators and other handlers must wear:

• Long-sleeved shirt and long pants

• Shoes plus socks

• Protective eyewear

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this

product’s concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning/maintaining

PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE

separately from other laundry.

User Safety Recommendations

Users should:

• Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet.

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean

clothing.

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As

soon as possible, wash thoroughly and change into clean clothing.

First Aid

If in eyes: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact

lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or

doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip a

glass of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center

or doctor. Do not give anything by mouth to an unconscious person.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Have the product container or label with you when calling a poison control center or doctor, or going for

treatment. You may also contact 1-800-992-5994 for emergency medical treatment information.

Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are

still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following

application. Toxicity is reduced when spray droplets are dry.

Risk to managed bees and native pollinators from contact with pesticide spray or residues can be

minimized when applications are made before 7:00 am or after 7:00 pm local time or when the

temperature is below 55oF at the site of application.

Refer to the Directions for Use for crop specific restrictions and additional advisory statements to protect

pollinators.

Do not apply directly to water, to areas where surface water is present or to intertidal areas below the

mean high water mark. Do not contaminate water when disposing of equipment washwaters.
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Directions for Use

It is a violation of Federal law to use this product in a manner inconsistent with its labeling.

Read all Directions for Use carefully before applying.

Do not apply this product in a way that will contact workers or other persons, either directly or through

drift. Only protected handlers may be in the area during application. For any requirements specific to

your state or tribe, consult the agency responsible for pesticide regulation.

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR

Part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests,

nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training,

decontamination, notification, and emergency assistance. It also contains specific instructions and

exceptions pertaining to the statements on this label about personal protective equipment (PPE), and

restricted entry interval. The requirements in this box only apply to uses of this product that are covered

by the Worker Protection Standard.

Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 24 hours.

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and

that involves contact with anything that has been treated, such as plants, soil, or water, is:

• Coveralls

• Shoes plus socks

Storage and Disposal

Do not contaminate water, food or feed by storage and disposal.

Pesticide Storage: Store in original container only.

Pesticide Disposal: Return any unopened, unused container of this unregistered product to the

manufacturer or distributor, or dispose of it in accordance with Resource Conservation and Recovery Act

regulations, following the expiration of the emergency exemption.

Container Handling: Nonrefillable container. Do not reuse or refill this container.

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows:

Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with

water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store

rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure

two more times. Pressure rinse as follows: Empty the remaining contents into application equipment or

a mix tank. Hold container upside down over application equipment or mix tank or collect rinsate for later

use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at

least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available

or puncture and dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by

state and local authorities.

Product Information

Carefully read, understand and follow label use rates and restrictions. Apply the amount specified in the

following tables with properly calibrated aerial or ground spray equipment. Prepare only the amount of

spray solution required to treat the measured acreage. The low rates may be used for light infestations of

the target pests and the higher rates for moderate to heavy infestations. Transform® WG insecticide may

be applied in either dilute or concentrate sprays so long as the application equipment is calibrated and

adjusted to deliver thorough, uniform coverage. Use the specified amount of Transform WG per acre

regardless of the spray volume used.

Use Precautions

Integrated Pest Management (IPM) Programs

Transform WG is recommended for IPM programs in labeled crops. Apply Transform WG when field

scouting indicates target pest densities have reached the economic threshold, i.e., the point at which the

insect population must be reduced to avoid economic losses beyond the cost of control. Other than

reducing the target pest species as a food source, Transform WG does not have a significant impact on

most parasitic insects or the natural predaceous arthropod complex in treated crops, including big-eyed
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

bugs, ladybird beetles, flower bugs, lacewings, minute pirate bugs, damsel bugs, assassin bugs,

predatory mites or spiders. The feeding activities of these beneficials will aid in natural control of other

insects and reduce the likelihood of secondary pest outbreaks. If Transform WG is tank mixed with any

insecticide that reduces its selectivity in preserving beneficial predatory insects, the full benefit of

Transform WG in an IPM program may be reduced.

Insecticide Resistance Management (IRM)

Transform WG contains a Group 4C insecticide. Insect biotypes with acquired resistance to Group 4C

insecticides may eventually dominate the insect population if Group 4C insecticides are used repeatedly

in the same field or area, or in successive years as the primary method of control for targeted species.

This may result in partial or total loss of control of those species by Transform WG or other Group 4C

insecticides.

To delay development of insecticide resistance, the following practices are recommended:

• Avoid consecutive use of insecticides on succeeding generations with the same mode of action (same

insecticide subgroup, 4C) on the same insect species.

