1 SPECIFIC EXEMPTION REQUEST

40 CFR 166.20 SUBPART B

USE OF COUNTER 20G FOR CONTROL OF SOUTHERN ROOT KNOT NEM A TODES ON COTTON IN GEORGIA

FEBRUARY 21, 20142 TABLE OF CONTENTS

Identity of Contact Persons .......................................................................... 3
Description of the Pesticide .......................................................................... 3
Description of the Proposed Use ..................................................................... 4

Alternative Methods of Control ..................................................................... 5
Effectiveness of Proposed Use ...................................................................... 8
Expected Residue Levels in Food .................................................................. 10

Discussion of Risk Information ..................................................................... 1 3
Coordination with Other Affected Federal or state agencies .................................... 19
Acknowledgement by Registrant .................................................................... 19
Enforcement Program

................................................................................. 19
Repeated Uses .......................................................................................... 2 0
Progress Towards Registration ....................................................................... 2 0
Nature of the Emergency .............................................................................. 2 0
Appendix A

- Emergency Exemption Draft Label .................................................. 2 3
Appendix B

- Counter 20G Feder al Label ............................................................ 2 6
Appendix C

- Registrant Acknowledgement .........................................................4 1
Appendix D

- Efficacy Data ............................................................................ 4 33 IDENTITY OF CONTACT PERSONS AND QUALIFIED EXPERTS (166 .20 (a)(1) )

Contact Persons:

Mr. Eric Olson, Pesticide Program Manager Section 18 & 24(c) Registration Georgia Department of Agriculture 19 M.L.K. Jr. Drive SW Room 410 Atlanta, GA 30334 Telephone : 404

- 656

- 4958 Fax: 404

- 657

- 8378 Qualified Experts:

Dr. Robert C. Kemerait, Jr. Professor and Extension Specialist Department of Plant Pathology University of Georgia 2360 Rainwater Rd. Tifton, GA 31793

- 5766 Telep hone: 229

- 386

- 3355 Fax: 229

- 386

- 7415

Dr. Ned French Product Development Manager, Southern Region AMVAC 1520 0 Burlingame Road Little Rock, AR 72223 Telephone: 501

- 258

- 0488

Mr. Chris Davis Regulatory Product Manager AMVAC 4695 MacArthur Court, Suite 1200 Newport Beach, CA 92660 Telephone: 949

- 221

- 6144 Fax: 949

- 261

- 2712

DESCRIPTION OF THE PESTICIDE REQUESTED (166.20(a)(2))
Common Chemical Name (Active Ingredient):
Terbufos (CAS No. 13071

- 79

- 9) ( S

- [[(1,1

- dimethylethyl)thio]methyl]0,0

- diethyl phosphorodithioate )4 Trade Name and EPA Registration Number:
Counter 20G Systemic Insecticide/Nematicide EPA Reg. No. 5481

- 562
(See Appendix B for a copy of the Counter 20G label)
% Active Ingredient:

20% terbufos

Manufacturer:
AMVAC Chemical Corporation

Other Pesticide Products:

None in the formulation
DESCRIPTION OF PROPOSED USE (166.20(a)(3) )

Sites to be treated and their location within the state:
The insecticide will be restricted to use on cotton fields within the state of Georgia for the purpose of controlling southern root knot nematode, Meloidogyne incognita

. Such use in cotton will be restricted to the following cotton

- producing counties: Appling, Atkinson, Bacon, Baker, Ben Hill, Berrien, Bleckley, Brooks, Bulloch, Burke, Calhoun, Candler, Clay, Coffee, Colquitt, Cook, Crisp, Decatur, Dodge, Dooly, Early, Em anuel, Grady, Houston, Irwin, Jeff Davis, Jefferson, Jenkins, Johnson, Lanier, Laurens, Lee, Macon, Miller, Mitchell, Montgomery, Pierce, Pulaski, Randolph, Screven, Seminole, Sumter, Tattnall, Telfair, Terrell, Thomas, Tift, Toombs, Turner, Ware, Wayne, W heeler, Wilcox, and Worth. ( http://www.georgiacottoncommission.org/images/E0010401/2012_MAP.pdf ).
Method of Application:

At

- planting treatment will be applied in

- furrow during operation of planting cotton.
Rate of Application:

5

- 10 lbs. Counter 20G per acre (1.0

- 2.0 lbs. a

. i

. /acre)
Maximum Number of Applications:
One application per acre per year
Total Acreage to be Treated:5 Georgia planted 1,600,000, 1,290,000, and 1,370,000 acres of cotton in 2011, 2012, and 2013, respectively. ( http://usda01.library.cornell.edu/usda/current/CropProdSu/CropProdSu

- 01

- 10

- 2014.pdf ). In a survey of cotton fields by county agents in 2002, 69% of fields were infested with root knot nematodes. ( http://www.ugacotton.com/vault/file/2014

- UGA

- Cotton

- P roduction

- Guide.pdf ). During 2014, Georgia could potentially treat 300 ,000 acres.

Total Amount of Product to be Used:
The rate and number of acres treated is not certain at this time because it is dependent on pest pressure. However, no single application would exceed the maximum use rate of 10 lbs. Counter 20 G per acre (2.0 lb. a

. i

. /acre)

. Any Applicable Restrictions Which Do Not Appear on the Labeling:
All applicable restrictions and requirements will appear on the C ounter 20G package and section 18 labels.
The Duration of the Proposed Use:
April 15 to July 1, 2014

Earliest Possible Harvest Dates:
September 1, 2014

ALTERNATIVE METHODS OF CONTROL (166.20(a)(4) )

a. Detailed explanation of why the currently registered product(s) are not available for the proposed use , i

. e . in adequate supply and/or are not effective to the degree needed in this emergency.
Three core options are available for management of nematodes in cotton: crop rotation, host plant resistance, and nematicides. Each of these is discussed below.
Crop Rotation: Rotation to non

- host crops is a tactic that can be practiced to manage nemat ode populations, but is not always economically feasible or agronomically possible. Soybeans, cotton, and corn are hosts of southern root knot nematode (RKN), while peanuts are not. Rotating to a non

- host crop can lower densities of southern root knot ne matode but does not eliminate the threat of root damage in subsequent crops. Certain fields for specific production reasons cannot be rotated regularly.6 Host

- Plant Resistance : Progress is being made in the development of cotton lines expressing some lev el of host tolerance to RKN; this offers limited tolerance, but is only available in a few cultivars.
Nematicides: Several nematicide and nematistatic products have been recommended for control of southern root knot nematode in cotton. Overall perform ance and availability varies widely among products.

Telone® II: The fumigant Telone II is efficacious against RKN; however, supplies of this material are reported to be limited and generally allocated to higher value markets in fruits and vegetables. F urther, the price of Telone II (3 gal/A at $18/gal = at least $54/A) is considered to be prohibitively expensive by cotton producers.

Temik® 15G: Temik 15G (aldicarb) was routinely used to manage nematodes in Georgia cotton fields until the registratio n was voluntarily discontinued by Bayer CropScience. In 2011, approximately 35% of the cotton acreage in Georgia was treated with Temik 15G at a use rate from 5 to 7 lb ./A (Williams

- Woodard 2011). Since then, aldicarb has not been available to cotton gro wers by an alternative manufacturer. On December 22, 2011 US

- EPA approved registration of M eymik 15G (aldicarb) by AgLogic, LLC ( http://www.aglogicchemical.com/ ); however, no clear and favorable indications have been made regarding the manufacturing or availability of M eymik 15G since that announcement. Dr. Scott Stewart (University of Tennessee) commented “Way back in December of 2011, I posted the article belo w. It continues to receive a good number of hits, particularly from areas that traditionally used a lot of Temik. So it seems time for an update. Unless something changes quickly, it appears that no Meymik will find its way into the supply chain in 2013 . It is unclear if or when Meymik will actually be introduced into the U.S. marketplace. Thus, aldicarb does not appear to be an option for the 2013 cropping season unless you have access to old supplies of Temik” (Stewart 2013).
Statements regarding t h e loss of Temik® 15G in cotton:

• “If Temik 15G were lost, all cotton producers would be forced to use short residual seed treatments, plus a follow

- up organophosphate foliar spray for thrips.”

– Dr. Jack Bacheler, North Carolina State University ( http://www.aglogicchemical.com/Industry_Support.html ).

• “...2011 production losses due to the absence of aldicarb are valued at $816 million.”

– E. Keith Menchey, Manager, National Cotton Council S cience & Environmental Sciences. ( http://www.aglogicchemical.com/Industry_Support.html ).

