1

Section 18 Application – sulfoxaflor (TransformTM) 

Arkansas Cotton 

Submitted by the Arkansas State Plant Board and University of Arkansas

Division of Agriculture

Type of Exemption – Arkansas 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:

Contact Persons:

Mr. Terry Walker

Director

Arkansas State Plant Board

P.O. Box 1069

Little Rock, AR 72203

501-225-1598

darryl.little@aspb.ar.gov

Ms. Brandi Reynolds

Assistant Director- Product Registration for Pesticide Division

Arkansas State Plant Board

P.O. Box 1069

Little Rock, AR 72203

501-225-1598

brandi.reynolds@aspb.ar.gov

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

University contact:

Gus Lorenz, Extension Entomologist- IPM Coordinator

University of Arkansas Division of Agriculture

Lonoke Research and Extension Center

Lonoke, AR 72086 

Phone: 501-676-3124

Fax: 501-676-7787

Email: glorenz@uaex.edu

Nick Seiter, Extension Entomologist
2

Assistant Professor

University of Arkansas Division of Agriculture

University of Arkansas

SEREC

PO Box 3508

Monticello, AR 71656

Phone: 870-532-7331

Email: nseiter@uaex.edu

Glenn Studebaker

Professor, Extension Entomologist

Entomology

University of AR, Division of Ag

NE Research and Extension Center, Keiser, AR

Telephone Number: 870-526-2199

E-mail: gstudebaker@uaex.edu

Registrant Representative

Tami Jones-Jefferson

U.S. Regulatory Leader 

U.S. Regulatory & Government Affairs – 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

University of Arkansas Cooperative Extension Service 

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 (Attachment 1)

Formulation: Active Ingredient 50%
3

SECTION 166.20(a) 3: DESCRIPTION OF PROPOSED USE

i. Sites to be treated:

The insecticide will be restricted to use on cotton fields in the state of Arkansas for 

the purpose of controlling the tarnished plant bug, Lygus lineolaris (Palisot de 

Beauvois). 

Historically, cotton has been produced in the counties of:

Clay, Greene, Craighead, Mississippi, Crittenden, St. Francis, Jackson, Prairie, 

Monroe, Phillips, Lonoke, Pulaski, Jefferson, Lincoln, Drew, Desha, Ashley, 

Lafayette, Lee, and Chicot in Arkansas.(2000 Crop Profile for Cotton in Arkansas; 

http://www.ipmcenters.org/cropprofiles/docs/ARcotton.html.)

ii. Method of Application:

Applications will be made by foliar application. 

iii. Rate of Application:

1.5 – 2.25 oz/ac (0.047 – 0.0071 lb ai/ac). Annual use will not exceed 8.5 oz. of 

Transform (0.266 lb. ai/ac).

iv. The maximum number of applications:

Do not apply more than four applications per season.

v. The total acreage to be treated:

In 2015 Arkansas planted approximately 205,000 acres of cotton 

(http://www.cotton.org/econ/cropinfo/varieties/midsouth.cfmacross). Arkansas producers 

treated 100% of the total planted acreage for the control of tarnished plant bug, Lygus 

lineolaris (Palisot de Beauvois) during 2015 (http://www.entomology.msstate.edu/ 

resources/tips/cotton-losses/data/). Cotton acreage in Arkansas is projected to be roughly 

40-50% higher in 2016 or as much as 300,000 acres but it could be even higher. Due to 

market issues many growers have not decided which crops they will plant in 2016. If 

Arkansas goes higher than 300,000 acres we project a potential need to treat 80% or 

about 320,000 acres with sulfoxaflor for control of tarnished plant bug. This assessment 

is based on conservative estimates of the 2014 and 2015 crops where 100% of the 

acreage was treated. A recent survey conducted in 2015 with consultants in all cotton 

growing regions in Arkansas indicated that approximately 60% of the acreage in 

Arkansas was treated 6 to 8 times per year from 2014-2015. Another 15% were treated 

more than 8 times. There were 15% of fields treated less than 6 times per year with 10% 

treated 2 times per season.

vi. The total amount of pesticide proposed to be used:

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

cause economic losses on approximately 320,000 acres in Arkansas during 2016. 

Therefore four applications of sulfoxaflor may be required on these acres to reduce the 
4

impact of this pest. The high rate (2.25 oz/acre) can only be used three times to prevent 

exceeding total annual rate of 8.25 oz product. Based upon this maximum allocation of 

8.25 oz (1.5-2.25 oz of formulated product per acre per application), treated (total 

sprayed) acreage will require no more than 160,000 pounds of formulated product or 

80,000 lbs of active ingredient on Arkansas’s 320,000 acres. 

vii. All applicable restrictions and requirements concerning the proposed use which 

may not appear on labeling:

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.

