EnlistTM Weed Control System 

TMColex-D, and Enlist are trademarks of Dow AgroSciences LLC. Components of the 

Enlist Weed Control System have not yet received regulatory approvals; approvals are 

pending. The information presented here is not an offer for sale. Enlist Duo is not yet registered for 

sale or use as a component of the Enlist Weed Control System. Always read and follow label 

directions.
Terminology

• Enlist Weed Control System

– Enlist trait in corn (aad-1)

– Enlist Duo Herbicide

• Lead commercial offering – 2,4-D choline + 

Glyphosate DMA

• Event – DAS-40278-9

• Gene – aad-1

• Protein – AAD-1
Overview

• Herbicide Tolerant Crops

• Glyphosate resistant weeds

• Resistance management

• AAD-1

• Current and future use of 2,4-D herbicide in corn

• Colex-D Herbicide Technology

• Herbicide Drift and Volatility
Glyphosate tolerant crop adoption
Heavy weed pressure on a single 

herbicide molecule

• Result

– A quadrupling of the amount of 

glyphosate use in corn, soybeans 

and cotton

• Effect

– Increasing number of glyphosateresistant weeds

– Increase number of hard-to-control 

weeds

• Implication

– Glyphosate systems alone not 

the answer

Glyphosate 4x rate

Glyphosate-resistant 

waterhemp

Southern IL

 

Hard-to-control 

velvetleaf and 

lambsquarters

Glyphosate used alone
Documented glyphosate resistance

• Marestail first U.S. weed documented as glyphosate-resistant1

• In 2010, there were 10 weeds with documented resistance to glyphosate

• Resistant weeds are spreading geographically

2011

2000

Marestail

 Marestail

 G. Ragweed

 C. Ragweed

 P. Amaranth

 Kochia

 Waterhemp

 Johnsongrass

 Italian Ryegrass

2011

Geographic Dispersion of 

Glyphosate-resistant Weeds

2011

2004

P. Amaranth

Sources: weedscience.org, Clemson 

University as of November 2011
Weed Control Challenges

• Increasing issue on farms across the 

U.S. in multiple crops

• Glyphosate resistance has heightened 

awareness of the issue

– Weed control issues are more 

broad than glyphosate resistance

• Herbicide tolerant crops did not cause 

weed resistance

– Virtually all modes of action have some 

weed resistance development

Growers Reporting 

Difficult-to-Control Weeds1

 1. Proprietary market research study conducted among Midwest, Mid South and 

Southeast growers. Jefferson Davis and Associates, February 2011.
0%

5%

10%

15%

20%

G. 

Ragweed

Waterhemp WaterhempC. Ragweed

Corn Soybeans

Prevalence of Weeds Negatively 

Impacts Production

• The need for weed control is agronomic 

and impacts production

• Herbicide resistance is a key driver for the 

need for new technology and inclusion of 

diverse modes of action

• New modes of action are extremely 

difficult to find and are 8-10 years away 

from market

Negative Yield Impact from Weeds in 

Corn & Soybeans2

S. Minnesota Giant Ragweed

 2. Integrated Pest & Crop Management Newsletter, University of Missouri Vol. 14, No. 11 Article 8 of 10, June 4, 2004; The Glyphosate, 

Weeds and Crops Series: Biology and Management of Common Ragweed Tom Jordan, Purdue University; Glenn Nice, Purdue 

University; Reid Smeda, University of Missouri; Christy Sprague, Michigan State University; Mark Loux, Ohio State University; Bill Johnson, 

Purdue University; The Glyphosate, Weeds and Crops Series: Biology and Management of Waterhemp Dawn Nordby, University of 

Illinois Bob Hartzler, Iowa State University Kevin Bradley, University of Missouri; The Glyphosate, Weeds and Crops Series: Biology and 

Management of Common Ragweed Tom Jordan, Purdue University, Glenn Nice, Purdue University, Reid Smeda, University of Missouri, 

Christy Sprague, Michigan State University, Mark Loux, Ohio State University, Bill Johnson, Purdue University
Multiple Modes of Action – An important part 

of sustaining weed control

The National Research Council 

and Weed Science Society of 

America agree that:

• Use of a single mode of action is 

considered unsustainable and 

recommend using a diversified 

weed management system

• Both cite use of herbicides with 

different modes of action as one of 

the important tools in such a 

program
Weed Resistance Management Strategies

Management Option

Risk of Resistance Development

Low Moderate High

Herbicide mix or rotation in 

cropping system >2 modes of action 2 modes of action 1 mode of action

Weed control in cropping 

system

Cultural, mechanical 

and chemical Cultural* and chemical Chemical only

Use of same MOA per 

season

Once More than once Many times

Cropping system Full rotation Limited rotation No rotation

Resistance status to MOA Unknown Limited Common

Weed infestation Low Moderate High

Control in last 3 years Good Declining Poor
DAS-40278-9 corn and EnlistTM Herbicide Solution

• New herbicide tolerant traits that provide 

robust tolerance to 2,4-D

• Will be stacked with glyphosate tolerance 

traits

– Will allow use of an additional mode of action without 

changing the farming system that growers have adopted

• Includes a new and innovative 2,4-D choline 

based herbicide

• Enlist herbicide will feature technology to 

reduce potential off-target movement

• Will be promoted with additional weed control 

modes of action (foundation chemistries, 

mechanical control, crop rotations)
DAS-40278-9 Corn: What is it?

• DAS-40278-9 corn contains the aad-1 gene, which 

expresses the AAD-1 protein

– aad-1 was isolated from common soil bacterium 

Sphingobium herbicidovorans

– Provides tolerance to registered herbicides of the chemical 

families:

• Phenoxy auxins (e.g., 2,4-D)

• Aryloxyphenoxypropionate (AOPP or “fop”) graminicides

(e.g., quizalofop, cyhalofop, haloxyfop, ...)

• Corn has some intrinsic tolerance to 2,4-D, and 2,4-D is 

currently registered by US EPA for use on corn

– Usage is low because of potential occurrence of crop injury
AAD-1: How does it work?

Phenoxy auxins (e.g., 2,4-D) 

Broad-spectrum, inexpensive, durable, primarily broadleaf herbicides 

Aryloxyphenoxypropionates (e.g., quizalofop, cyhalofop, haloxyfop)

Broad-spectrum, highly-active grass-specific herbicides

O

OH

O

Cl Cl

2,4-D

Quizalofop

OH

Cl Cl

N

N O

OH Cl

AAD-1

Inactive

AAD-1

Inactive N

N O

O

OH

O

Cl

• Provides robust tolerance to pre-emergence and post-emergence applications of 

2,4-D

• Robust tolerance to applications of all “fop” herbicides

DCP
DAS-40278-9 Corn: How will it be 

marketed and used?

• DAS-40278-9 will be “stacked” through conventional 

breeding with other corn traits that have been 

previously deregulated. 

• DAS-40278-9 is a complement to existing herbicidetolerant traits, not a substitute
Benefits to Utilizing AAD-1 Corn

• Allows use of a broad-spectrum herbicide MOA for use in glyphosate

tolerant application systems. Improves control of key hard-to-control 

broadleaf weeds compared to glyphosate systems alone.

• 2,4-D controls “weed shifts” that are hard to control with glyphosate

alone, reducing the need for increasing glyphosate rates

• 2,4-D provides an effective resistance management / prevention 

solution. Low cost, high performance solution to reduce escalation of 

glyphosate (and ALS) resistance in mono and dicot weeds. 

• 2,4-D extends and protects the utility of glyphosate:

– The most widely used herbicide in crop and fallow:

– Glyphosate cropping system is simple, reliable and robust 

– Roundup Ready market penetration predicted for 2011: corn (90%), 

soybean (95%), cotton (75%)

– Supports conservation tillage farming systems

• Quizalofop provides a new MOA selectable marker for stacking traits
• Eliminates interval (up to 14 days) between pre-plant application and planting.

• Eliminates drop nozzles for corn greater than 8”

• Allows 1 lb ae/A per application with max of 2 broadcast applications, POST through V8 or 48” corn.

• 2,4-D can be applied selectively when weed control is needed and most effective, overlapping with 

 glyphosate application window

3 lb ae/A

Maximum 

seasonal rate

3 lb ae/A

Planting

Current use pattern of 2,4-D for conventional corn

Pre-Harvest

1.5 lb ae /A 

Pre-plant

1 lb ae /A

Post 0.5 lb ae /A 

If < 8” over the top 

If > 8” off foliage

Proposed use of 2,4-D for DAS 40278-9 Corn

Corn stage 

V8 / 48”

Pre-plant

1 lb ae /A

Minimum 

12 days apart

Post 

1lb ae /A

Post

1lb ae /A

Use of 2,4-D on DAS 40278-9 Corn
• Provides up to 1 lb ae/A of each active ingredient per application with maximum of 2 postemergent broadcast applications through V8 or 48” corn.