• “Since Temik's 2011 removal from the marketplace, nematode control in cotton has grown more challenging.” C. Johnson ( http://dtnpf

digital.com/article/Nematode+Nemesis/1563182 /184326/article.html ).

Seed Treatments: Aeris TM Seed Applied Insecticide/Nematicide (thiodicarb), Avicta® Complete Cotton (abamectin), and Poncho®/Votivo® (Bacillus firmus I

- 1582) are seed treatment products registered for use to suppress nematodes in cotton (nematicide active ingredient indicated in parentheses). In situations of relatively low nematode infestations, “seed treatment nematicides may prove sufficient protec tion” (Overstreet & Kirkpatrick 2011). The overall performance of7 seed treatments for nematode management can be classified as weak based on a sampling of comments from experts in the field cotton production and nematology.

• “At lower nematode populations , both Avicta and Aeris can be comparable in efficacy to Temik 15G at 5 lb./A for management of nematodes. As nematode populations increase, Temik 15G at 5 lb./A provided better early season management of southern root knot nematode and increased yields o ver seed treatments.” (“2014 Georgia cotton production guide,” 2014).

• According to Dr. Tom Allen, Extension Plant Pathologist, and Darrin Dodds, Extension Cotton Specialist, in Mississippi, “Seed treatment nematicide products are available for applicati on to cotton seed. However, the products that are commercially available are best placed in situations where low to moderate numbers of nematodes are present” (Allen & Dodds 2012).

• “With seed treatments, you get convenience, but you don’t get superior c ontrol. You don’t get superior thrips control. You don’t get superior nematode suppression. I’d rather have 5 pounds of Temik.” Steve Brown, former Georgia Extension Specialist for cotton ( Golden 2006 ) .

• In the article “Farming Cotton Without Temik,” Texas A&M Agricultural Scientists David Kerns (former Extension Entomologist), Jason Woodward (Extension Plant Pathologist), and Terry Wheeler (Research Plant Pathologist), note tha t Aeris “offers limited activity under low populations [of nematodes] at the current use rate,” Avicta “offers suppression of low populations,” and Votivo appears “to be less effective than Aeris, and when combined with Aeris, it has not improved performan ce over Aeris alone” (Kerns et al. 2011).

• “However, having talked with a number of plant pathologists, Temik at 5 lb. per acre performs better where nematode problems are more substantial. So they are concerned that current seed treatments are not adequa te” (Steward 2013).
Research evaluations of nematicide seed treatments have demonstrated limited performance against root

- knot nematodes (RKN).

• Based on an evaluation of 20 field trials conducted in TX (12) and AL (8) between 2004 and 2010, Wheeler et al. found that aldicarb averaged significantly fewer RKN galls per root system compared with the untreated check or nematicide seed treatments (Aeris and Avicta Complete Cotton). Root galling observed with the seed treatments was equal to or greater than the untreated check.

• In a trial that included multiple rates of Telone, treatments that included Telone averaged significantly fewer RKN per cm 3 compared with the untreated control and Avicta Complete Cotton (Overstreet 2012). Telone alone and followed by Avicta Complete Cotton significantly lowered final root

- knot nematode populations compared with untreated control, and Avicta Complete Cotton without Telone II averaged more RKN per 500 cm 3 than the untreated control (Overstreet et al. 2013).

• Cattaneo et al. (2011) demonstrated that root galling by RKN was significantly lowered by Temik at 5.5 and 7.5 lbs. per acre, and Aeris® averaged greater galling than the untreated control.

• In a trial located in central Alabama (Lawrence et al. 2011), seed treat ments did not significantly lower RKN gall ratings or eggs per gram of root, and Poncho+Votivo at 12.7 oz. per cwt seed provided a 24% reduction in RKN egg relative to the untreated control. This was the largest reduction observed for seed treatments eval uated, which included Votivo, Aeris, and Avicta.8 • Faskes and Starr (2007) found that RKN root gall ratings for abamectin (nematicide active ingredient in Avicta) and untreated cotton were not significantly different at 21, 28, or 35 days after planting.

b. Detailed explanation of why alternative practices, if available, either do not provide adequate control or would not be economically or environmentally feasible.
Tactics of crop rotation, host plant tolerance, and nematicides are available tools for use against plant parasitic nematodes in cotton. Crop rotation is a tool with merit, but does not eliminate the problem of root

- knot nematodes in cotton, and further, crop rotation is not feasible on all fields. Progress is being made with breeding cotton plants that exhibit limited tolerance to nematodes; however, under moderate to severe nematode pressure, nematodes can generate considerable stress to cotton plants. Nematicides include aldicarb, Telone, and seed treatments. Te lone is very expensive and has very limited availability in areas that produce cotton, aldicarb is not available to growers, and seed treatments offer nematode suppression against light populations. All of these practices are currently being implemented t o manage RKN in cotton. However, except for Telone, the available tactics collectively offer limited suppression of RKN.

EFFICACY OF THE USE PROPOSED UNDER SECTION 18 (166.20(a)(5))

C ounter ® 20G S ystemic I nsecticide

- N ematicide (EPA Reg. No. 5481

- 562 ) has been evaluated for many years, particularly in corn which is a registered use, and in recent years, C ounter 20G has been tested in field experiments in cotton for management of nematodes and thrips. C ounter 20G is an organophosphate insecticide whic h offers a new mode of action for managing difficult to control root

- knot nematode in cotton. Note: all tables and figures referenced here are in Appendix D

.
COUNTER 20G AND ROOT KNOT NEMATODES

OVERVIEW: Historical review of trial data with C ounter 20G on cotton.

• 2011: C ounter at 6.5 to 8 lbs. product (20G)/A performed similarly to Temik and was more efficacious against southern root knot nematode, Meloidogyne incognita, than 4 to 6 lbs. /A of C ounter or Avicta Complete.

• 2013: Nematode findings were variable by location, by sampling period, and among treatments, which is one of the challenges with nematode research. C ounter applied in

- furrow offered reductions in nematodes.

GREENHOUSE: In greenhouse trials conducted by Lawre nce, Moore, and Lawrence in 2011, 500 cc of autoclaved soil mix was inoculated with 5,000 vermiform life stages and eggs of reniform or root

- knot nematode, and nematodes were extracted 45 to 60 days after planting. C ounter and Temik were highly efficaciou s against root knot nematode (Figure 2); C ounter averaged the lowest reniform nematode counts among all treatments, and Avicta was not significantly different from the untreated control (Figure 3).9 FIELD TRIALS: In replicated, small plot field trials co nducted in 2011 and 2013, nematode evaluations were recorded following at

- planting, in

- furrow treatment with C ounter 20G at use rates from 4 to 10 lbs. /A.

2011: Results from trial locations in AL, AR, SC, and VA document fewer RKN with C ounter at 5.25 to 6.5 lbs./A and Temik at 7 lbs./A compared with the untreated control as well as Avicta Complete, which was not different from the untreated control (Figures 4

- 7). C ounter at a rate of at least 6.5 lbs./A and Temik at 7 lbs./A averaged reductio ns in RKN of 56% and 60%, respectively (Figure 8).

2013: Nematode trials are a significant challenge at best, and 2013 was no exception. Trials ranged from no nematode pressure to very high counts, and some populations crashed between the first and seco nd soil sampling. Consequently, RKN counts contained some undesirable variability. Results from 2013 are depicted relative to the untreated control, which is set to equal a baseline of 100%. A decline in percentage below 100% indicates some control or a reduction in RKN compared with the untreated control. In 2013, trials emphasized comparing at

- planting granular nematicides, and seed treatments were not included.
Based on locations with adequate nematode densities in trials from 2013, in

- furrow trea tments of C ounter at 5 and 10 lbs./A were efficacious against RKN. Temik averaged the largest reduction among treatments applied in

- furrow but is no longer available to growers. At approximately 30 days after plant emergence (DAE), Temik at 7 lbs./A had the lowest percentage (10%) of RKN relative to the untreated control, but C ounter at 5 and 10 lbs./A averaged 34% RKN, which was a substantial decline in nematode numbers (Figure 9). By 60

- DAE, performance of nematicide treatments was similar (24 to 36%) and favorable with the lowest value for Temik at 7 lbs. /A followed by C ounter at 10 lbs. /A and then 5 lbs

. /A (Figure 10).