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

18 label:

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

• Minimum Treatment Interval: Do not make applications less than 5 days apart.

• Do not make more than four applications per acre per season and no more than two 

applications during bloom.

• Do not apply more than a total of 8.5 oz of Transform WG (0.266 lb ai of 

sulfoxaflor) per acre per year. Use rate is 1.5 – 2.25 oz/ac (0.047 – 0.0071 lb ai/ac) 

per application. Annual use will not exceed 0.266 lb ai/ac

• Applications are restricted to cotton producing counties of Arkansas 

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

following:

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

treatment, applications must 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 Arkansas Pollinator Stewardship Program

• Transform WG should be applied only when populations are above thresholds as 

published in the MP-144 Insecticide Recommendations for Arkansas, page 74 or 

page 80. The stated threshold is equal to or greater than 3 tarnished plant bugs per 5 

row ft. on a drop cloth or one per 3 row feet on problem fields or 12 per 100 sweeps 

with a standard sweep net).

viii. The duration of the proposed use:

June – October of the 2016 cotton growing season 
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ix. Earliest possible harvest dates:

September 15, 2016

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

ARKANSAS

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

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

resistance has been documented to nearly every class of these compounds among MidSouth (Arkansas, Louisiana, Mississippi, Tennessee) populations of this insect. 

Populations have demonstrated resistance to pyrethroids and some organophosphates for 

several years (Snodgrass and Gore 2007), but many populations remained susceptible to 

neonicotinoid insecticides including thiamethoxam and imidacloprid (Snodgrass et al. 

2008). Acephate has been the most widely used and effective insecticide for control of 

plant bugs in cotton but efficacy continues to decrease in Louisiana and much of the mid 

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

rapidly eroding across Louisiana (Figure 1, Copes et al. 2010). 

Fig. 1. Three years, 2007-2009 of acephate efficacy

Against the TPB in Louisiana field trials. The dotted

Line indicates the action threshold of 6/ 10 row ft.

Even though acephate expressed partial efficacy against tarnished plant bugs in Arkansas, 

higher rates (0.5 to 1.25 lb AI/acre) were necessary each year from 2007-2009 to maintain 

the infestations below the action threshold. The highest rate actually exceeded the labeled 

rate that could be used. These field efficacy results are supported by laboratory data from 

Snodgrass which show significant levels of OP resistance in tarnished plant bug 

populations throughout the hills and delta in Arkansas, Louisiana, and Mississippi. During

the past two years, populations in these states also have been expressing lower 

susceptibility to neonicotinoid products, but no high levels of resistance have been 

documented. (Snodgrass 2010 abstract, See Appendix A). 
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In our regional plant bug trial conducted in 2009-2010 the following list of currently 

labeled products were used to evaluate their efficacy against tarnished plant bug in the 

Midsouth (Table 1):

Table 1. Regional treatment list of currently labeled products tested. 

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

plant bug numbers, but none are consistently effective and can maintain sub-economic 

injury levels for the season. During 2009 and 2010, the regional (Arkansas, Louisiana, 

Mississippi, and Tennessee) full-season insecticide screen was used to evaluate a list of 

products for control of tarnished plant bug (Fig 2, Lorenz et al., 2009 unpublished). As the 

data indicates no treatment of currently labeled products were able to lower plant bug 

numbers below the threshold of 6 plant bugs per 10 row feet at 6-10 days following the 

second application. (Figure 3, Lorenz et al. 2010 unpublished). 

Product Formulation Rate/ Acre

1. UTC

2. Acephate 90 S or 97 0.75 lb

3. Bidrin 8 EC 6 oz

4. Vydate 3.77 C-LV 12 oz

5. Centric 40 WG 2 oz

6. Trimax Pro 4.44 SC 1.5 oz

7. Carbine 50 WG 2.5 oz

8. Leverage 2.7 SE 4.5 oz

9. Intruder 70 WP 1.1 oz

10. Endigo 2.06 ZC 5.0 oz

11. Diamond 0.83 EC 9.0 oz

12. Brigade 2 EC 5.12 oz
7

a

cd

cd

b

bc bcd bc

cd bcd

d

bcd

bc

0

2

4

6

8

10

12

14

16

18

total plant bugs / 10 row ft.