Planting Corn stage 

V8 / 48”

Pre-plant

Minimum 

12 days 

apart

Post Post

Proposed Use of 2,4-D/glyphosate (Enlist Duo) on DAS 

40278-9 Corn
Proposed Quizalofop Use Pattern with Enlist Corn

Quizalofop new use in Enlist Corn:

•Selection agent for transgenic (AAD-1) seed corn production 

•POST grass control option. 

• Normal use rate currently recommended for grass control in soybean and cotton. 

•Total seasonal use no greater than current in-crop use rate (0.082 lb ae/A)

•Selective use of Fop use will be new for corn. Provides optimal use timing as a 

selection agent and for control of grasses.

 Post up to 0.082 lb/A

New use pattern for Dow AgroSciences Enlist Corn

V6
Enlist Duo Herbicide with Colex-D 

Technology

• Regulatory approval by EPA required for all herbicide 

products.

• Enlist Duo will be the only auxin-based herbicide 

allowed post-emergent on DAS-40278-9 corn.

• Violation of federal law to use a herbicide inconsistent 

with an EPA-approved label.
Colex-D Technology
Colex-DTM Technology

• 2,4-D choline

– Novel use of an essential human nutrient

– Most non-volatile 2,4-D product

– Improved eye irritation

– Enhanced product handling features

• Latest formulation science and techniques

– Significant decrease in driftable fines

• State of the Art Manufacturing Processes

– Major reduction in odor

– Traditional 2,4-D odor virtually non-detectable at edge of field
Why 2,4-D Choline?

• Arose from a desire to fundamentally change aspects of 

traditional 2,4-D

– Greatly reduce potential for off-target herbicide movement

• Esters were a non-starter

• Could a form be found with even lower volatility than 

amines?

– Enhance the toxicology profile

• Toxicity profile of counter ions

• Eye irritation potential of amines and 2,4-D acid

– Improve handling characteristics

• Cold weather handling

• Mixability
Field Volatility Study Design

• 4 sites

– 2010 (2,4-Ds only)

• Farmland, IN - Soybean (12”)

• Fowler, IN – tilled bare soil

– 2011(tank mixes and premix)

• Little Rock, AR – soybeans (5-6”)

• Ty Ty, Georgia – cotton (12”)

• Sampling

– Indirect flux measurement

– 5 and 15 m from plot boundaries

– Air-sampling pumps, 1 L/min

– OVS tubes, XAD-2 resin

• c. 6-hour intervals

• to c. 72 hours

• Conditions

– Farmland – 60s – mid-80s, 45-100% RH, no precip

– Fowler – low 50s – mid-80s, 26-98% RH , 1.2” rain late day 2 

– Little Rock – high 70s – high 90s, 35-96% RH, 0.1” in rain night day 2

– Ty Ty – mid-60s – high 90s, 24-97% RH, no precip

– Soil very dry in all sites
Three Day Cumulative Vapor Loss of 2,4-D

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

0 12 24 36 48 60

cumulative mass loss, % of 

applied

Hours after treatment

Farmland (80% canopy)

Choline

DMA

EHE

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

0 12 24 36 48 60

cumulative mass loss, % of 

applied

Hours after treatment

Fowler (bare soil)

Choline

DMA

EHE

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%

3.0%

3.5%

4.0%

4.5%

0 12 24 36 48 60 72

cumulative mass loss, % of 

applied

Hours after treatment

Arkansas (15% canopy)

choline alone

choline + glyphosate

DMA 

EHE

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%

3.0%

3.5%

4.0%

4.5%

0 12 24 36 48 60 72

cumulative mass loss, % 

applied

Hours after treatment

Georgia (40% canopy)