COUNTER 20G AND THRIPS In trials from 2013 that were separate from nematode field trial experiments, C ounter 20G was evaluated again st thrips infesting cotton during early season. In a series of 8 replicated, small plot field trials located across the southern US (GA

- 1, MS

- 1,NC

- 3, TN

- 1, and TX

- 2), C ounter 20G at 5, 6.5, and 10 lbs. per acre was compared with Temik at 5 lbs. per acre and an untreated control. Up to 30 days after planting, control of immature thrips was generally good, particularly given that 4 of 8 locations had very heavy thrips pressure (>100 thrips per 5 plants). C ounter (5, 6.5 or 10 lbs. /A) r esults were similar to Temik. Crop injury was not observed with any soil insecticides. On average, differences in plant stand were small, and plant measurements were neutral to positive. Plant ratings for plant vigor and height increased with C ounter and mirrored findings with Temik at 5 lbs. per acre. S ummary chart s of these experiments against tobacco thrips can be provided upon request.

SUMMARY: Based on greenhouse and field trial evaluations of C ounter 20G in 2011 and 2013, the efficacy of C ounter against root

- knot nematode was similar to but slightly less than that observed with Temik 15G at 7 lbs. per acre. C ounter at 6.5 to 10 lbs./A applied in

- furrow at planting is often more efficacious for nematode management compared with rates less than 6. 5 lbs./A. Furthermore, when applied under a nematode

- active seed treatment such as Avicta,10 Poncho, or Aeris, C ounter at 6.5 lbs./A in

- furrow should provide a beneficial enhancement of nematode management.

EXPECTED RESIDUE LEVELS IN FOOD (166.20(a)(6) )
Residue trials were conducted on cotton in the U.S. using terbufos at application rates ranging from 1.5 lb a

. i

. /A to 10.2 lb a

. i

. /A. The proposed Section 18 label rate is 2 lb. ai/A and well within the range of rates tested. . These studies demonstrat e that even under exaggerated conditions there are no quantifiable residues on cotton; therefore there would not be anticipated residues in processed cottonseed oil. On this basis, a single tolerance of 0.05 ppm the Level of Quantitation (LOQ) for terbufo s would be warranted.
The residue chemistry program was conducted in all of the major cotton growing regions of the United States. No measureable residues were found using either band or furrow treatments for two distinct formulations. The proposed Secti on 18 label similarly is only for a single application at planting. The description and results of those residue trials are in the table below.1112 R eferences:

1/ Roman, M.; Zummo, G.; RES

- 356; Counter® terbufos (CL 92,100/15G): Residues of Total CL 92, 100

- Related Compounds in Cottonseed (IF, BAND; MS, 1986) (C

- 2997); Study conducted by American Cyanamid Company, Agricultural Division, Princeton, NY 08540; reported on 11/05/87.

2/ Leonard, R.; RES

- 409; CL 92,100 (terbufos/XL): Residues of CL 92,100

- Related Compounds in Cotton (AT PLANTING; MS, 1988); Study conducted by American Cyanamid Company, Agricultural Division, Princeton, NY 08540; reported on 08/30/91.

3/ Leonard, R.; RE S

- 411; CL 92,100 (terbufos/XL): Residues of CL 92,100

- Related Compounds in Cotton (AT PLANTING; GA, 1988); Study conducted by American Cyanamid Company, Agricultural Division, Princeton, NY 08540; reported on 09/09/91.

4/ Leonard, R.; RES

- 406; CL 92,100 ( terbufos/15G): Residues of CL 92,100

- Related Residues in Ginned Cottonseed After Application at the Maximum Labelled Use Rate (AT PLANTING; AR, 1990); Study conducted by American Cyanamid Company, Agricultural Division, Princeton, NY 08540; reported on 08/ 30/91.

5/ Leonard, R.; RES

- 407; CL 92,100 (terbufos/15G): Residues of CL 92,100

- Related Residues in Ginned Cottonseed After Application at the Maximum Labelled Use Rate (AT PLANTING; LA, 1990); Study conducted by American Cyanamid Company, Agricultural Di vision, Princeton, NY 08540; reported on 08/30/91.

6/ Leonard, R.; RES

- 410; CL 92,100 (terbufos/XL): Residues of CL 92,100

- Related Compounds in Cotton (AT PLANTING; TX, 1988); Study conducted by American Cyanamid Company, Agricultural Division, Princeton, NY 08540; reported on 08/30/91.

7/ Roman, M.; Zummo, G.; RES

- 357; Counter® terbufos (CL 92,100/15G): Residues of Total CL 92, 100

- Related Compounds in Cottonseed (IF, BAND; TX, 1986) (C

- 2997); Study conducted by American Cyanamid Company, Agricultural Di vision, Princeton, NY 08540; reported on 11/05/87.

8/ Roman, M.; Zummo, G.; RES

- 358; Counter® terbufos (CL 92,100/15G): Residues of Total CL 92, 100

- Related Compounds in Cottonseed (IF, AZ, 1986) (C

- 2997); Study conducted by American Cyanamid Company, Agr icultural Division, Princeton, NY 08540; reported on 11/06/87.

9/ Leonard, R.; RES

- 408; CL 92,100 (terbufos/XL): Residues of CL 92,100

- Related Compounds in Cotton (AT PLANTING; CA, 1988); Study conducted by American Cyanamid Company, Agricultural Division , Princeton, NY 08540; reported on 08/30/91.
DISCUSSION OF RISK INFORMATION (166.20(a)(7) )
Dietary Risk from Foods:13 As reported in the previous section, a cottonseed tolerance of 0.05 ppm the Level of Quantitation (LOQ) for terbufos would be warranted. Assuming that a tolerance value of 0.05 ppm is also used for cottonseed oil, the following tables demonstrate that the incremental risk is negligible and no dietary risk exceedances for food items would occur.

Comparison of Acute 99.9th Percentile Exposures (as % of aPAD of 0.0003 mg/kg/d)

– FOOD ONLY Assumes 100% crop treated.

Population Groups Baseline Cotton

U.S. Population 17.50% 17.60%

All Infants 28.60% 28.60%

Children 1

- 2 yrs 35.80% 36.00%

Children 3

- 5 yrs 33.80% 34.00%

Children 6

- 12 yrs 22.00% 22.20%

Youth 13

- 19 yrs 11.80% 11.80%

Adults 20

- 49 yrs 11.30% 11.40%
Adults 50+ yrs 9.60% 9.70%

Females 13

- 49 yrs 11.80% 11.90%14 Comparison of Chronic Exposures (as % of cPAD of 0.00005 mg/kg/d)

- FOOD ONLY Assumes 100% crop treated.

Population Groups Baseline Cotton

U.S. Population 1.20% 1.70%

All Infants 3.60% 3.80%

Children 1

- 2 yrs 5.10% 6.10%

Children 3

- 5 yrs 3.00% 4.30%

Children 6

- 12 yrs 1.50% 2.40%

Youth 13

- 19 yrs 0.70% 1.20%

Adults 20

- 49 yrs 0.80% 1.20%
Adults 50+ yrs 1.10% 1.40%

Females 13

- 49 yrs 0.80% 1.20%

Cottonseed hulls, meal and trash can sometimes be used as feed items for livestock. Based on the cotton residue data, even with some concentration, residues would not exceed the proposed 0.05 ppm tolerance being proposed for cottonseed. Further, as these commodities are not as common as feedstock commodities associated with corn, the potential levels of terbufos in animal commodities would not be gre ater than what is already in place; and there would be no associated incremental dietary risk calcu lated based on these feedstocks.
Dietary Risk from Water: In 2006, EPA issued its Reregistration Eligibility Decision for Terbufos. Within this document, the Agency concluded, “The risk reduction measures contained within this IRED, including the limitations on sales of terbufos, reducing the maximum application rate for sorghum, increasing the depth of incorporation of granules into the soil, removal of “o ver

- the

- top applications and the use of vegetative buffer strips between field and water bodies and other areas where water contamination could occur, particularly the use of a 500 foot buffer between treated area and water sources on nearby lands which wo uld include such thing as reservoirs, are expected to provide improved protection of water resources from terbufos contamination. This supports the Agency’s belief that drinking water risks will be reduced to a level at which the risk cup is not exceeded”

.15 Utilizing EPA’s current water exposure modeling (PRZM/EXAMS) in consideration of the terbufos on cotton Section 18, we believe that there would not be a higher exposure or related risk from exposure associated with the cotton use and that the water

- based dietary risk would continue to be based on the sorghum use. As a part of our assessment, we have determined that the counties associated with our Section 18 submission are associated with areas of low aquifer vulnerability. In Figure 1A below is a 2012 map of the major cotton growing belt in Georgia based on information from the Georgia Cotton Commission website. http://www.georgiacottoncommission.org/index.cfm?show=10&mid=5 ) The area within the black polygon represents the major cotton growing regions in Georgia and those counties included in this petition. In Figure 1B is the USGS groundwater vulnerability map (for polar nitrates/nitrites, which would serve as a reasonable surrogate for terbufos sulfoxide and sulfone, the two polar degr a dates of terbufos associated with potential groundwater contamination). http://ga.water.usgs.gov/edu/nitrogen.html The overlay betw een the two maps indicates that in general, the areas of primary cotton use in Georgia are not associated with vulnerable acquifers. Therefore, EPA’s groundwater risk assessment for cotton use in this area would be expected to demonstrate that for this ar ea of the country, there is a lower risk associated with terbufos groundwater contamination, compared to other areas of the country where terbufos is used such as within the midwestern corn growing belt.