Fig. 2. Across Location Regional Plant Bug Summary 2009

6-10 DAT-2

6-10 Days After Treatment 2

Locations: AR-(Studebaker), AR-(Akin), AR-(Lorenz), MS-(Cook), LA

Figure 2. Regional plant bug efficacy trial summary across states, 2009.

Figure 3. Regional plant bug efficacy trial summary across states, 2010.

In 2010 the figure above shows the lack of control for all currently labeled products for 

control of plant bugs in MS, LA and 3 locations in AR (Fig. 3). 
8

Six sprays were applied to the Louisiana trial which was designed to simulate moderate to 

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

cotton fields (Figure 4, Sharp et al. 2010 and B. R. Leonard unpublished).

 

Fig. 4. Efficacy of selected insecticides for tarnished plant bug control.

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

treatments significantly reduced numbers relative to a non-treated control. However, only 

Endigo and Diamond successfully reduced numbers below the action threshold (line 

marked with AT) used to gauge the need for additional treatments to stop yield losses. In 

addition, all of the bars highlighted with an asterisk (*) illustrate that six applications of 

those treatments exceeded the total allowable seasonal AI/acre. Only Vydate and Intruder 

AI’s were not exceeded. Yield losses have become severe in these situations in spite of 

multiple insecticide sprays. Currently, the only chemical strategy recommended is to coapply two insecticides and rotate among chemical classes.

In some areas across Arkansas 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. Arkansas producers averaged 3.5

applications during 2007 (Williams 2008) for this pest, but some areas received 8-10

treatments. In 2011 the average number of applications for this pest increased to 5 

applications with some areas reporting 8 or more applications. Current trends with 

insecticide resistance and lack of effective alternative technologies will allow problems 

with tarnished plant bug management to intensify across Arkansas and the Mid-South 

states. Chemical control options that provide consistent efficacy are not available to 

manage this pest. Effective Lygus control is a serious, unmet need for Mid-South cotton 
9

growers and one that requires immediate and urgent action. This has now become an 

emergency situation.

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

populations in these states have become significantly more difficult to control using 

common recommended insecticides (Lorenz et al. 2009; Moore et al. 2010). As a result, 

the numbers of applications and use rates needed to control tarnished plant bug have

increased. With a novel mode of action and chemical class, sulfoxaflor will successfully 

control both insecticide-susceptible and -resistant populations of tarnished plant bug, 

thereby improving the overall cotton IPM system. This would be a tremendous economic 

opportunity for cotton growers, and more environmentally-friendly alternative to the 

sustained frequency of the currently used products. 

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

to induce additional pest problems (spider mites and cotton aphids) in some areas. This is 

of great concern to many producers and pest management practitioners. Organophosphate, 

carbamate and pyrethroid insecticides can impact natural beneficial arthropod populations 

and flare secondary insects. Acephate is commonly used for Lygus control and can flare 

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

should reduce the frequency of selected insecticides 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. Limited 

data currently suggest that sulfoxaflor is not likely to flare aphids and mites. A comparison 

of the years 2008-2011 and 2012-2015 indicate that Arkansas has seen a yield increase of 

15% while acreage has decreased by 38%, however, the number of tarnished plant bug 

applications has increased by 33% ~1.6 more applications per season (Table 2.):

Table 2. Comparison of 2008-2011 prior to Transform and 2012-2015 with Transform 

in Arkansas.

Pre Transform Use In Arkansas Post Transform Use in Arkansas

Year Yield Acres TPB 

Sprays

Year Yield Acres TPB 

Sprays

2008 1012 615000 1.9 2012 1064 585000 5.1

2009 818 500000 2.9 2013 1133 305000 6

2010 1045 540000 2.8 2014 1145 330000 6

2011 929 660000 4.4 2015 1112 205000 6

Percent Change Pre and Post Transform Use 15% -38% 33%

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

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

Several IPM strategies are recommended for controlling tarnished plant bug in cotton 

(Gore et al. 2008). Non-chemical tactics include area-wide control of non-crop alternate 

hosts and selected host plant resistance traits. Proper selection of varieties and managing 

the optimum planting period are being to produce a rapid fruiting and early maturing crop; 

thereby reducing the time the crop is susceptible to this pest. Careful insecticide 

application timing based upon revised spray action thresholds are used to precisely target 
10

populations before they reach outbreak levels. All of these practices are currently in place 

and are being used by cotton producers. However, these strategies only serve to suppress 

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

practices are still necessary to provide tarnished plant bug management in cotton. 

Over the last ten years, field use rates have more than doubled and control has continued to 

decline. This has put a tremendous amount of pressure on the neonicotinoid class. Of that 

class, thiamethoxam is by far the most effective for tarnished plant bug control. 