• Consider tank mixtures or premix products containing insecticides with different modes of action

(different insecticide groups) provided the products are registered for the intended use.

• Base insecticide use upon comprehensive IPM programs.

• Monitor treated insect populations in the field for loss of effectiveness.

• Do not treat seedling plants grown for transplant in greenhouses, shade houses, or field plots.

• Contact your local extension specialist, certified crop advisor, and/or manufacturer for insecticide

resistance management and/or IPM recommendations for the specific site and resistant pest problems.

• For further information or to report suspected resistance, you may contact Dow AgroSciences by calling

800-258-3033.

Mixing Directions

Application Rate Reference Table

Application Rate of

Transform WG

(oz/acre)

Active Ingredient

Equivalent

(lb ai/acre)

0.75 0.023

1.5 0.047

2.25 0.071

Transform WG – Alone

Fill the spray tank with water to about 1/2 of the required spray volume. Start agitation and add the

required amount of Transform WG. Continue agitation while mixing and filling the spray tank to the

required spray volume. Maintain sufficient agitation during application to ensure uniformity of the spray

mix. Do not allow water or spray mixture to back-siphon into the water source.

Transform WG - Tank Mix

When tank mixing Transform WG with other materials, conduct a compatibility test (jar test) using relative

proportions of the tank mix ingredients prior to mixing ingredients in the spray tank. If foliar fertilizers are

used, the jar test should be repeated with each batch of fertilizer utilizing the mixing water source.

Vigorous, continuous agitation during mixing, filling and throughout application is required for all tank

mixes. Sparger pipe agitators generally provide the most effective agitation in spray tanks. To prevent

foaming in the spray tank, avoid stirring or splashing air into the spray mixture.

Mixing Order for Tank Mixes: Fill the spray tank with water to 1/4 to 1/3 of the required spray volume.

Start agitation. Add different formulation types in the order indicated below, allowing time for complete

dispersion and mixing after addition of each product. Allow extra dispersion and mixing time for dry

flowable products.

Add different formulation types in the following order:

1. Transform WG and other water dispersible granules

2. Wettable powders

3. Suspension concentrates and other liquids
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Maintain agitation and fill spray tank to 3/4 of total spray volume. Then add:

4. Emulsifiable concentrates and water-based solutions

5. Spray adjuvants, surfactants and oils

6. Foliar fertilizers

Finish filling the spray tank. Maintain continuous agitation during mixing, final filling and throughout

application. If spraying and agitation must be stopped before the spray tank is empty, the materials may

settle to the bottom. Settled materials must be resuspended before spraying is resumed. A sparger

agitator is particularly useful for this purpose.

Premixing: Dry and flowable formulations may be premixed with water (slurried) and added to the spray

tank through a 20 to 35 mesh screen. This procedure assures good initial dispersion of these formulation

types.

Application Directions

Proper application techniques help ensure thorough spray coverage and correct dosage for optimum

insect control. Apply Transform WG as a foliar spray at the rate indicated for target pest. The following

directions are provided for ground and aerial application of Transform WG. Attention should be given to

sprayer speed and calibration, wind speed, and foliar canopy to ensure adequate spray coverage.

Spray Drift Management

Wind: To reduce off-target drift and achieve maximum performance, apply when wind velocity favors ontarget product deposition.

Temperature Inversions: Do not make ground or aerial applications during a temperature inversion.

Temperature inversions are characterized by stable air and increasing temperatures with height above

the ground. Mist or fog may indicate the presence of an inversion in humid areas. The applicator may

detect the presence of an inversion by producing smoke and observing a smoke layer near the ground

surface.

Droplet Size: Use only medium or coarser spray nozzles (for ground and non-ULV aerial application)

according to ASABE (S-572.1) definition for standard nozzles. In conditions of low humidity and high

temperatures, applicators should use a coarser droplet size except where indicated for specific crops.

Ground Application

To prevent drift from groundboom applications, apply using a nozzle height of no more than 4 feet above

the ground or crop canopy. Shut off the sprayer when turning at row ends. Risk of exposure to sensitive

aquatic areas can be reduced by avoiding applications when wind directions are toward the aquatic area.