Also, provided is Figure 1C, is a 2009

- 2010 map of the major corn growing belt in Georgia based on information provided by from The University of Georgia’s College of Agriculture and Environmental Sciences. http://flacrops.com/wp

content/uploads/2013/04/2013CompleteCornProductionGuideUGA.pdf
By overlaying maps 1A and 1C, it is evident that there is significant correlation between the major cotton and corn growing belts in Georgia. On this basis, aquifers that could potentially be exposed to terbufos from a new use on cotton already have simil ar exposure potential from the registered corn use; so there would not be any new exposure scenario by implementing the Section 18.16 Figure 1 Georgia M aps of Cotton U se, G roundwater Vulnerability and Corn U se

1A17 1B

1C

Within the RED using modeling practices in place at the time, EPA determined that the acute EECs for corn (likely in a more vulnerable setting than Georgia) were 4.8 ppb for groundwater and 8.44 for surface water. Within this assessment, the Agency used t he Index Reservoir (IR) and Percent Crop Area (PCA) modifications to Tier II PRZM

- EXAMS and determined a high range terbufos EEC of 25.5 associated with the sorghum use. The proposed label rate for use on cotton in Georgia is between the currently approve d corn and sorghum rates. So there should not be any significant incremental risk associated with the proposed use. Additionally, the EECs18 associated with cotton use in Georgia would still be lower because the Georgia aquifers are not as vulnerable to gr oundwater exposure as aquifers in the Midwestern part of the U.S. associated with the corn belt. Regardless, the drinking water risk should continue to be based on the already registered sorghum use.

Ecological Risk Assessment and Endangered Species Conce rns:

As provided in the section on dietary risk from water, there is significant overlap between the counties of high use in Georgia for corn and cotton. Corn and cotton would be expected to be planted on similar agricultural soils; therefore no addition al wildlife species should be impacted by the addition of the cotton use of terbufos in the specified counties. In Figure 2 below is a map that includes the state of Georgia. The shaded polygon approximates the use area proposed for the Section 18. This map was developed using the U.S. Fish & Wildlife Service’s computer program IPaC

- Information, Planning, and Conservation System. http://ecos.fws.gov/ipac/ Within this polygon, the program has identified animal and plant species that are endangered, threatened, or a candidate species.

Figure 2. Polygon Representing Terbufos on Cotton Section 18 Proposed Use Area19 Included within the polygon are the following counties: Houston, AL | Russell, AL | Appling, GA | Atkinson, GA | Bacon, GA | Baker, GA | Baldwin, GA | Ben Hill, GA | Berrien, GA | Bibb, GA | Bleckley, GA | Brooks, GA | Bulloch, GA | Burke, GA | Calhoun, GA | Candler, GA | Chattahoochee, GA | Clay, GA | Clinch, GA | Coffee, GA | Colquitt, GA | Colu mbia, GA | Cook, GA | Crawford, GA | Crisp, GA | Decatur, GA | Dodge, GA | Dooly, GA | Dougherty, GA | Early, GA | Emanuel, GA | Evans, GA | Glascock, GA | Grady, GA | Greene, GA | Hancock, GA | Houston, GA | Irwin, GA | Jeff Davis, GA | Jefferson, GA | Je nkins, GA | Johnson, GA | Jones, GA | Lanier, GA | Laurens, GA | Lee, GA | Lincoln, GA | Lowndes, GA | Macon, GA | Marion, GA | McDuffie, GA | Miller, GA | Mitchell, GA | Monroe, GA | Montgomery, GA | Peach, GA | Pulaski, GA | Putnam, GA | Quitman, GA | Ra ndolph, GA | Richmond, GA | Schley, GA | Screven, GA | Seminole, GA | Stewart, GA | Sumter, GA | Talbot, GA | Taliaferro, GA | Tattnall, GA | Taylor, GA | Telfair, GA | Terrell, GA | Thomas, GA | Tift, GA | Toombs, GA | Treutlen, GA | Turner, GA | Twiggs, GA | Upson, GA | Warren, GA | Washington, GA | Webster, GA | Wheeler, GA | Wilcox, GA | Wilkes, GA | Wilkinson, GA | Worth, GA | Aiken, SC | Allendale, SC | Barnwell, SC.
With the proposed Sec 18 for use on cotton, no new species would be impacted due to t he high degree of overlap between corn and cotton uses in this state. In fact it is quite likely that there is no increased exposure within this area based on the fact that cotton and corn plantings are frequently rotated.
Because the region in Georgia associated with the Section 18 for terbufos on cotton does not contain areas that are very vulnerable to groundwater contamination and with the imposition of a 500 foot buffer to minimize runoff potential, the requirement that product be applied in a close d system and the timing of the application is at planting the environmental risk to aquatic species of plants, birds and animals should be adequately addressed with the currently approved uses on

corn. Occupational Risk:

Counter 20G is sold in Lock

- N

- Lo ad closed systems. Therefore, the worker risk assessment that EPA conducted for the use of Counter 20G on corn would be protective of the proposed cotton

use. The Sectio n 18 would also use the same 48

- hour Restricted Entry Interval on the currently approv ed Counter 20G label.

COORDINATION WITH OTHER AFFECTED FEDERAL, STATE AND LOCAL AGENCIES (166.20(a)(8))20 The Georgia Department of Agriculture, Pesticides Division, has state aut hority to carry out operations or measures to detect, eradicate, suppress, control, and prevent or retard the spread of certain plant pests. The Department has closely coordinated these programs with the USDA

- APHIS, as they also have authority in these matters regarding certain plant pe sts.

ACKNOWLEDGEMENT BY REGISTRANT (166.20(a)(9))
The basic manufacturer, A MVAC Chemical Corporation , has been notified of this intended use and supports the state of Georgia’s request for a specific exemption. (See letter in Appendix C ). A copy of thi s exemption request will be provided to the manufacturer for their information and comment.

ENFORCEMENT PROGRAM (166.20(A)(10)
The Georgia Department of Agriculture is the state lead agency for pesticides in Georgia and has been delegated primacy for enfo rcement of FIFRA by the United State s Environmental Protection Agency (EPA). A fully equipped pesticide residue laboratory is available for monitoring residues resulting from applications made under emergency exemptions, and the Department of Pesticide Enf orcement monitors compliance under a reciprocal agreement with EPA.

REPEAT USES (166.20(a)(11)

This is the first emergency exemption request for terbufos on cotton.

PROGRESS TOWARDS REGISTRATION (166.25(b)(2)(ii)
The registrant is participating in this emergency exemption program at the request of the cotton growers of Georgia. If the Section 18 is approved, the registrant will discuss with U. S. EP A a Section 3 submission.

NATURE OF THE EMERGENCY (166.20(c))

a. Name of the pest: All plant parasitic nematodes affecting cotton in Georgia as well as potential for Fusarium oxysporum fsp vasinfectum causal agent of Fusarium wilt.

- Southern root

- knot nematode ( Meloidogyne incognita )21 - Reniform nematode ( Rotylenchus reniformis )

- Columbia lance nematode ( Hoplolaimus columbus )

- Sting nematode ( Belonolaimus sp.)

- Fusarium wilt caused by Fusarium oxysporum fsp vasinfectum is severe when cotton is also affected by plant

- parasitic nematodes.

b. Discussion of the events that brought ab out the emergency
Cotton growers in Georgia have a critical and urgent need for a replacement product for Temik 15G that was voluntarily discontinued by Bayer CropScience. None of the current options are able to fill the void left for managing nematode s

. Use of seed treatment nematicides may actually cost growers more than they return in increased yield. Telone II is an effective fumigant, but is in limited supply today and also adds expense that is not appropriate for fields with lower populations of ne matodes. As remaining stocks of Temik 15G have dwindled to the final remnants, it is critical that growers have access to Counter 20G, a granular insecticide/nematicide to remain profitable in growing cotton where nematodes affect the crop. Results have shown that Counter 20G has significant efficacy in the reduction of nematodes affecting cotton.