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 provides 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). Recently the control observed with Centric has declined and is not as 

effective in recent years. USDA has reported increased tolerance to thiamethoxam (pers 

comm 2016). The only other labeled insecticides available are Carbine (flonicamid) and 

Diamond (novaluron). Figure 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 one or 

two applications of Transform will provide significant economic benefits for cotton 

growers in Arkansas.

SECTION 166.20(a) 5: EFFECTIVENESS OF PROPOSED USE

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

Sulfoxaflor (DAS test code GF-2372, proposed trade name TransformTM) has been 

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

Babcock et al. (2010, See Appendix B) and Zhu et al. (2010, See Appendix C) clearly 

define the biology and biochemistry of sulfoxaflor and demonstrate a novel mode of action 

against sap feeding insects including those in the order Heteroptera. Insects in the genus 

Lygus are included this order. Sulfoxaflor-induced mortality was similar between 

insecticide-resistant and –susceptible strains of several Homoptera and Heteroptera. No 

cross-resistance was detected to sulfoxaflor in populations expressing resistance to a broad 

range of modes of action. The effectiveness of sulfoxaflor against insecticide-susceptible 

populations of tarnished plant bug, Lygus lineolaris (Palisot de Beauvois) was comparable 

to those of other labeled classes of insecticides. These research projects support a novel 

mode of action for sulfoxaflor including those insecticides with similar chemical structures 

(neonicotinoids). 
11

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

Arkansas (Appendix D) against tarnished plant bug and are in the process of being 

published, trial results showed that Sulfoxaflor was usually as good as standards but often 

much better. The first field results were reported by Smith et al. (2010, See Appendix E) 

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

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

tarnished plant bug nymphs. For Louisiana during 2009-2010, Hardke (2011, Submitted 

to Entomological Society of America’s Arthropod Management Tests, See Appendix F) 

summarized the results of field trials for sulfoxaflor performance against tarnished plant 

bug. In the 2009 trials, effective rates and application frequencies were defined compared 

to standard products. In a co-application trial with a pyrethroid-resistant population, 

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

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

combination with novaluron demonstrated significantly better control of tarnished plant 

bugs than acephate and efficacy equivalent to a combination of a pyrethroid and 

thiamethoxam (Endigo). Reports of additional field trials from Arkansas, Mississippi, and 

Tennessee are in preparation and will serve to support the Louisiana results.

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

plant bug infestations on cotton during 2008-2010 is reported in Appendix G. These results 

demonstrated sulfoxaflor at one or more rates demonstrated control of plant bugs (high 

population levels) superior to the OP, dicrotophos. The residual efficacy of sulfoxaflor was 

greater than that for both dicrotophos and thiamethoxam. Efficacy was similar to a coapplication of a pyrethroid + neonicotinoid. In a comparison of cotton yields among 

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

spectrum and may have provided some yield increase from additional caterpillar pest 

control). Pest management practitioners recognize that sulfoxaflor should not be used as a 

single, season-long treatment, so chemical control strategies with co-applications and/or 

rotation for sequential treatments are the logical use pattern.

Other studies conducted in Arkansas show the yield loss associated with the current 

standard (acephate) and the increased yield of sulfoxaflor, well exceeding 20% in 2009 

(Table 3.) and up to 46% in 2010 (Table 4).

Table 3. Efficacy and yield comparison of selected Transform rates and 

acephate, 2009.

Transform Trial 2009

Treatments Season Total 

Plant Bugs

Harvest % Yield 

above 

UTC Lint lbs/acre

Transform 0.045 lb ai/a AB 59.3 d 587 a 126%

Transform 0.022 lb ai/a AB 108 c 538 ab 107%

Transform 0.034 lb ai/a AB 79 d 522 ab 101%

Orthene 1 lb/a A 178.3 b 475 bc 83%

UTC 276.3 a 260 d
12

Table 4. Efficacy and yield comparison of selected Transform rates and 

acephate, 2010.