Row Crop Application

Use calibrated power-operated ground spray equipment capable of providing uniform coverage of the

target crop. Orient the boom and nozzles to obtain uniform crop coverage. Use a minimum of 5 to 10

gallons per acre, increasing volume with crop size and/or pest pressure. Use hollow cone, twin jet flat fan

nozzles or other atomizer suitable for insecticide spraying to provide a fine to coarse spray quality (per

ASABE S-572.1, see nozzle catalogs). Under certain conditions, drop nozzles may be required to obtain

complete coverage of plant surfaces. Follow manufacturer's specifications for ideal nozzle spacing and

spray pressure. Minimize boom height to optimize uniformity of coverage and maximize deposition

(optimize on-target deposition) to reduce drift.

Aerial Application

Apply in a minimum spray volume of 3 gallons per acre. Mount the spray boom on the aircraft so as to

minimize drift caused by wing tip or rotor vortices. Use the minimum practical boom length and do not

exceed 75% of the wing span or 80% of the rotor diameter. Flight speed and nozzle orientation must be

considered in determining droplet size. Spray must be released at the lowest height consistent with pest

control and flight safety. Do not release spray at a height greater than 10 feet above the crop canopy

unless a greater height is required for aircraft safety. When applications are made with a crosswind, the

swath will be displaced downwind. The applicator must compensate for this displacement at the

downwind edge of the application area by adjusting the path of the aircraft upwind.
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Spray Adjuvants

The addition of agricultural adjuvants to sprays of Transform WG may improve initial spray deposits,

redistribution and weatherability. Select adjuvants that are recommended and registered for your specific

use pattern and follow their use directions. When an adjuvant is to be used with this product, Dow

AgroSciences recommends the use of a Chemical Producers and Distributors Association certified

adjuvant. Always add adjuvants last in the mixing process.

Rotational Crop Restrictions

The following rotational crops may be planted at intervals defined below following the final application of

Transform WG at specified rates for a registered use.

Crop Re-Planting Interval

cotton no restrictions

all other food and feed crops 360 days

Application Rates

Refer to state-specific Section 18 label for approved uses, application timing and

restrictions.

This product cannot be used without a valid state-specific Section 18 label. The

label must be in the possession of the user at the time of application. The

Section 18 label can be obtained from state and/or county authorities where it is

valid. Please contact your Dow AgroSciences representative for further

information.

Terms and Conditions of Use

If terms of the following Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies are not

acceptable, return unopened package at once to the seller for a full refund of purchase price paid.

Otherwise, use by the buyer or any other user constitutes acceptance of the terms under Warranty

Disclaimer, Inherent Risks of Use and Limitation of Remedies.

Warranty Disclaimer

Dow AgroSciences warrants that this product conforms to the chemical description on the label and is

reasonably fit for the purposes stated on the label when used in strict accordance with the directions,

subject to the inherent risks set forth below. Dow AgroSciences MAKES NO OTHER EXPRESS OR

IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR

ANY OTHER EXPRESS OR IMPLIED WARRANTY.

Inherent Risks of Use

It is impossible to eliminate all risks associated with use of this product. Plant injury, lack of performance,

or other unintended consequences may result because of such factors as use of the product contrary to

label instructions (including conditions noted on the label, such as unfavorable temperature, soil

conditions, etc.), abnormal conditions (such as excessive rainfall, drought, tornadoes, hurricanes),

presence of other materials, the manner of application, or other factors, all of which are beyond the

control of Dow AgroSciences or the seller. All such risks shall be assumed by buyer.

Limitation of Remedies

To the extent permitted by law, the exclusive remedy for losses or damages resulting from this product

(including claims based on contract, negligence, strict liability, or other legal theories), shall be limited to,

at Dow AgroSciences' election, one of the following:

1. Refund of purchase price paid by buyer or user for product bought, or

2. Replacement of amount of product used
C1C / Transform WG / Sec 18 MS Cotton / 02-22-16

Dow AgroSciences shall not be liable for losses or damages resulting from handling or use of this product

unless Dow AgroSciences is promptly notified of such loss or damage in writing. In no case shall Dow

AgroSciences be liable for consequential or incidental damages or losses.

The terms of the Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies cannot be

varied by any written or verbal statements or agreements. No employee or sales agent of Dow

AgroSciences or the seller is authorized to vary or exceed the terms of the Warranty Disclaimer or

Limitation of Remedies in any manner.

®

Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

Accepted __/__/__
Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268-1054 USA

Transform® WG

EPA Reg. No. 62719-625

For Control of Lygus Bugs in Cotton

Section 18 Emergency Exemption

File symbol: XXXXXX

FOR DISTRIBUTION AND USE ONLY IN MISSISSIPPI UNDER SECTION 18 EMERGENCY

EXEMPTION

This Section 18 Emergency Exemption is effective XXXXX and expires XXXXXXX.