Plant

- parasitic nematodes, especially the southern root

- knot nematode and the reniform nematode, cause significant losses to cotton in Georgia every season. Ba sed upon surveys conducted in 2002

- 2004 at the University of Georgia, it is estimated that at least 70% of the cotton acreage in Georgia is infested with the southern root

- knot nematode and at least an additional 5% is infested with the reniform nematode. These nematodes cause significant damage to the cotton crop and directly result in severe yield losses in fields were the crop is not adequately protected.
Historically, aldicarb (Temik 15G) provided the backbone of nematode management for cotton growers in Georgia. This granular insecticide/nematicide was typically used at a rate of 5

- 6 lb. /A as an in

- furrow application; however in severe cases it was also “knifed

- in” on either side of the cotton crop (typically at the “pinhead square” growth stage). Tr eatment with Temik 15G was the standard for both management of plant

- parasitic nematodes and also thrips.

In 201 1 Bayer CropScience, manufacturer of Temik 15G, announced that it would voluntarily discontinue the production of Temik 15G, despite the popular ity of this product among farmers, for example peanut and cotton farmers, in the southern United States. As we enter the 2014 growing season, the availability of Temik 15G has dwindled and is almost absent from the market place now. There is no product o n the market now that adequately fills the void left with the discontinuation of production of Temik 15G.
Despite the significant importance of plant

- parasitic nematodes affecting cotton in Georgia, loss of Temik 15G puts a significant strain o n growers to effectively and economically manage this family of pests. Although new varieties of cotton are being released that have som e level of resistance to the southern root

- knot nematode, such resistance is far from complete and use of nematicides is22 still warr anted. Also, yield potential in the newer, more resistant varieties is not equal to those of the best varieties. I t is important to note that no varieties are currently resistant to the reniform, Columbia lance, or sting nematodes.
Fumigation with Telon e II is an important management strategy for our cotton growers to manage nematodes, however Telone II is not a replacement for the loss of Temik 15G. Telone II is significantly more costly ($60/A versus $15/A) and is less appropriate where nematode popul ations are low

- to

- moderate. The availability of Telone II has been severely restricted over the past few years as the down

- turn in the economy has resulted in a decreased demand for manufacture of plastics, of which Telone II is a by

- product.
Cotton growe rs do have access to seed

- treatment nematicides, such as AVICTA Complete Pak and AERIS Seed

- Applied System. Appropriate where populations of nematodes are low, these products do not compare to Temik 15G (and likely Counter 20G) when applied at more damagi ng levels. In a study presented at the 2007 National Cotton Council, seed treatment nematicide AVICTA Complete Pak was compared to Temik 15G in 25 trials. In 14 of these trials, Temik out

yielded the AVICTA by an average of 119 lb. /A; where the advantage was to AVICTA, AVICTA
out

- yielded the Temik by only an average of 48 lb. /A. Taking into consideration the cost of each product, growers were much more likely to realize a profit with the use of Temik and more likely to lose money with the use of the seed treatment. Aldicarb is no longer available to our growers; however it is very important to bring terbufos (Counter 20G) to the cotton fields of Georgia as an economical and effective replacement. Use of seed

- treatment nematicides is not cost

- effective in many fields. Use of Counter 20G is an important tool for the profitabl e cotton production in Georgia.

c. Discussion of the anticipated economic loss, addressing one or more of the following:

i. Yield anticipated in t he absence of the emergency and expected losses in quality due to the emergency : In 2007, Kemerait presented a paper at the National Cotton Council Beltwide Cotton Conference where results from 25 field trials comparing yields for Temik 15G to the most common seed

- treatment nematicide (AVICTA Complete Cotton) available today. (It is believed that use of Counter 20G will produce results similar to that of Temik 15G.) Twenty

- five data sets were presented in this paper comparing AVICTA Co mplete Pak to Temik 15G, 5.0 lb. /A. AVICTA Complete Pak out

- yielded Temik 15G, 5.0 lb. /A, in 11 of these trials; however only in one of these trials were the yields statistically different. Temik 15G, 5.0 lb. /A, out

- yielded AVICTA in 14 trials; however y ields were statistically different in only one of the 14 trials. The numeric yield advantage to Temik 15G over AVICTA Complete Pak was 119.5 lb. lint/A. The numeric yield advantage to AVICTA Complete Pak over Temik 15G was 48.1 lb. lint/A. Based upon th e cost of treatment and resulting yields, Temik 15G was the more effective product and produced economic return for the growers. Use of AVICTA Complete Pak was much less likely to23 return value to the grower. For this reason, it is critically important fo r growers to have the opportunity to use Counter 20G.

ii. Changes in crop prices due to the emergency : Cotton prices have declined dramatically since 2011 and have suffered a loss of 5.54% since July of 2013. This decline in the price of cotton makes it ever more critical for cotton growers in Georgia to receive a Section 18 Emergency exemption label for Counter 20G to replace use of Temik 15G. Simply put, growers need an alternative to seed

- treatment nematicides that wi ll provide increased efficacy a t c omparable prices.

iii. Changes in operating costs anticipated due to the emergency : N/A

iv. Any other information explaining economic consequences of the emergency : Plant

parasitic nematodes are a significant and constant threat to cotton production in Georgia. Now is the critical time for growers to have the opportunity to transition to use of Counter 20G from Temik 15G.24 

## A PPENDIX A

DRAFT EMERGENCY EXEMPTION USE DIRECTIONS25 RESTRICTED USE PESTICIDE
Due to Acute Oral, Dermal and Inhalation Toxicity and Risks to Aquatic Organisms and Wildlife.
For retail sale to, and use only by Certified Applicators or persons under the direct supervision of a

Certified Applicator, and only for those uses covered by the Certified Applicator's certification.



## COUNTER 20G SYSTEMIC INSECTICDE/NEMATICIDE
SECTION 18 EMERGENCY EXEMPTION
FOR DISTRIBUTION AND USE ONLY IN GEORGIA

DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling.
All applicable directions, restrictions, Worker Protection Standard (WPS) requirements, and precautions of the federally registered product label for C ounter ® 20G Systemic Insecticide

- Nematicide (EPA Reg. No. 5481

- 562), as well as the Section 18 directi ons, must be followed.
This section 18 label contains directions for use that do not appear on the EPA registered label of C ounter 20G Insecticide Nematicide.
This label must be in possession of the use at the time of pesticide application.

Directions for use on cotton

PEST RATE OF COUNTER® 20G SYSTEMIC INSECTICIDE

NEMATICIDE (per acre) REMARKS

Nematodes 1 :

Root Knot 6.5

– 10 lbs. /A Apply granules evenly in

- furrow at planting time directly into the open seed furrow (36 to 40

- inch row spacing) behind the planter shoe and immediately cover with soil by mechanical means, so that granules are completely covered with soil. Soil temperatur e, moisture and tilth should be favorable for good germination and emergence 1 Counter 20G at 6.5 to 10 Thrips 5

– 6.5 lbs. /A26 lbs

. /A suppresses root knot nematodes.

Use Restrictions:

• The maximum single at

- plant application rate is 10 lbs. C ounter 20G /A or 2 lbs. a.i./A.

• Do not apply after planting.

• Crop injury may occur if applications of a urea herbicide (such as Karmex®, Direx®, or Diuron herbicides or fluometuron

- containing herbicides such as Cotoran®) are made in conjunction with soil

- applie d organophosphate pesticides.

• Postemergence ALS

- inhibiting herbicides such as Staple® or Envoke® SHOULD NOT be used if Counter 20G has been applied to cotton at the time of planting.

• Do not graze or harvest cotton within 30 days after at

- planting applica tion.

C ounter is a registered trademark , in the US and some other countries, of AMVAC Chemical Corporation.
Staple is a trademark of E.I. DuPont deNemours and Company.

Cotoran , Direx and Karmex are trademark s of Agan Chemical Manufacturers, Ltd.

Envoke is a trademark of Syngenta Participations AG

. ©2014 AMVAC Chemical Corporation. All Rights Reserved.27 

## APPENDIX B

COUNTER 20G FEDERAL LABEL28 RESTRICTED USE PESTICIDE
Due to Acute Oral, Dermal and Inhalation Toxicity
and Risks to Aquatic Organisms and Wildlife.
For retail sale to, and use only by Certified Applicators or persons under the direct supervision of a

Certified Applicator, and only for those uses covered by the Certified Applicator's certification.