PB5-2010

Treatment

Plant 

Bugs 

3DAT

Season 

Total

Plant 

Bugs

Yield 

lint 

lbs/acre

% Yield 

above 

UTC

Transform 0.045 lb ai/a 18.3 cd 93.3 c 1231 a 36%

Endigo 5 oz/a 18.8 cd 105.5 c 1136 ab 26%

Bidrin 6 oz/a 6.3 d 100.5 c 1100 ab 22%

Transform 0.067 lb ai/a 17.5 cd 86.5 c 1065 ab

c

18%

Acephate 0.5 lb./acre 53.8 b 185 b 833 c -8%

Untreated Check (UTC) 105.8 a 309.8 a 903 bc

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

with sulfoxaflor maintained tarnished plant bug populations below the action threshold for 

the duration of the trial; whereas a standard strategy was unable to provide satisfactory 

control. In a commercial field, the standard treatments (without sulfoxaflor) would have 

required additional applications to reduce populations. In the season-long trials, strategies 

relying on sulfoxaflor significantly increased cotton yield above the standard-treated and 

non-treated plots. Willrich et al. (2010, see Appendix H) further summarized results for 

2008-2009 as an abstract and reported sulfoxaflor’s acute toxicity for knockdown of 

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

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

cotton treated with acephate (1.0 lb AI/acre) across 16 trials. Recent trial results continue to 

show the efficacy of Transform has not diminished as shown in the Tables 5 and 6 below 

from a trial conducted in 2014 and 2015, respectively.
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Table 5. Efficacy of selected insecticides for control of tarnished plant bug 

showing total plant bugs sampled, yield and yield reduction compared to 

Transform. 2014.

Treatment Season Total

Plant Bugs

Yield

lbs/acre

% below

Transform 1.75 oz 19 5326.6

UTC 149 2499 -53

Bidrin 6 oz/acre* 38 4237.9 -20

Brigade 5.6 oz/acre* 70.4 3598 -32

Sivanto 14 oz/acre 85 2804.8 -47

Vydate C-LV 10.7 oz/acre 51 3151.8 -41

DoubleTake 4 oz/acre 143 2473.8 -54

Table 6. Efficacy of selected insecticides showing total number of plant bugs

sampled, yield and percentage of reduced yield compared to Transform. 2015.

Treatment

Season 

Total

Plant Bugs

Yield

pounds/acre % below

Transform 1.75 oz 45 4157

UTC 140 3244.1 -22%

Strafer 3 oz 61 3307.2 -20%

Centric 2 oz 75 3387.4 -19%

Centric 2 oz & Diamond 6 oz 65 3426.1 -18%

Orthene 1 lb 46 3335.8 -20%

Transform averaged about 20% better control and the same for increased yield over other 

treatments.

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 
14

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. 

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

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 two spotted spider mite or cotton aphid. A study conducted in 

Stoneville, MS in 2013 compared 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 two 

spotted 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 control of 

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.
15

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

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

the number of insecticide sprays for two spotted 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. 

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

currently used to manage tarnished plant bug on cotton. It is an excellent tool for Arkansas

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
16

value against insecticide-resistant populations. Sulfoxaflor is the backbone of chemical 

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

situation. Sulfoxaflor has been widely adopted by producers because of safety to 

pollinators and other beneficial insects. Two of the largest beekeepers in Arkansas have 

shown their support for Transform use on cotton (Attachment 2 & 3). 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. It also provides for insecticide resistance management which is, or 

should be, a concern for everyone. 

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 nonaquatic-crop 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. 
17

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 subpopulations 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.
18

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 sub chronic, chronic and short-term studies. Hepatotoxicity occurred at lower 

doses in long-term studies compared to short-term studies.
19

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 

high-dose 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, and 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 sub lethal 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 
20

(1 fish at 400 mg a.i./L for rainbow trout). No other treatment-related sub lethal effects 

were reported. For an estuarine/marine sheepshead minnow, sulfoxaflor was also 

practically non-toxic with an LC50 of 288 mg a.i./L. Sub lethal 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 non-toxic 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 
21

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/kg-diet for mallard ducks and bobwhite quail. The NOAEL from these 

studies is 5620 mg/kg-diet as no treatment related mortality of sub lethal 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. Longerterm 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 
22

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 non-toxic 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 10-8 torr 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 bio concentration study was provided due to the low Kow, but sulfoxaflor is not 

expected to bio accumulate 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 
23

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 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 Arkansas

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 
24

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 Arkansas 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 Arkansas, were prepared by ASPB.

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

ARKANSAS

The Arkansas State Plant Board will receive a copy 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 (Attachment 4). 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) (Attachment 1).

SECTION 166.20(a) 10: ENFORCEMENT PROGRAM IN ARKANSAS

The Arkansas State Plant Board (ASPB) has adequate authorities for enforcing provisions 

of Section 18 emergency exemptions. ASPB will require Dow AgroScience to prepare 

Section 18 labeling that complies with ASPB 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 request under a Section 18 of FIFRA, the product was used under a 

Section 18 in 2012. The product was labeled from 2013 through 2015 but the label was 

withdrawn for unknown or unspecified reasons. No valid reasons were given. We 

have had use of Transform since 2012 either through a Section 18 or a Label 3 and 

have no reported cases of problems with honey bees or pollinators in that time. 