choline alone

choline + glyphosate

DMA

EHE
Cumulative losses greatly reduced with 

2,4-D choline

Site EHE DMA

2,4-D choline 

Alone

2,4-D choline 

+ Glyphosate

Farmland 3.83% 0.71% 0.33% -

Fowler 1.55% 0.62% 0.20% -

Little Rock* 3.9% 0.81% 0.08% 0.09%

Ty Ty* 2.83% 0.91% 0.02% 0.01%

* non-optimized fluxes

•2,4-D choline avg 6x lower than DMA

•2,4-D choline avg 24x lower than EHE
Prediction at Larger Scale

Simulated exposure from 40-acre treatment area: first 6 

hours after application - units: (μg/m3)-hr

•Relate model estimates over time to plant effects => risk assessment &

 stewardship recommendations

Choline

meters

-400 -200 0 200 400 600 800

meters -400

-200

0

200

400

600

800

0.0 

0.5 

1.0 

1.5 

2.0 

2.5 

3.0 

DMA

meters

-400 -200 0 200 400 600 800

meters -400

-200

0

200

400

600

800

EHE

meters

-400 -200 0 200 400 600 800

meters -400

-200

0

200

400

600

800
Volatility Summary

• Novel 2,4-D choline salt showed consistent 

reduction of volatile loss potential

• 2,4-D choline averaged 96% reduction vs. 

ester

• 2,4-D choline average 84% reduction vs. 

DMA
EnlistTM Herbicide spray drift research
Technologies for Controlling Spray Droplet Size

• Application Equipment

– Nozzle type, application parameters (boom height, pressure, 

speed, etc) have major effect on droplet size

• Formulation (Spray Solution) Properties

– Tank mix composition is generally viewed as less important than 

application parameters, but as will be shown, can be significant
Spray Droplet Size Distribution of New Premix 

Formulation vs. 2,4-D + Glyphosate Tank Mix

0

0.5

1

1.5

2

2.5

1 10 100 1000 10000

Particle Size (um)

Density Distribution

15 GPA DAS Premix

10 GPA DAS Premix

15 GPA T.M. of DMA6 and Durango DMA

10 GPA T.M. of DMA6 and Durango DMA

Sample 15 GPA Premix

10 GPA Premix

15 GPA Tank Mix

10 GPA Tank Mix

d(0.5)

271

265

150

148

% Fines

16.8%

18.8%

50.2%

51.1%
2,4-D Choline + Glyphosate 

Premix

• Incorporates 

the attributes 

of the new 2,4-

D choline

• Utilizes new 

formulation 

advancements 

to improve 

particle size 

distribution 

and reduce 

drift
Field study – McCook, NE

• ISO standard 22866/ASABE 561.1/EPA DRT draft

• 2 application plots

– Plot 1 – 180 x 460 ft

– Plot 3 – 180 x 535 ft

• Triplicate downwind collectors

– Tracer dye and 2,4-D analytical

• Winds 3 – 11 mph

• Application with commercial equipment

• Enlist Herbicide Solution premix vs. tank mix

• 3 nozzles

– XR - Medium

– AIXR – Very/extremely coarse

– TTAI – Ultra coarse

• 37 total treatments
Comparison of deposition at 100 feet

normalized to the tank mix deposition with XR nozzle

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

XR TTAI AIXR

Relative deposition @ 100 ft

Tank Mix

Enlist Duo

Tank mix

Enlist Herbicide Solution
EnlistTM Weed Control System 

Stewardship Overview

TMEnlist and Enlist Duo are trademarks of Dow AgroSciences LLC. 

 Components of the Enlist Weed Control System have not yet received regulatory approvals; approvals are pending.

 The information provided here is not an offer for sale. ©2011 Dow AgroSciences LLC
Stewardship Program Goals

• Addresses both crop and herbicide

• Provide Comprehensive Guidance and 

Education on Responsible Use

• Promote Use of AuthorizedHerbicides

• Minimize Potential Off-Target Movement

• Promote Weed Resistance Management

• Promote Responsible Use and Worker Safety

• Support Compliance with Regulatory 

Requirements

Integrated

Stewardship

Program
Integrated Stewardship Program

• Built upon existing stewardship 

programs for agricultural chemicals 

and seed traits

• Obtained input from key 

stakeholders and functional 

subject matter experts

Technology 

Advancements

Management 

Recommendations 

and Resources

Education, 

Training and 

Outreach

Integrated

Stewardship

Program
Introducing Enlist Ahead

• First-of-its-kind management resource

• Designed for the grower and applicator

• Benefits-based resource

• Helps growers succeed while promoting 

responsible use of the Enlist system

• Will offer technology advancements, 

management recommendations & 

resources, and education, training & 

outreach 
Enlist Ahead

Technology 

Advancements

Education,

Training and 

Outreach

Foundational Pillar What How

Herbicide products that will provide:

• Exceptional weed control

• Convenience for the grower and applicator

• Built-in drift reduction to minimize the potential 

for off-target movement

Train growers and applicators on:

• Enlist basics and Colex-DTM Technology

• Spray equipment and application practices

• Managing product use near sensitive crops

• Weed resistance management

Encourage dialogue between neighbors

• In-field and instructor-led training

• Interactive online learning modules

• Support online sensitive crop registries

• Collaborate with value chain and 

industry associations

Management 

Recommendations 

and Resources

Provide management recommendations 

and resources to:

• Promote responsible use of the Enlist system

• Minimize the potential for off-target movement

• Promote weed resistance management 

practices

• Promote biotechnology trait stewardship

• Product Labels

• Technology Use Agreements

• Product Use Guides 

• Required use of authorized herbicides

• Use of alternative MOA herbicides 

• Tools for selection of proper 

application equipment and practices

• Communications to distributors, 

retailers, growers, and applicators
Stewardship Program Components

• Authorized Herbicide Product Label (submitted 

to EPA)

• Access Authorized via Signed Technology Use 

Agreement

• Comprehensive Product Use Guides

• Education and Training for Distributors, 

Retailers, Growers and Applicators

• Product Stewardship Tools and Resources

• Compliance Monitoring and On-Farm 

Assessments

Integrated

Stewardship

Program
• Requires applicators to follow all state and local 

pesticide requirements regarding application of 

2,4-D herbicides 

• Does not allow application into areas of 

temperature inversion

• Restricts ground applications to wind speeds less 

than or equal to 15 mph

• Requires using spray nozzles in accordance with 

manufacturer recommendations that produce a 

droplet size classification of coarse or coarser 

(ASABE S-572 standard)

• Recommends use of drift reduction nozzles

Authorized Herbicide Product Label

Technology

Advancements
• Requires an upwind setback of 250 feet from 

sensitive areas if coarse or very coarse 

droplet classifications cannot be maintained

• Requires use of properly maintained and 

calibrated ground application equipment with 

minimum boom heights based upon nozzle 

manufacturer’s recommendations 

• Provides instructions for sprayer and 

equipment clean-out after product use

• Does not allow aerial or chemigation 

applications (i.e. ground application only)

Authorized Herbicide Product Label

Technology

Advancements
• Requires growers to utilize approved 

Dow AgroSciences authorized herbicides only 

for in-crop applications

• Requires growers to adhere to Product Label 

and Product Use Guide requirements

• Requires growers to provide access to 

information about utilization of the technology 

and allow on-farm assessments

• Provides Dow AgroSciences the right to revoke 

technology access if stewardship obligations 

are not met

• Use of any herbicide or combination of 

herbicides not authorized by the Technology 

Use Agreement would infringe patents owned 

by DAS

Access Authorized Via Technology Use 

Agreements

Technology 

Use

Agreements
Comprehensive Product Use Guides

Technology 

Advancements

Education 

& 

Training

• Authorized Use via Grower 

Agreements

• Stakeholder Outreach

•Technical Information

• Compliance 

Monitoring

Tools & Activities

Product 

Use 

Guidelines

• Requires growers to read and follow all FIFRA 

Pesticide Product Label directions

• Requires growers to utilize only approved 

Dow AgroSciences authorized herbicides for incrop applications

• Requires growers to adhere to Weed Resistance 

Management practices

• Recommends growers utilize herbicide products 

with additional modes of action
Education, Training and Outreach

Technology 

Advancements

Education 

& 

Training

• Authorized Use via Grower 

Agreements

• Stakeholder Outreach

•Technical Information

• Compliance 

Monitoring

Tools & Activities

• Reinforces requirements to adhere to product use 

guidelines, pesticide product label, and all product 

stewardship requirements for responsible use and 

proper stewardship of the technology 

• Provides product guidance at retail locations on 

responsible use of the technology to promote 

proper stewardship

• Includes responsible use of trait and herbicide 

technology, weed resistance management, spray 

technology and stewardship requirements

• Diverse modes of delivery including webinars, 

Instructor-Led-Training, online modules and field 

demonstrations for growers, applicators, retailers 

and distributors

Education, 

Training and 

Outreach
Ongoing Training and Communications

• Building an external Learning Management System specifically for 

the channel and end-users

• In-field training including spray application training

• Grower and channel focused

communications supplemental 

to regulatory documents

• Websites 
Enlist 360

• Comprehensive training effort for 

retailers, applicators, seed sellers and 

growers

• Enlist 360 will include training 

information delivered in diverse learning 

methods including computer based, 

classroom, hands-on and in-field

• Contracted with an adult learning 

company for development of training 

modules

• Training name and consistent look 

helps the end-user understand the four 

training elements are linked

Information Sheet
Field Training Learner Guide
Investment in Training Equipment
Compliance Monitoring