SYSTEMIC I NSECTICIDE

– NEMATICIDE LOCK’n LOAD ® CLOSED LOADING SYSTEM FOR USE IN FIELD CORN (including FIELD CORN containing in

- plant corn rootworm protection traits, such as YieldGard®, Herculex® and Agrisure ® traits), FIELD CORN GROWN FOR SEED, POPCORN, SWEET CORN, SUGAR BEETS, AND GRAIN SORGHUM ACTIVE INGREDIENT: By Weight

Terbufos: S

- [[(1,1

- dimethylethyl)thio]methyl]0,0

- diethyl phosphorodithioate

.......... 20.0%

INERT INGREDIENTS:

................................ ................................ ................................ . 80.0%

TOTAL 100.0%
EPA Reg. No. 5481

- 562 EPA Est. No. 5481

- AL

1

KEEP OUT OF REACH OF CHILDREN 

## DANGER! PELIGRO!

 

## POISON 
Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)29 FIRST AID Organophosphate (a cholinesterase inhibitor)

CALL A PHYSICIAN AT ONCE IN ALL CASES OF SUSPECTED POISONING

If swallowed • Call a poison control center or doctor immediately for treatment advice.

• Have person sip a glass of water if able to swallow.

• DO NOT induce vomiting unless told to by a poison control center or doctor.

• DO NOT give anything by mouth to an unconscious person. If inhaled • Move person to fresh air.

• If person is not breathing, call 911 or ambulance, then give artificial respiration, preferably mouth to mouth if possible.

• Call a poison control center or doctor for further treatment advice. If on skin or clothing • Take off contaminated clothing.

• Rinse skin immediately with plenty of water for 15

- 20 minutes.

• Call a poison control center or doctor for treatment advice. If in eyes • Hold eye open and rinse slowly and gently with water for 15

- 20 minutes.

• Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye.

• Call a poison control center or doctor for treatment advice.

Repeated inhalation or skin contact may, without symptoms, progressively increa se susceptibility to poisoning. Antidote: Atropine is an antidote

EMERGENCY INFORMATION Have the product container or label with you when calling a poison control center or doctor, or going for treatment. Call a physician in all cases of suspected poisoning. If warning symptoms appear, keep patient prone and quiet. Start artificial respirat ion immediately if patient is not breathing. Transport the patient immediately to the nearest hospital.
FOR THE FOLLOWING EMERGENCIES, PHONE 24 HOURS A DAY:
For Medical Emergencies phone:................................................................. ....................................................1

- 888

- 681

- 4261
For Transportation Emergencies, including spill, leak or fire, phone: CHEMTREC.......................................1

- 800

- 424

- 9300
For Product Use Information phone : AMVAC.............................................. ...................................1

- 888

- 462

- 6822

4100 E. Washington Boulevard Los Angeles, CA 90023 1

- 888

- 462

- 682230 NOTE TO PHYSICIANS Warning signs and symptoms include weakness, muscle twitching, headache, tightness in chest, respiratory depression, blurred vision, miosis, hypersecretion, nausea, vomiting, diarrhea, and abdominal cramps. If poisoning is probable, treat the patient immed iately. Clear airway and provide oxygen before administering atropine. Give atropine intravenously (IV), intramuscularly or through an alternative route such as an endotracheal tube. Depending on severity of poisoning, use 2 to 4 milligrams IV in adults (o r 0.05 mg/kg in children under 12 years) every 10

- 15 minutes until fully atropinized as shown primarily by control of pulmonary secretions. Proceed concurrently with decontamination using proper protective gear; for example, chemical

- resistant gloves rathe r than cotton or leather ones. Use soap (preferably, tincture of green soap) and water, or a dilute hypochlorite solution, for decontaminating skin. Maintain atropinization by repeated doses based on recurrence of symptoms. Twenty to thirty milligrams, or more, may be required during the first 24 hours, and preservative

- free atropine preparation should be used if large doses are required. Generally, inducing emesis is not advisable. Avoid opiates, parasympathomimetic agents (e.g. succinylcholine), theophyll ine, reserpine, and or phenothiazines. Suction oral secretions and emesis to avoid aspiration. Artificial respiration or oxygen administration may be necessary. Probable mucosal damage may contraindicate the use of gastric lavage. If not contraindicated, g astric emptying by lavage may be considered after ingestion of a potentially life

- threatening amount if it can be performed soon after ingestion (within an hour). A slurry of activated charcoal may be medically warranted at an oral dose appropriate for adu lt, child, or infant. For seizures, give a benzodiazepine intravenously. Observe patient continuously for at least 72 hours. Allow no further exposure until cholinesterase regeneration has taken place as determined by blood tests.
Pralidoxime chloride (2

- P AM; PROTOPAM chloride) appears to be an effective adjunct to atropine, especially in those severely ill and if given soon. Before it’s administered, obtain a blood sample for cholinesterase analysis. Adjusting for age and weight, pralidoxime may be adminis tered as a continuous infusion after a loading dose or using a bolus method.

PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS DANGER!
Fatal if swallowed, inhaled, or absorbed through the skin. Corrosive. Causes irreversible eye damage. DO NOT get in eyes, on skin, or on clothing. DO NOT breathe dust.
Keep Out of Reach of Domestic Animals.31 WORK SAFETY RULES

REPEATED EXPOSURES TO CHOLINESTERASE INHIBITORS SUCH AS ARE CONTAINED IN THIS PRODUCT MAY, WITHOUT WARNING, CAUSE PROLONGED SENSIT IVITY TO VERY SMALL DOSES OF ANY CHOLINESTERASE INHIBITOR.
Persons working with this product should have frequent blood tests of their cholinesterase levels. If the cholinesterase level falls below a critical point, no further exposure should be allowed un til it has been determined by means of blood tests that the cholinesterase level has returned to normal.
Before using this product, consult the National Pesticide Information Center for recommendations regarding such blood tests, poisoning management, emer gency treatment, and other information regarding the toxicity of terbufos. The toll

- free number for the National Pesticide Information Center is 1

- 800

- 858

- 7378.
If handled indoors, provide mechanical exhaust ventilation.
Keep all unprotected persons, child ren, livestock, and pets away from treated areas or where there is danger of drift.

DO NOT rub eyes or mouths with hands. If you feel sick in any way, STOP work and get help right away. See FIRST AID section.

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Some materials that are chemical

- resistant to this product are those made of waterproof material. If you want more options, follow the instructions for Category A on an EPA chemical

- resistance category selection chart.
Loaders, applicators and other handle rs using engineering controls must wear:

• Long

- sleeved shirt and long pants

• Shoes plus socks

• Protective eyewear In addition to the above, loaders must also wear:

• Chemical

- resistant gloves (such as those made of waterproof material)

• Chemical

- resistant apron

• See engineering controls for additional requirements IMPORTANT: All other handlers performing tasks such as spill clean up or equipment cleaning, for which engineering controls are not feasible must wear:

• Coveralls over long

- sleeved shirt and long pants

• C hemical

- resistant footwear plus socks

• Chemical

- resistant gloves32 • Protective eyewear

• A respirator with an organic

- vapor removing cartridge with a pre

- filter approved for pesticides (MSHA/NIOSH approval number prefix TC

- 23C), or a canister approved for pestic ides (MSH/NIOSH

- approval number prefix TC

- 14G), or a NIOSH

- approved respirator with an organic vapor (OV) cartridge or canister with any N, R, P or HE pre

- filter

• Chemical

- resistant apron if exposed to concentrate Follow manufacturer’s instructions for clea ning and maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. Wash all PPE after each day’s use.

DO NOT reuse contaminated clothing. Clothing and protection equipment he avily contaminated must be destroyed according to state and local regulations. HEAVILY CONTAMINATED CLOTHING CANNOT BE ADEQUATELY DECONTAMINATED.

ENGINEERING CONTROLS This product is formulated into an enclosed system (LOCK’n LOAD®) that meets the definition of a closed loading system in the Worker Protection Standard for Agricultural Pesticides [40 CFR 170.240(d)(4)]. In addition to wearing the required PPE specified above for loaders must be provided, must have immediately a vailable, and must wear in case of a broken package, spill or equipment breakdown: coveralls, chemical

- resistant footwear plus socks, a respirator with either an organic vapor

removing cartridge with a pre

- filter approved for pesticides (MSHA/NIOSH approva l number prefix TC

- 23C) or a canister approved for pesticides (MSHA/NIOSH approval number prefix TC

- 14G) or a NIOSH approved respirator with an organic vapor (OV) cartridge or canister with any N, R, P or HE pre

- filter

. Applicators must use an enclosed cab that meets the definition in the Worker Protection Standard for Agricultural Pesticides for dermal protection. In addition, the applicator:

• Must wear the PPE required for handlers using engineering controls.