• This labeling must be in the possession of the user at the time of application.

• It is in violation of federal law to use this product in a manner inconsistent with its labeling.

• All application directions, restrictions, and precautions on the registered product label for Transform WG

(EPA Reg. No. 62719-625) are to be followed.

• Any adverse effects resulting from the use of Transform WG under this emergency exemption must be

immediately reported to the Mississippi Department of Agriculture and Commerce.

Directions for Use

Pests and Application Rates:

Pests

Transform

WG

(oz/acre)

tarnished plant bug 1.5 – 2.25

(0.047 – 0.071

lb ai/acre)

Advisory Pollinator Statement: Notifying known beekeepers within 1 mile of the treatment area 48

hours before the product is applied will allow them to take additional steps to protect bees. If known

apiaries are within one mile of cotton fields intended for treatment, applications should be made within

three hours of sunset during the flowering period. Prior to use of Transform WG, growers and the

beekeepers hosted on their farm are advised to implement cooperative standards outlined in the

Mississippi Honeybee Stewardship Program.

Application Timing: Treat in accordance with local economic thresholds. Consult your Dow

AgroSciences representative, cooperative extension service, certified crop advisor or state agricultural

experiment station for any additional local use recommendations for your area.

Application Rate: Use a higher rate in the rate range for heavy pest populations. Two applications may

be required for optimum tarnished plant bug control under high pest pressure or heavy immigration of

plant bugs from other crops.

Restrictions:

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

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

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

• 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.

Environmental Hazards

This product is highly toxic to bees exposed through contact during spraying and while spray droplets are

still wet. This product may be toxic to bees exposed to treated foliage for up to 3 hours following

application. Toxicity is reduced when spray droplets are dry.
Risk to managed bees and native pollinators from contact with pesticide spray or residues can be

minimized when applications are made before 7:00 am or after 7:00 pm local time or when the

temperature is below 55° F at the site of application.

Do not apply directly to water, to areas where surface water is present or to intertidal areas below the

mean high water mark. Do not contaminate water when disposing of equipment washwaters.

®TMTrademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow

R396-082

Approved: __/__/__

Initial printing

February 22, 2016

To whom it may concern:

The purpose of this letter is to request an emergency exemption (Section 18) for the use 

of sulfoxaflor (Transform WGTM, Dow AgroSciences) to manage tarnished plant bug, 

Lygus lineolaris, in cotton. Cotton producers throughout Mississippi have successfully 

used sulfoxaflor since 2012 to manage tarnished plant bugs. Since its introduction, 

Transform has reduced overall tarnished plant bug applications, and provided significant 

yield increases and returns in gross revenues. Over the last four years, sulfoxaflor has 

replaced more toxic insecticides including pyrethroids, organophosphates, and 

neonicotinoids. Because of its high level of efficacy, relative safety to beneficial 

arthropods and pollinators, and protection of cotton yields, Transform has become the 

foundation of the insecticide component of Mississippi’s overall IPM program. Since the 

initial Section 3 registration in 2013, Transform has been used on more than three million 

acres across the mid-south region with zero reported incidents of adverse effects on bees 

or other pollinators. Despite the higher cost of Transform relative to other products used 

for tarnished plant bug control, cotton growers and consultants have incorporated 

Transform into their overall insect management programs. This demonstrates their 

commitment to selecting safe alternatives to more toxic insecticides as long as they do 

not sacrifice yields. 

Cotton growers, beekeepers, and other stakeholders in the state of Mississippi 

demonstrated their commitment to the protection of managed honey bees with their 

adoption of the Mississippi Honey Bee Stewardship Program. Since the introduction of 

this program, the level of cooperation and communication between beekeepers and 

farmers has been unprecedented. In particular, the vast majority of growers in Mississippi 

have bought into this program and view beekeepers as fellow farmers. As a result, they 

have shown real concern about the livelihood of beekeepers they host on their farms. The 

recent cancellation of the Transform registration as a result of the actions of the Pollinator 

Stewardship Council has severely damaged the relationships between many farmers and 

beekeepers. I have already heard of beekeepers being demanded to remove their bees 

from some farms throughout the state. If Transform is not available to growers 

throughout Mississippi in 2016, it will set the relationships between farmers and 

beekeepers back to before the adoption of the Mississippi Honeybee Stewardship 

Program. In fact, those relationships will be more strained than it was before the program.
Finally, Transform has become the foundation of our integrated pest management 

program for cotton in Mississippi. It provides a high level of efficacy and yield protection 

from tarnished plant bug and cotton aphid, preserves beneficial insect populations, and 

more importantly replaces more toxic insecticides. Because of these attributes, Transform 

rapidly became the foundation of our cotton integrated pest management program for 

tarnished plant bug. The recent cancellation of Transform has been damaging to our 

overall IPM program and to the relationships between beekeepers and farmers in all 

regions of Mississippi.