SECTION 166.20(b) 1: NAME OF THE PEST

Lygus lineolaris (Palisot de Beauvois), tarnished plant bug 

SECTION 166.20(a) 11: 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 
25

from tarnished plant bugs during flowering was relatively uncommon. However, with 

>80% of Mid-South (Arkansas, Louisiana, Mississippi, Tennessee) cotton now being 

planted to transgenic cotton expressing one or more toxins derived from Bacillus 

thuringiensis (Bt) (Williams 2008) and the eradication of the boll weevil, Anthonomus 

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

other pests during flowering have been eliminated. An increase in federal 

conservation/wetlands reserve programs, wide scale adoption of conservation tillage 

systems, and increased diversity of the summer farmscape with crop rotations have created 

a more favorable environment enhancing tarnished plant bug population development. 

Recently, this region has experienced a significant reduction in cotton acres and subsequent 

increase in field corn which also has exacerbated this emergency situation. The tarnished 

plant bug has adapted to some grass crops with reproduction on field corn which provides a 

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

the population. The consequence of these Southern production system changes is that 

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

last decade. Just due to higher populations which persist longer during the season, control 

costs and crop losses associated with tarnished plant bugs have increased dramatically.

Typically, fewer than two applications per season were directed towards this pest prior to 

the mid-1990’s. Now as of last year growers made an average of 5 insecticide applications 

targeted at this pest in in Arkansas (Williams 2011). 

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

intensified selection for resistance. Snodgrass and Gore (2007) has reported resistance to a 

number of OP’s, carbamates, and pyrethroids. Producers were relying heavily on 

neonicotinoids (thiamethoxam, imidacloprid), but now some populations are expressing 

reduced sensitivity to those products. In addition, the actual seasonal AI/acre of 

neonicotinoids further restricts product availability. In order to obtain some level of 

population management, there has been an increase in rates to the highest dose labeled for a 

single application. Tarnished plant bug management in many Mid-South fields has 

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

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

on the stages of crop protection, cotton producers and pest management practitioners are in 

crisis phase with tarnished plant bug. The subsequent step is that of the disaster phase 

which would result in a collapse of the existing pest management system for Mid-South 

cotton. 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 Arkansas.

SECTION 166.20(a) 11: 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 risk to endangered or 

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

accordance to the section 18 use directions. 

• See Attachment 5 – Endangered and Threatened Species List 2014
26

SECTION 166.20(a) 11: DISCUSSION OF SIGNIFICANT ECONOMIC LOSS

TIER 1 ANANLYSIS

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

impact on Mid-South cotton during the past 5 years. In these areas, specifically in the delta 

regions of Arkansas, Louisiana, and Mississippi, it has been ranked the number one most 

yield limiting pest over the last several years (Williams 2008-2015). In 2007, control cost 

for tarnished plant bug in the Mid-South was at least three-fold greater than the national 

average control cost. In a comparison of recent years it is obvious

Tables 7 and 8 show a comparison of yields from the emergency period (Pre Transform) 

and the non-emergency period (Post Transform) for the state of Arkansas. Since Transform 

became available it is clear that yields have increased (17.1%) and overall plant bug 

applications have increased (94%). This information supports the criteria for emergency 

exemption under Tier 1 analysis for the state of MS.

Table 7. Arkansas Losses due to Tarnished Plant Bug by Year

Year

Cotton 

acreage

% 

acreage 

treated 

for TPB

Average no. 

applications 

targeting 

TPB

Average 

cost ($) 

per 

treatment

Average 

total cost 

($/acre)

Average 

% yield 

loss

Average 

yield 

(pounds 

per acre)

Prior to introduction of sulfoxaflor

2008 640,0001 842 1.882 $6.752 $12.692 1.44%2 1,0121

2009 520,000 90 2.88 $7.01 $20.18 2.79% 818

2010 537,000 92 2.80 $6.45 $18.06 2.74% 1,045

2011 620,000 100 4.35 $7.01 $30.48 3.42% 929

Averages 579,250 91.5% 2.98 $6.81 $20.35 2.60% 951

Post introduction of sulfoxaflor

2012 580,000 99 5.13 $9.00 $46.18 4.00% 1,064

2013 318,000 100 6.00 $9.00 $54.00 5.00% 1,133

2014 316,000 100 6.00 $7.00 $42.00 3.83% 1,145

2015 205,000 100 6.00 $7.34 $44.06 3.92% 1,112

Averages 354,750 99.8% 5.78 $8.09 $46.56 4.19% 1,114

Percent change (pre-sulfoxaflor vs. post sulfoxaflor)