• Will conduct grower surveys and on-farm 

assessments to monitor compliance with the 

Technology Use Agreement and Product Use Guides

• Upon request, technology users must provide 

information regarding the location of fields planted 

with Enlist corn and the herbicides used 

• Have dedicated hotline to report potential incidents 

involving Enlist products

• Will investigate allegations and follow-up, as needed

• Failure to follow the stewardship requirements will 

result in:

– education and reinforcement of stewardship 

requirements with growers, applicators, and retailers; 

– additional education and training; and/or

– loss of access to the technology 

Compliance

Monitoring
Tools and Resources

• AdvanceFarming.com

• Trait Stewardship Website

• Enlist Weed Control System Technical Bulletin

• Customer Service and Product Information Hotline

• Trained and Dedicated Enlist Field Specialists

• Additional product support resources include 

Product Stewardship Specialists, Customer 

Agronomists, Field Biologists, Product Managers, 

Crop Protection and Seed Sales Representatives

Tools and 

Resources
Overview of Submitted Documents

TMEnlist and Enlist Duo are trademarks of Dow AgroSciences LLC. 

 Components of the Enlist Weed Control System have not yet received regulatory approvals; approvals are pending.

 The information provided here is not an offer for sale. ©2011 Dow AgroSciences LLC
DAS Supplied Materials

DAS has submitted numerous documents to APHIS that are part of the 

administrative record relating to DAS-40278-9 corn deregulation (including 

documents related to EPA’s review of 2,4-D)

• Intent: Provide pertinent facts/data to APHIS to inform the drafting of the 

EA and response to comments

• Types of Material:

– DAS-40278-9 Corn Petition 

– DAS research summaries: drift/volatility

– DAS Educational materials: EnlistTM Weed Control System, Stewardship Program

– Scientific papers/published abstracts: utility of AAD-1 transgenes

– Submissions/responses/decisions from EPA/FDA

– DAS authored ‘white papers’ on specific topics: technology benefits, Stewardship 

Program, herbicide use

– DAS comments to the docket
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Provide APHIS with new information expanding on original petition

• Develop the context for the product and its development

Document Key Information

Background

EnlistTM Technical Bulletin Overview of DAS-40278-9 Corn and other technologies 

comprising the EnlistTM Weed Control System

PNAS Articles and Letters to Editor

Robust crop resistance to broadleaf and grass herbicides 

provided by aryloxyalkanoate dioxygenase transgenes

2,4-Dichlorophenoxyacetic acid (2,4-D)–resistant crops and the 

potential for evolution of 2,4-D–resistant weeds

Reply to Egan et al.: Stewardship for herbicide-resistance crop 

technology

Scientific description of the utility of AAD transgenes in 

conferring herbicide tolerance to crops.

Related discussion of development of herbicide resistant 

weeds 

ISB News Report

Utility of Aryloxyalkanoate Dioxygenase Transgenes for 

Development of New Herbicide Resistant Crop Technologies

Description of the utility of using AAD transgenes as an 

effective new tool allowing for sustainable weed 

management strategies

U.S. EPA Tour of Weed Resistance Management Challenges in

Missouri, Illinois, and Arkansas

Documents the problems related to gyphosate-resistant 

weeds being faced by growers 
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Provide APHIS with new information expanding on original petition

• Develop the context for the product and its development

Background Information:

• EnlistTM Technical Bulletin – product information

• PNAS Articles and Letters to Editor – transgene development and utility

• ISB News Report – application to weed resistance management

• U.S. EPA Tour of Weed Resistance Management Challenges
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Economic and agronomic benefits of DAS-40278-9 corn when 2,4-D is used for 

weed control

Document Key Information

Benefits of DAS-40278-9 Corn

Economic and Agronomic Impacts of the Introduction of DAS40278-9 Corn on Glyphosate Resistant Weeds in the U.S. 