Thank you.

Sincerely,

Angus Catchot, Extension Entomologist-MSU-ES
Representing beekeepers across Mississippi

Mississippi Beekeepers Association

214 Shadow Wood Dr

Clinton, MS 39056

601-924-2582

22 February 2016

To Whom It May Concern:

 The Executive Board of the Mississippi Beekeepers Association (MBA) met on 18 February 2016 to address some 

concerns and issues that have arisen with relationships between Mississippi beekeepers and Mississippi row crop 

producers. This letter is supported by the Executive Board of MBA. As an organization made up of commercial, sideline, 

and hobby beekeepers, we recognize the important and mutually beneficial relationship between beekeepers and row crop 

farmers in Mississippi. This was clearly demonstrated in the development of the Mississippi Honeybee Stewardship 

Program that brought together famers and beekeepers to work on cooperative standards between both groups. 

The request from the MBA Board with regards to the Transform® WG, sulfoxaflor, “Section 18” Emergency 

Exemption application is as follows:

The Mississippi Beekeepers Association would like to express our support for the cotton and grain 

sorghum (milo) farmers of Mississippi to be able to use Transform® WG, sulfoxaflor, for the control of 

tarnished plant bugs, Lygus lineolaris, in Mississippi cotton and sugarcane aphids, Melanaphis sacchari,

in Mississippi grain sorghum. We understand that a “Section 18” Emergency Exemption is being 

requested for the control of these pests in Mississippi. The Board supports the use of Transform® WG on 

grain sorghum and cotton, but we would like to request during plant bloom (flowering) that if a known

apiary (bee yard of managed honey bee colonies) is within one (1) mile of the site of treatment that 

application occur within three (3) hours of sunset. 

Recently, there has been considerable press and media coverage on the decline of the honeybee populations 

worldwide. There are numerous factors that affect colony health and overwintering losses of honeybees. It has been 

clearly documented that honeybee losses are due to a variety of factors including Varroa mites, pesticide exposure, habitat 

loss, viral diseases, nutrition inadequacies, etc. These stressors may be acting alone or in combination thereof.

As beekeepers in the state of Mississippi, we are fully aware of the risk taken when we place our hives on

or in the vicinity of row crop farms. We rely annually on planted and farmed crops such as soybeans and cotton to provide 

pollen and nectar for our bees despite the fact that cotton, corn, soybeans, grain sorghum, wheat, rice, and peanuts makeup greater than 99% of all row crops in the Mid-South region. These cultivated crops do not require bee pollination to 

produce, but some do benefit to varying degrees from bee pollination, depending the crop and varieties planted.

Many Mississippi beekeepers have worked diligently to maintain their relationships with the row crop producers 

of Mississippi. Recent lawsuits, launched by non-governmental organizations (NGOs), along with media coverage, have 

given the impression that beekeepers, in general, are against the use of “all” pesticides. This misrepresentation has caused 

tension on relationships that we have developed over many years, and in several cases, generations of beekeepers and row 

crop producers. Beekeepers have appreciated the relationships with their host farmers in the past, and this is now in 

danger. We want to remain profitable, we want row crop producers to be profitable, and we realize that pesticide 

applications will be necessary in many cases, including on those crops attractive to honey bees. We recognize that just as 

growers in the Mid-South region routinely experience high levels of pest pressure and need products such as Transform®

WG to remain profitable, we need our bees foraging on their crops for us (beekeepers) to remain profitable. Furthermore, 

we find that most farmers appreciate our bees foraging their crops and do appreciate the relationship formed between 

them and beekeepers. Moreover, most farmers realize a need for our partnership for us (beekeepers) to remain profitable.

In conclusion, we would ask that EPA grant Mississippi row crop producers the “Section 18” Emergency 

Exemption to use Transform® WG in 2016 for control of tarnished plant bugs in cotton and sugarcane aphids in grain 

sorghum. Again, we would also request that if managed bees are within one (1) mile of the treated area that applicators

make applications within three (3) hours of sunset if flowering is occurring in cotton.