• Must either use an enclosed cab that also provi des equivalent respiratory protection to an organic vapor

- removing respirator or wear a respirator with either an organic vapor

- removing cartridge with a pre

- filter approved for pesticides (MSHA/NIOSH approval number prefix TC

- 23G), or a canister approved for pesticides (MSHA/NIOSH approval number prefix TC

- 14G), or a NIOSH

approved respirator with an organic vapor (OV) cartridge, or canister with any N, R, P or HE pre

- filter

.
• Must be provided with, must have immediately available for use, and must wear if they must exit the cab in the treated area: coveralls, chemical

- resistant gloves, chemical

- resistant footwear plus socks, and if using an enclosed cab that provides respiratory protection, respirator with either an organic vapor

- removing cartridge with a pre

- filter approved for pesticides (MSHA/NIOSH approval number prefix TC

- 23C), or a canister approved for pesticides (MSHA/NIOSH approval number prefix TC

- 14G), or a NIOSH approved respirator with an organic vapor (OV) cartridge, or canister with any N, R, P or HE pre

- filter.

• Must take off any PPE that was worn in the treated area before reentering the cab.

• Must store all such PPE in a chemical

- resistant container such as a plastic bag, to prevent contamination inside of the cab.33 USER SAFETY RECOMMENDATIONS
Users Should:

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

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

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. FAILURE TO FOLLOW PRECAUTIONS INCLUDING WEARING PROPER PERSONAL PROTECTIVE EQUIPMENT (PPE) MAY RESULT IN SERIOUS OR EVEN LIFE

- THREATENING POISONING REQUIRING IMMEDIATE MEDICAL ATTENTION. THE ACTIVE INGREDIENT OF THIS GRANULAR FORMULATION CAN BE ABSORBED THROUGH THE SKIN TO CAUSE POISONING

.

ENVIRONMENTAL HAZARDS This pesticide is highly toxic to fish and wildlife and has been known to cause fish kills. Runoff may be hazardous to aquatic organisms in neighboring areas. DO NOT apply directly to water or to areas where surface water is present or to intertidal areas below the mean high water mark. DO NOT contaminate water when disposing of equipment wastewater or rinsate. See DIRECTIONS FOR USE for required buffer zones or setbacks. Birds and mammals may be killed if granules are not properly covered with soil in all areas of the treated field and in loading areas. Cover, incorporate or clean up product that is spilled during loading or that is visible on the soil surface in turn areas.

DO NOT apply in wet soil conditions that may prevent the equipment from covering pe sticide granules. DO NOT apply to frequently flooded areas.
Under certain field and weather conditions, terbufos and its degradates have a potential for runoff into surface water for several weeks following application. Keep out of lakes, ponds, and stream s.

DIRECTIONS FOR USE It is a violation of federal law to use this product in a manner inconsistent with its labeling. DO NOT apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your state or tribe, consult the agency responsible for pesticide regulation. This label must be in the possession of the user at the time of pesticide application.34 AGRICULTURAL U SE REQUIREMENTS
Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, an d handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protectiv e equipment (PPE), notification to workers, and restricted

- entry interval. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard.

DO NOT enter or allow worker entry into treated areas during the restricted entry interval (REI) of 48 hours

. The REI is increased to 72 hours in areas where average rainfall is less than 25 inches a year.
Exception: If the product is soil

- injected or soil

- incorporated, the Worker Protection Standard, under certain circumstances, allows workers to enter the treated area if there will be no contact with anything that has been treated.
PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with any thing that has been treated, such as plants, soil, or water is:

• Coveralls over long

- sleeved shirt and long pants

• Chemical

- resistant gloves made of any waterproof materials

• Chemical

- resistant footwear plus socks

• Protective eyewear Notify workers of the application by warning them orally and by posting warning signs at entrances to treated areas.

PRECAUTIONS AND RESTRICTIONS
BEFORE USING, READ PRECAUTIONARY STATEMENTS AND ENVIRONMENTAL HAZARDS.

• Do not contaminate food or feed products.

• Not for use or stor age in or around home.

• Keep out of reach of Domestic Animals.

• Once a container has been attached to the hopper, it is recommended that it be used completely. Make sure the hoppers are emptied while still in the field. Refer to Storage and Disposal stateme nts for further instructions. Loader and applicator requirements to minimize the potential for runoff to surface water:

• Maintain a 500 ft

. vegetative buffer between treated area and surface water on neighboring land.

• Maintain a 500 ft

. buffer between a standpipe drain outlet and surface water on neighboring land.

• Maintain a 66 ft

. setback between the treated area and entry points to surface water bodies on

non

- highly erodible soils.35 • Maintain a 300 ft

. setback between the treated area an d entry points to surface water bodies on highly erodible soils (HES).

• Maintain a 66 ft

. setback between treated area and standpipes on terraced fields as well as a 66 ft vegetative buffer between the tile outlet and entry points to surface water bodies.
A ll setbacks must be planted to a crop or seeded with grass or other suitable cover, and all vegetative buffers must be seeded with grass or other suitable cover.

DO NOT load, rinse, or wash equipment within 300 ft

. from surface water bodies.

DO NOT load, r inse, or wash equipment within 50 ft

. from wells unless conducted on an impervious surface.
To prevent channeling of surface water runoff, adjust the planter row

- cleaners appropriately to prevent rows lower in height than adjacent soil.

AGRICULTURAL USE TA BLE

Restriction: DO NOT apply more than one application per year for each of the listed crops.

Crops Pests Controlled Rate of Counter ® 20G Systemic Insecticide Nematicide Application Remarks

FIELD CORN
( including FIELD CORN containing in

plant corn rootworm protection traits, such as YieldGard®, Herculex® and Agrisure® traits),

FIELD CORN GROWN FOR SEED, POPCORN AND SWEET CORN
At Planting Corn Rootworms 1

Wireworms

White Grubs
Seedcorn Maggots

Seedcorn B eetles

Corn Flea Beetles
Grape Colaspis
Maize Billbugs

Southern Corn

Billbugs
Thrips
Symphylans
Chinchbugs 2 Banded or In

Furrow

4.5 to 6 1,3 oz. per 1,000 ft. of row for any row spacing.

DO NOT exceed 6.5 pounds of Counter 20G per

acre. Banded
Place granules in a 4 to 5

- inch band over the open seed furrow, in front of the presswheel and incorporate evenly into the top 1 inch of the soil.

In

- Furrow
Place granules directly into the open seed furrow behind the planter shoe, so that granules are completely covered with soil. For use on conventional, conservation,

or no

- till corn. In sit uations where crop debris or winds can prevent proper placement of granules, in

- furrow applications are recommended. In

furrow applications reduce the potential for insecticide runoff resulting from excessive rain.

Adjust the presswheel so that the closed seed furrow is higher than the surrounding soil to reduce the potential for insecticide run

- off resulting from excessive rain.

1 Counter 20G at 6 oz per 1,000 ft. of row controls species of corn rootworm larvae including Southern, Northern, Western, and M exican corn rootworms. Rates less than 6 oz per36 Nematodes 3 :

Lance

Lesion

Root Knot
Spiral

Stunt
Sting
Stubby root
Dagger
Suppression of:

Cutworms 4

Lesser Cornstalk

Borers 1,000 ft of row are recommended for suppression only, unless used in combination with a corn hybrid containing in

- plant corn rootworm protection traits.

2 For use in the states of Alabama, Florida, Georgia, L ouisiana, Mississippi and Texas only for early season control of light to moderate infestations.

3 Counter 20G at 6 oz per 1,000 ft. of row controls the listed nematode species. Rates less than 6 oz per 1,000 ft. of row are recommended for suppression onl y.

4 Under heavy cutworm infestations, it may be necessary to apply a rescue treatment with an insecticide such as Ambush® or Discipline® 2EC after corn emergence to control surviving cutworm larvae.

If application is made at planting, do not make posteme rgence or cultivation time treatments of Counter 20G

Restriction: ALS

- inhibiting herbicides* SHOULD NOT be used if Counter 20G has been applied to corn at the time of planting. See additional information for “at cultivation” applications.