Cropping System

1/ Benefits of Glyphosate Tolerant Crops

2/ Weed Management in Glyphosate Tolerant Corn and 

Soybeans

3/ Long-term Weed Resistance Management through Use of 

Herbicide Tolerant DAS-40278-9

4/ Economic Benefits of Dow AgroSciences Herbicide Tolerant 

Technology

5/ Impact of 2,4-D on Herbicide Tolerant DAS-40278-9 Corn and 

DAS-68416-4 Soybeans on the Cost and Environmental Load of 

Herbicides Applied on Glyphosate Tolerant Corn and Soybeans

Projected herbicide use and impact of EnlistTM Weed Control 

System vs. alternatives

Examines changes in herbicide application in corn and 

soybean with and without adoption of Enlist crops

Research Demonstrating Reduction in Potential Off-Target 

Movement for 2,4-D Choline and Colex-DTM Technology as Part 

of the EnlistTM Weed Control System

Provides information related to volatility and spray drift 

characteristics associated with 2,4-D choline and the 

proprietary formulation comprising Colex-DTM Technology 

that is part of the EnlistTM Weed Control System.
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Economic and agronomic benefits of DAS-40278-9 corn when 2,4-D is used for 

weed control

Benefits of DAS-40278-9 Corn:

• Economic and Agronomic Impacts of the Introduction of DAS-40278-9 Corn on 

Glyphosate Resistant Weeds in the U.S. Cropping System

• Projected Herbicide Use and Impact of EnlistTM Weed Control System vs. 

Alternatives

• Research Demonstrating Reduction in Potential Off-Target Movement for 2,4-D 

Choline and Colex-DTM Technology as Part of the EnlistTM Weed Control System
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Establish the ongoing regulatory activities and respective accountabilities of USEPA and APHIS pertaining to DAS-40278-9 corn and 2,4-D/quizalofop

Document Key Information

Regulatory Information

Regulatory Overview of 2,4-D and Quizalofop Summary of US-EPA regulatory authority and status of 

2,4-D and quizalofop at EPA

Summary of 2005 2,4-D Reregistration Eligibility Document 

(RED)

Major conclusions from RED and information from the US 

EPA 2,4-D RED Facts website (e.g. use profile, regulatory 

history, human health and environmental assessment)

GF-2654 TC US- EPA Data Submission Letter Supporting data for 2,4-D choline submitted to EPA

Draft Label GF-2654 TC Submitted to US-EPA

Details of proposed label for 2,4-D choline including 

herbicide resistance management, spray drift 

management and application directions.

GF-2727 TC Label Amendment Amendment submission to register the use of a premix of 

2,4-D choline and glyphosate DMA on DAS-40278-9 corn

US-FDA Conclusion of Consultation Letter re: DAS-40278-9 

Corn

Documentation of conclusion of US FDA consultation for 

DAS-40278-9 corn.
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Establish the ongoing regulatory activities and respective accountabilities of USEPA and APHIS pertaining to DAS-40278-9 corn and 2,4-D/quizalofop

Regulatory Information:

• Regulatory Overview of 2,4-D and Quizalofop

• Summary of 2005 2,4-D Reregistration Eligibility Document (RED)

• GF-2654 TC US- EPA Data Submission Letter

• Draft Label GF-2654 TC Submitted to US-EPA

• GF-2727 TC Label Amendment

• US-FDA Conclusion of Consultation Letter re: DAS-40278-9 Corn
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Detail the risk mitigating effect of DAS’ Product Stewardship Program and related 

proprietary technology 

Document Key Information

Product Stewardship Information

EnlistTM Weed Control System Stewardship

Program Overview

Stewardship program goals, components, education and 

training, compliance and reporting

Stewardship of Herbicide Tolerant Trait Technology for 

DAS-40278-9 Corn

Detailed description of Stewardship program goals, 

components, eduction and training, compliance 

monitoring

EnlistTM Technical Bulletin Brief description of the Stewardship program

Research Demonstrating Reduction in Potential Off-Target 

Movement for 2,4-D Choline and Colex-DTM Technology as Part 

of the EnlistTM Weed Control System

Data demonstrating the characteristics of 2,4-D choline 

and Colex-DTM Technology relative the Stewardship 

program

Draft Label GF-2654 TC Submitted to US-EPA Details of proposed label for 2,4-D choline including spray 

drift management and application directions.
DAS Supplied Materials

Documents Supplied in Support of Draft EA Development

• Detail the risk mitigating effect of DAS’ Product Stewardship Program and related 

proprietary technology 

Product Stewardship Information

• EnlistTM Weed Control System Stewardship Program Overview

• Stewardship of Herbicide Tolerant Trait Technology for DAS-40278-9 Corn

• EnlistTM Technical Bulletin

• Research Demonstrating Reduction in Potential Off-Target Movement for 2,4-D 

Choline and Colex-DTM Technology as Part of the EnlistTM Weed Control System

• Draft Label GF-2654 TC Submitted to US-EPA
DAS Comments on EA

TMEnlist and Enlist Duo are trademarks of Dow AgroSciences LLC. 