Sincerely,

Austin C. Smith

MBA President
1

MISSISSIPPI

List of Federally Threatened and Endangered Species by County 

Codes: E = Endangered C = Candidate

CH = Critical Habitat P = Proposed

T = Threatened 

 November 2015

The following list contains species that are known to occur in Mississippi. It includes historic range 

information, known species locations, as well as the “Section 7 range” or “Area of Influence” of a species 

population which identifies the area within which, if an action is proposed, potential effects to this species 

should be considered.

NOTE:The brown pelican (Pelecanus occidentalis) was delisted in 2009 but the pelican is still protected by 

the Migratory Bird Treaty Act. The American bald eagle (Haliaeetus leucocephalus) was delisted in 2007 but 

nesting eagles and their nest trees are still protected under the Bald and Golden Eagle Protection Act.

Statewide T Wood Stork Mycteria americana

Adams E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

Alcorn E Indiana bat Myotis sodalis

E Mitchell’s satyr butterfly Neonympha mitchellii mitchellii

T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

PT White fringeless orchid Platanthera integrilabia

Amite T Louisiana black bear Ursus americanus luteolus

E Red-cockaded woodpecker Picoides borealis

Attala T Northern long-eared bat Myotis septentrionalis

Benton E Indiana bat Myotis sodalis

T Northern long-eared bat Myotis septentrionalis

Bolivar E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum 

T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Calhoun T Northern long-eared bat Myotis septentrionalis

Carroll T Louisiana black bear Ursus americanus luteolus

 T Northern long-eared bat Myotis septentrionalis
2

Chickasaw T Northern long-eared bat Myotis septentrionalis

 T Price’s potato bean Apios priceana 

Choctaw T Northern long-eared bat Myotis septentrionalis

Claiborne T Bayou darter Etheostoma rubrum

E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum 

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

T Rabbitsfoot mussel Quadrula cylindrica cylindrica

Clarke T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (Pascagoula River System)

T Yellow-blotched map turtle Graptemys flavimaculata

Clay T Northern long-eared bat Myotis septentrionalis

 T Price’s potato bean Apios priceana

Coahoma E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Copiah T Bayou darter Etheostoma rubrum

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

C Pearl darter Percina aurora (Pearl River System)

E Red-cockaded woodpecker Picoides borealis

T Ringed map turtle Graptemys oculifera

Covington T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

C Pearl darter Percina aurora (Pascagoula River System)

T Yellow-blotched map turtle Graptemys flavimaculata

DeSoto E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

Forrest T/PCH Black pinesnake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis

T Yellow-blotched map turtle Graptemys flavimaculata
3

Franklin T Louisiana black bear Ursus americanus luteolus

E Red-cockaded woodpecker Picoides borealis

George T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis 

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis

T Yellow-blotched map turtle Graptemys flavimaculata

Greene T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis 

T Yellow-blotched map turtle Graptemys flavimaculata

Grenada T Northern long-eared bat Myotis septentrionalis

Hancock T Gopher tortoise Gopherus polyphemus

T Green sea turtle Chelonia mydas

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Inflated heelsplitter mussel Potamilus inflatus

E Kemp’s ridley sea turtle Lepidochelys kempii

E Leatherback sea turtle Dermochelys coriacea

T Loggerhead sea turtle Caretta caretta

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pearl River System)

TCH Piping plover Charadrius melodus

T Red knot Calidris canutus rufa

T Ringed map turtle Graptemys oculifera

E West Indian manatee Trichechus manatus

Harrison E Alabama red-bellied turtle Pseudemys alabamensis

T/PCH Black pinesnake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

T Green sea turtle Chelonia mydas

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

E Kemp’s ridley sea turtle Lepidochelys kempii

E Leatherback sea turtle Dermochelys coriacea

T Loggerhead sea turtle Caretta caretta

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

TCH Piping plover Charadrius melodus

T/PCH Red knot Calidris canutus rufa

E Red-cockaded woodpecker Picoides borealis

E West Indian manatee Trichechus manatus
4

Hinds T Bayou darter Etheostoma rubrum

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

T/CH Rabbitsfoot mussel Quadrula cylindrica cylindrica

T Ringed map turtle Graptemys oculifera

Holmes T Louisiana black bear Ursus americanus luteolus 

T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Humphreys T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Issaquena E Fat pocketbook mussel Potamilus capax 

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Itawamba TCH Alabama moccasinshell Medionidus acutissimus