-38% 9.1% 94% 18.8% 128% 61.2% 17.1%

1

Average yields based on NASS survey data for Arkansas, 

http://www.nass.usda.gov/Statistics_by_State/Arkansas/index.php

2

Application costs based on Mississippi State University Beltwide Cotton Losses archive, 

http://www.entomology.msstate.edu/resources/cottoncrop.asp
27

Table 8. Analysis of yield, cost and revenues for Arkansas.

Yield 

(pounds 

lint/acre)

Costs 

($/acre) of 

TPB 

applications

Gross 

revenue 

($/acre)

Net revenue 

($/acre) after 

TPB costs

Prior to introduction of sulfoxaflor

2008 1,0121 $12.692 $627.443 $614.75

2009 818 $20.18 $507.16 $486.98

2010 1,045 $18.06 $647.90 $629.84

2011 929 $30.48 $575.98 $545.50

Avg 2008-2011 951 $20.35 $589.62 $569.27

Post introduction of sulfoxaflor

2012 1,064 $46.18 $659.68 $613.50

2013 1,133 $54.00 $702.46 $648.46

2014 1,145 $42.00 $709.90 $667.90

2015 1,112 $44.06 $689.44 $645.38

Avg 2012-2015 1,113 $46.56 $690.37 $643.81

Percent change (pre-sulfoxaflor vs. post-sulfoxaflor)

Change 2012-

2015 162 $26.21 $70.06 $74.54

17.1% 128.8% 17.1% 13.1%

1

Average yields based on NASS survey data for Arkansas, 

http://www.nass.usda.gov/Statistics_by_State/Arkansas/index.php

2

Application costs based on Mississippi State University Beltwide Cotton Losses archive, 

http://www.entomology.msstate.edu/resources/cottoncrop.asp 3

Gross revenue assuming an average cotton price of $0.62 per pound of lint

Table 9. Yield loss associated with Transform compared to commercial standards and 

untreated check in efficacy trial,2015.

Season Total Yield

Treatment Plant Bugs pounds/acre

% 

below

Transform 1.75 oz. 45 4157

UTC 140 3244.1 -22%

Strafer 3 oz. 61 3307.2 -20%

Centric 2 oz. 75 3387.4 -19%

Centric 2 oz. & Diamond 6 

oz. 65 3426.1 -18%

Orthene 1 lb. 46 3335.8 -20%
28

Table 10. Yield loss associated with Transform compared to commercial standards 

and untreated check in efficacy trial,2014

Season Total Yield

Treatment Plant Bugs lbs./acre

% 

below 

Transform 1.75 oz. 19 5326.6

UTC 149 2499 -53

Bidrin 6 oz./acre* 38 4237.9 -20

Brigade 5.6 oz./acre* 70.4 3598 -32

Sivanto 14 oz./acre 85 2804.8 -47

Vydate C-LV 10.7 oz./acre 51 3151.8 -41

DoubleTake 4 oz./acre 143 2473.8 -54

SUMMARY OF ANALYSIS

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

past 4 years, this pest infested virtually 100% of the planted acreage in Arkansas (Table 7). 

Direct losses from this pest in Arkansas indicate an average of 4.19% yield loss in spite of 

spending an average $46.56/acre per year for control. This should be considered a 

conservative estimate because currently there is no alternative strategy which can be used 

to eliminate crop damage and cotton yield losses from tarnished plant bug. Based on the 

average for the last 4 years Arkansas’s historical insect losses and yield data, producers 

spent over $16.5MM with an estimated cost of control and yield loss of $34.8MM. These

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

http://www.entomology.msstate.edu/resources/tips/cotton-losses/ data. However, as shown 

in Table 8, cotton acreage was reduced by 38%, the percentage of acreage treated increased 

dramatically and the number of applications has almost doubled. The average cost of 

control has increased and the total cost of control for plant bugs has more than doubled. 

While yields have increased they certainly have not kept up with the cost of control and 

associated loss from tarnished plant bug.