 Components of the Enlist Weed Control System have not yet received regulatory approvals; approvals are pending.

 The information provided here is not an offer for sale. ©2011 Dow AgroSciences LLC
DAS Supplied Materials

DAS Comments to the DAS-40278-9 Corn Docket

• Goal: Provide information relevant to issues being raised in 

the docket

• 3 comments submitted with attached documents

– APHIS-2010-0103-4933: Commitment to the Responsible 

Development and Use of the EnlistTM Weed Control System

– APHIS-2010-0103-5029: 2,4-D and DAS-40278-9 Corn Not 

Associated with Agent Orange Health Controversies

– APHIS-2010-0103-5865, 66, 67, 68, 70, 71, 74, 75: DAS Comments 

to Docket (1 comment, 8 parts)
DAS Supplied Materials

APHIS-2010-0103-4933: Commitment to the Responsible 

Development and Use of the EnlistTM Weed Control 

System

– Details risk mitigating effects of DAS’ technology and 

related product stewardship efforts

– Key aspects involve minimizing the potential for off-target 

movement of herbicide and promoting Weed Resistance 

Management (WRM) practices

– Farmer communication, outreach, training and education
DAS Supplied Materials

APHIS-2010-0103-5029: 2,4-D and DAS-40278-9 Corn Not 

Associated with Agent Orange Health Controversies

– 2,4-D choline is not Agent Orange; 2,4-D was not the focus 

of Agent Orange controversies 

– 2005, the U.S. EPA concluded that “there is a reasonable 

certainty no harm will result to the general population or 

any subgroup from the use of 2,4-D.”

– The dioxins of concern, 2,3,7,8-TCDD and 1,2,3,7,8-

PeCDD have not been found in 2,4-D produced by Dow 

AgroSciences
DAS Supplied Materials

APHIS-2010-0103-5865, 66, 67, 68, 70, 71, 74, 75: DAS 

Comments to Docket (1 comment, 8 parts)

– Main body of the comment provides facts/citations and linkage to 

the DEA relevant to key areas identified during our assessment 

of docket comments

• Gene Flow

• Seed, Organic and Specialty Production

• Trait Stacking in Commercial Corn Hybrids

• Regulatory Oversight of Pesticides in the U.S.: The Role of US-EPA

• Herbicide Resistance

• 2,4-D Toxicity Issues

• Off-Target Movement of 2,4-D

• Quizalofop Summary
DAS Supplied Materials

APHIS-2010-0103: DAS Comments to Docket (cont’d)

• Appendices provide factual material relevant to the deregulation process

– New Citation Inserts to DEA

– Research Demonstrating Reduction in Potential Off-Target Movement

– EPA Human Health Risk Assessment (2,4-D choline/DAS-40278-9)

– EPA Order Denying NRDC‟s petition to cancel 2,4-D registrations

– Weed Resistance Management Media Articles 

– Draft label for use of the 2,4-D/glyphosate pre-mix formulation on DAS40278-9 corn. 

– DAS Comments on APHIS’ PPRA

– Specific Comments on DAS-40278-9 Corn DEA
DAS Supplied Materials

Additional Comment Analysis will be Provided in Near Future

• Focus on substantive comments with relevance to DAS-40278-9 corn

• Anticipated materials:

– Table summary of comments with reference to various documents in the record 

or other APHIS NEPA documents (e.g. RRSB FEIS)

• Will provide specific direction to relevant information by 

document/page

– Increased herbicide application volume

– AAD-1 expression in pollen

– Herbicide synergy, multiple resistance development

– Stewardship documents 

• e.g. Technology Use Agreement, Stewardship Program 

• If beneficial, data/documents submitted to EPA can be provided
Thank You 

Components of the Enlist Weed Control System have not yet received 

regulatory approvals; approvals are pending. Enlist Duo is not yet registered 

for sale or use as a component of the Enlist Weed Control System.

The information provided herein is not an offer for sale. 

TMEnlist is a trademark of Dow AgroSciences LLC. 

©2011 Dow AgroSciences LLC