ECH Black clubshell mussel Pleurobema curtum

ECH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

E Mitchell’s satyr butterfly Neonympha mitchellii mitchellii

T Northern long-eared bat Myotis septentrionalis

TCH Orange-nacre mucket Lampsilis perovalis

ECH Ovate clubshell mussel Pleurobema perovatum

ECH Southern clubshell mussel Pleurobema decisum

ECH Southern combshell mussel Epioblasma penita

PT White fringeless orchid Platanthera integrilabia

Jackson E Alabama red-bellied turtle Pseudemys alabamensis

T Black pinesnake Pituophis melanoleucus lodingi 

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

T Green sea turtle Chelonia mydas

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

E Kemp’s ridley sea turtle Lepidochelys kempii

E Leatherback sea turtle Dermochelys coriacea

 TCH Loggerhead sea turtle Caretta caretta

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

ECH Mississippi sandhill crane Grus canadensis pulla

C Pearl darter Percina aurora (Pascagoula River System)

TCH Piping plover Charadrius melodus

T Red knot Calidris canutus rufa

E Red-cockaded woodpecker Picoides borealis

E West Indian manatee Trichechus manatus

T Yellow-blotched map turtle Graptemys flavimaculata
5

Jasper T Gopher tortoise Gopherus polyphemus

E Red-cockaded woodpecker Picoides borealis

Jefferson E Fat pocketbook mussel Potamilus capax 

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

E Red-cockaded woodpecker Picoides borealis

Jefferson Davis T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

Jones T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus 

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis

T Yellow-blotched map turtle Graptemys flavimaculata

Kemper T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

Lafayette T Northern long-eared bat Myotis septentrionalis

Lamar T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

T Louisiana black bear Ursus americanus luteolus

E Red-cockaded woodpecker Picoides borealis

Lauderdale T Northern long-eared bat Myotis septentrionalis

Lawrence T Black pinesnake Pituophis melanoleucus lodingi

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Leake T Northern long-eared bat Myotis septentrionalis

C Pearl darter Percina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Lee T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

Leflore T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Lincoln T Bayou darter Etheostoma rubrum

T Louisiana black bear Ursus americanus luteolus 

E Red-cockaded woodpecker Picoides borealis
6

Lowndes TCH Alabama moccasinshell Medionidus acutissimus

ECH Black clubshell mussel Pleurobema curtum

ECH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

 T Northern long-eared bat Myotis septentrionalis

TCH Orange-nacre mucket Lampsilis perovalis

ECH Ovate clubshell mussel Pleurobema perovatum

T Price’s potato bean Apios priceana

ECH Southern clubshell mussel Pleurobema decisum

ECH Southern combshell mussel Pleurobema penita

Madison T Northern long-eared bat Myotis septentrionalis

T Rabbitsfoot mussel Quadrula cylindrica cylindrica

 T Ringed map turtle Graptemys oculifera

Marion T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

C Pearl darter Percina aurora (Pearl River System)

T Ringed map turtle Graptemys oculifera

Marshall E Indiana bat Myotis sodalis

T Northern long-eared bat Myotis septentrionalis

Monroe TCH Alabama moccasinshell Medionidus acutissimus

ECH Black clubshell mussel Pleurobema curtum

ECH Heavy pigtoe mussel Pleurobema taitianum

T Inflated heelsplitter mussel Potamilus inflatus

E Mitchell’s satyr butterfly Neonympha mitchellii mitchellii

T Northern long-eared bat Myotis septentrionalis

TCH Orange-nacre mucket Lampsilis perovalis

ECH Ovate clubshell mussel Pleurobema perovatum

T Price’s potato bean Apios priceana

ECH Southern clubshell mussel Pleurobema decisum

ECH Southern combshell mussel Epioblasma penita

 PT White fringeless orchid Platanthera integrilabia

Montgomery T Northern long-eared bat Myotis septentrionalis

Neshoba T Northern long-eared bat Myotis septentrionalis

T Ringed map turtle Graptemys oculifera

Newton T Northern long-eared bat Myotis septentrionalis

E Red-cockaded woodpecker Picoides borealis 

Noxubee T Alabama moccasinshell Medionidus acutissimus

T Inflated heelsplitter mussel Potamilus inflatus

T Northern long-eared bat Myotis septentrionalis

T Orange-nacre mucket mussel Lampsilis perovalis

T Price’s potato bean Apios priceana

E Red-cockaded woodpecker Picoides borealis

E Southern clubshell mussel Pleurobema decisum
7

Oktibbeha T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

E Red-cockaded woodpecker Picoides borealis

Panola T Northern long-eared bat Myotis septentrionalis

Pearl River T Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Inflated heelsplitter mussel Potamilus inflatus