Two studies, one in 2014 and one in 2015 clearly show the level of control and impact on 

yield that Transform has compared to other standard insecticides (Tables 9 &10). A 20 to 

32% yield loss for all standards compared to Transform. The above referenced information 

on the analysis required by EPA for emergency exemption clearly demonstrates that all 

criteria are met for sulfoxaflor in the state of Arkansas. These data also demonstrate that 

since Transform has become available for use in cotton, Arkansas producers have benefited 

greatly both in terms of gross revenue and increased yield protection. Furthermore, during 

the 4 year period that Transform has been used, there have been no reports of bee kills 

associated with this product and our largest commercial bee keepers support the Section 18 

for Transform (Attachments 2 & 3). 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.
29

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

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

costs due to the emergency;

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

of the problem and magnitude of costs and yield losses associated with tarnished plant bugs 

in cotton.

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

reasonably anticipated in the absence of the emergency;

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

of the problem and magnitude of costs and yield losses associated with tarnished plant bugs 

in cotton.

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

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

economic viability of cotton across Arkansas and the rest of the Mid-South region. Use of 

the available products in the recommended chemical control strategy is not economically 

feasible, sustainable, or environmentally friendly. During the anticipated conditional 

Section 18 registration period (2011), sulfoxaflor has the potential to mitigate the 

substantial financial losses, and become part of a holistic IPM program for cotton growers. 

Summary:

The Current Situation Producers are Facing in Cotton Producing Areas in Arkansas

The 2014 and 2015 season resulted in even higher pressure from tarnished plant bug 

resulting in another increase in the average number of applications required to attempt an 

acceptable level of control for tarnished plant bug. Cost of control went from over $30 per 

acre to about $43 per acre the last two years. No other pest comes close to the loss 

associated with this pest. Unlike Mississippi that has easily defined areas like the Hills vs 

Delta, in Arkansas we have only Delta and within the Delta are areas where plant bugs are 

not as much of an issue and others where plant bugs are very bad, this is confounded by the 

fact that both types of areas can and do occur in the same county or area. We need every 

tool we can get to manage this tarnished plant bug issue, at the same time we do not want 

to cause harm to the environment. However, there is no threat with sulfoxaflor. Tarnished 

plant bug represents a real threat to the producers in the Midsouth. I would much rather 

have two or three applications of sulfoxaflor than four or five of an organophosphate.

Sulfoxaflor (Transform) has been used by producers in Arkansas and the Midsouth since 

2012 in cotton for control of tarnished plant bugs. Since its introduction, Transform has 

reduced overall tarnished plant bug applications and provided significant yield increases 

and returns in gross revenues. Transform is considered a foundational product in Arkansas 
30

and the Midsouth cotton IPM programs in cotton due to its safety on beneficial insects. 

Since 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. 

Furthermore, studies by Whalen et al. (2015) indicate that in mid-south agroecosystems 

cotton is not a preferred foraging host.

References used to support previous statements and Section 18 request:

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

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

Characterization of Sulfoxaflor, a Novel Insecticide. 2010. Pest Mgmt. Sci. (In press, See 

Appendix C).

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

/newsletters/pests/cis/index.html.

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

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

Conf., National Cotton Council, Memphis, TN. 

Copes, J. T., G. L. Snodgrass, J. Sharp, B. R. Leonard, D. R. Ring, and D. Blouin. 2010. 

Acephate resistance is widespread in Louisiana tarnished plant bug populations. La. Agric. 

53: 14-15.

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

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

Stewart, and K. Tindall. 2008. Strategies for managing tarnished plant bugs in cotton. 

Miss. State Univ. White Paper Recommendations Report, 4 pp. released April 2008. 

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, B. R. 

Leonard, J. W. Sharpe, E. Burris and K. A. Fontenot. 2010.Summary of tarnished plant 

bug efficacy trials in Louisiana 2007-2009. Proc. Beltwide Cotton Conf. 817-819. 

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

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

control in Louisiana cotton, p. 1170. In Proceedings, 2010 Beltwide Cotton Conferences, 

National Cotton Council, Memphis, TN.
31

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

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

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

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

Cotton Incorporated Seminar, Memphis, TN (November 9-11, 2010) See Appendix A.

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

bug, pp. 56-59. In Proc. Beltwide Cotton Res. Conf., National Cotton Council, Memphis, 

TN.

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

Determining Resistance Levels in Tarnished Plant Bug Populations to Neonicotinoid 

Insecticides. Southwestern Entomologist 33: 173-180. 

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.

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

Richburg. 2010. Performance of Dow AgroSciences’ Sulfoxaflor insecticides against 

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

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

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

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

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

and Biochemistry of Sulfoxaflor: A Novel Sap-Feeding Insecticide. J. Agric. Food Chem. 

(Accepted for publication, See Appendix C).