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pearl River System)

E Red-cockaded woodpecker Picoides borealis 

T Ringed map turtle Graptemys oculifera

Perry T/PCH Black pinesnake Pituophis melanoleucus lodingi

ECH Dusky gopher frog Rana sevosa

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis 

T Yellow-blotched map turtle Graptemys favimaculata

Pike TCH Gulf sturgeon Acipenser oxyrinchus desotoi

 T Louisiana black bear Ursus americanus luteolus

 T Ringed map turtle Graptemys oculifera

Pontotoc T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

Prentiss E Indiana bat Myotis sodalis

E Mitchell’s satyr butterfly Neonympha mitchellii mitchellii

T Northern long-eared bat Myotis septentrionalis

T Price’s potato bean Apios priceana

 PT White fringeless orchid Platanthera integrilabia

Quitman T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Rankin TCH Gulf sturgeon Acipenser oxyrinchus desotoi

 T Northern long-eared bat Myotis septentrionalis

 T Ringed map turtle Graptemys oculifera

Scott T Northern long-eared bat Myotis septentrionalis

C Pearl darter Percina aurora (Pearl River System)

E Red-cockaded woodpecker Picoides borealis

T Ringed map turtle Graptemys oculifera
8

Sharkey T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Simpson TCH Gulf sturgeon Acipenser oxyrinchus desotoi

C Pearl darter Percina aurora (Pearl River System)

 T Ringed map turtle Graptemys oculifera

Smith T Gopher tortoise Gopherus polyphemus

E Red-cockaded woodpecker Picoides borealis

 T Yellow-blotched map turtle Graptemys flavimaculata

Stone T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

E Red-cockaded woodpecker Picoides borealis

Sunflower T Louisiana black bear Ursus americanus luteolus

T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

TCH Rabbitsfoot mussel Quadrula cylindrica cylindrica

E Sheepnose mussel Plethobasus cyphyus

Tallahatchie T Northern long-eared bat Myotis septentrionalis

E Pondberry Lindera melissifolia

Tate T Northern long-eared bat Myotis septentrionalis

Tippah E Indiana bat Myotis sodalis

T Northern long-eared bat Myotis septentrionalis

Tishomingo ECH Cumberlandian combshell Epioblasma brevidens

E Gray bat Myotis grisescens

E Indiana bat Myotis sodalis

E Mitchell’s satyr butterfly Neonympha mitchellii mitchellii

T Northern long-eared bat Myotis septentrionalis

TCH Rabbitsfoot mussel Quadrula cylindrica cylindrica

 ECH Slabside pearlymussel Lexingonia dolabelloides

 T Snail darter Percina tanasi

 E Snuffbox mussel Epioblasma triquetra

 PT White fringeless orchid Platanthera integrilabia

Tunica E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

Union T Northern long-eared bat Myotis septentrionalis

 T Price’s potato bean Apios priceana
9

Walthall T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

Warren E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

 T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

TCH Rabbitsfoot mussel Quadrula cylindrica cylindrica

Washington E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

 T Northern long-eared bat Myotis septentrionalis

E Pallid sturgeon Scaphirhynchus albus

E Pondberry Lindera melissifolia

E Sheepnose mussel Plethobasus cyphyus

Wayne T/PCH Black pinesnake Pituophis melanoleucus lodingi

T Gopher tortoise Gopherus polyphemus

TCH Gulf sturgeon Acipenser oxyrinchus desotoi

T Louisiana black bear Ursus americanus luteolus

E Louisiana quillwort Isoetes louisianensis

C Pearl darter Percina aurora (Pascagoula River System)

E Red-cockaded woodpecker Picoides borealis 

T Yellow-blotched map turtle Graptemys flavimaculata

Webster T Northern long-eared bat Myotis septentrionalis

Wilkinson E Fat pocketbook mussel Potamilus capax

E Least tern (interior) Sterna antillarum

T Louisiana black bear Ursus americanus luteolus

E Pallid sturgeon Scaphirhynchus albus

E Red-cockaded woodpecker Picoides borealis

Winston T Northern long-eared bat Myotis septentrionalis

E Red-cockaded woodpecker Picoides borealis 

Yalobusha T Northern long-eared bat Myotis septentrionalis

Yazoo T Louisiana black bear Ursus americanus luteolus

 T Northern long-eared bat Myotis septentrionalis

 E Pondberry Lindera melissifolia

T Rabbitsfoot mussel Quadrula cylindrica cylindrical

END