Restriction: DO NOT graze or cut for forage within 30 days of treatment.37 Postemergence Incorporated (Same as crops above) Maize billbugs

Southern corn

billbugs Banded
6 oz. per 1,000 ft. of row for any row spacing. DO NOT exceed 6.5 pounds of Counter 20G per

acre. Apply in a 7 inch band over the row of seedling corn plants when billbugs or damage are observed, usually in the 1 to 6 leaf stage of growth. Use cultivators or other suitable implement to lightly incorporate granules into soil. Only one at

- planting, postemerge nce incorporated, or cultivation

- time treatment of Counter 20G may be used on field corn and field corn grown for seed, popcorn, and sweet

corn.

Consult your state experiment station, state extension service or certified pest management specialist for pro per timing of application.

Restriction: DO NOT harvest sweet corn within 60 days after application.

Restriction: DO NOT graze or cut for forage within 30 days of treatment.

FOR FIELD CORN ONLY (Excluding Field Corn Grown For Seed)

At Cultivation Corn rootworms 6 oz. per 1,000 ft. of row for any row spacing. DO NOT exceed 6.5 pounds of Counter 20G per

acre. Apply granules to base of plants just ahead of cultivation shovels
so as to cover granules with soil. Restriction: DO NOT graze or cut for forage wi thin 30 days of treatment.

Counter 20G may be applied 7 days after application of ALS

- inhibiting herbicides*.

*Such as Accent ® , Accent Gold ® , Basis Gold ® , Steadfast ® , Beacon ® , Exceed ® , Hornet ® , Permit ® , Scorpion III ® , Celebrity ®

, Celebrity ® Plus, Lightning ® , Northstar ® and Spirit ® herbicides.

Crops Pests Controlled Rate of Counter ® 20G Systemic Insecticide Nematicide Application Remarks

ONLY ONE APPLICATION OF COUNTER 20G PER Y EAR MAY BE MADE FOR SUGAR BEETS.38 SUGAR BEETS
At Planting Sugar beet root maggots 5

Sugar beet

leafhopper 6

Aphids 6

Wireworms 5

White Grubs 5

Crown borer Banded or Modified In

Furrow

3

- 6 oz. per 1,000 ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 9.8 lbs. of Counter 20G per acre. Modified In

Furrow
Apply in

- furrow at planting time 2

- 3 inches behind the seed drop zone after some soil has covered the seed. At Planting

Restriction: DO NOT place granules in direct contact with the seed or crop injury may occur. Power incorporation may be used.

Restriction: DO NOT incorporate deeper than 2 inches.

5 If especially heavy infestations are expected, use the 6 oz. rate.

6 Modified in

- furrow only at the 6 oz.
rate.

Restriction: DO NOT harvest sugar beets or feed tops to livestock within 150 days of a knifed

- in application Suppression of:

Cutworms Banded
6 oz. per 1,000 ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 9.8 lbs. of Counter 20G per acre. Banded
Apply in 5 to 7 inch band over the row and lightly incorporate into the soil with drag chains or tines.

Suppression of:
Sugar beet cyst

nematode

Control of:
Sugar beet

leafhopper
Aphids Knifed

- in
6 oz. per 1,000 ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 9.8 lbs. of Counter 20G per acre. Knifed

- In
Drill granules 2 inches to the side of the seed and 2 to 4 inches below the seed.

SUGAR BEETS
Postemergence Sugar bee t root maggots
Sugar beet

leafhopper
Aphid
Sugar beet root

aphid

Crown borer 7 Banded

3

- 6 oz. per 1,000 ft. of row for any row spacing (minimum 20

- inch row spacing). Banded
Apply in 5 to 7 inch band over the row and lightly incorporate into the soil with cultivation shovels or other suitable implement. Postemergence
For sugar beet root maggot control apply at the time of first fly emergence.

Restriction: DO NOT harvest sugar beets or feed tops to livestock within 110 days after at planting banded, at plan ting modified in

- furrow or postemergence banded applications.39 7 Postemergence

– apply Counter 20G at the first sign of crown borer infestation.

ONLY ONE APPLICATION OF COUNTER 20G PER Y EAR MAY BE MADE FOR GRAIN SORGHUM.

GRAIN SORGHUM
At Bedding Greenbugs
Corn leaf aphids Knifed

- in
5.2 oz. per 1,000 ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 8.4 lbs. of Counter 20G per acre. Knifed

- in
Drill granules 1

- 4 inches below the seed OR 1

- 4 inches below the seed and up to 5 inches to the side of the seed. Restriction: DO NOT place granules in direct contact with seed as crop injury may occur.

Restriction: DO NOT graze or harvest grain sorghum forage within 50 days after treatment.

Restriction: DO NOT harvest grain sorghum fodder o r grain within 100 days after treatment.

GRAIN SORGHUM
At Planting Corn rootworms including:

Southern corn

rootworms

Wireworms

White Grubs

Nematodes
Greenbugs
Corn leaf aphids
Chinchbugs 9 Banded
5.2oz. per 1,000 ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 8.4 lbs. of Counter 20G per acre. Banded 8

Place granules in a 5 to 7 inch band directly behind the planter shoe in front of the press wheel and lightly incorporate with drag chains or tines. 8 Restriction: DO NOT use banded applications for aphid control in New Mexico, west Texas and the panhandle of Oklahoma.

Restriction: DO NOT graze or harvest grain sorghum forage within 50 days after treatment.

Rest riction: DO NOT harvest grain sorghum fodder or grain within 100 days after treatment.

9 For use in the states of Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi and Texas only for early season control of light to moderate infestations.
Greenbugs Knifed

- in
5.2 oz. per 1,000 Restriction: DO NOT place granules in direct contact with seed as crop40 Corn leaf aphids ft. of row for any row spacing (minimum 20 inch row spacing) or no more than 8.4 lbs. of Counter 20G per acre. injury may occur.

Restriction: DO NOT graze or harvest grain sorghum forage within 50 days after treatment.

Restriction: DO NOT harvest grain sorghum fodder or grain within 100 days after treatment.

Use Rates as Pounds per Acre*
(based on various row spacing and application rates)

Row Width

(Inches) Application Rates (oz/1,000 ft. of row)

3 oz. 4 oz. 6 oz.

40” 2.5 3.3 4.9

38” 2.6 3.4 5.2

36” 2.7 3.6 5.4

34” 2.8 3.9 5.6

32” 3.1 4.1 6.1

30” 3.3 4.4 6.5

28” 3.5 4.7 7.1

26” 3.8 5.0 7.6

24” 4.1 5.4 8.2

22” 4.5 5.9 8.9

20” 4.9 6.5 9.8
*See directions for specific use rates on each crop.41 CALIBRATION INFORMATION
It is important that applicator equipment be properly set to deliver the labeled rate. Please refer to planter manufacturer for detailed information on appropriate gauge settings and calibration procedures

.

STORAGE AND DISPOSAL

DO NOT contaminate water, food, or feed by storage and disposal.

PESTICIDE STORAGE: Store pesticide products in a secure locked area where children, unauthorized p ersons, and animals cannot enter.

DO NOT store in the same area with food or feed. DO NOT store open containers.

PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of federal law. If these wastes cannot be disposed of by use according to label instructions, contact your state pesticide or Environmental Control Agency, or the hazardous waste representative at the nearest EPA Regional Office for guidance. Open dumping is prohibited.

CONTAINER DISPOSAL:
DO NOT DISCARD THE CONTAINER. Do not attempt to open or tamper with the container. Completely empty container into application equipment. Return empty container to point of purchase or call 1

- 888

- GO

- AMVAC for instructions. Re

- fillable container. Refill this container with pesticide only. Do not reuse this container for any other purpose.

LIMITED WARRANTY AND DISCLAIMER
The manufacturer warrants (a) that this product conforms to the chemical description on the label; (b) that this product is reasonably fit for the purposes set forth in the directions for use, subject to the inherent risks referred to herein, when it is us ed in accordance with such directions; and (c) that the directions, warnings, and other statements on this label are based upon responsible experts' evaluations of reasonable tests of effectiveness, of toxicity to laboratory animals and to plants and resid ues on food crops, and upon reports of field experience. Tests have not been made on all varieties of food crops and plants, or in all states or under all conditions.

THERE ARE NO EXPRESS WARRANTIES OTHER THAN THOSE SET FORTH HEREIN. TO THE EXTENT CONSIS TENT WITH APPLICABLE LAW, THE MANUFACTURER NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR REPRESENTATIVE, TO MAKE ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND42 TO THE EXTENT CONSISTENT WITH APPLICABLE LAW IT EXPRESSLY EXCLUDES AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OF FITNESS FOR A PARTICULAR PURPOSE, OR ANY WARRANTY OF QUALITY OR PERFORMANCE. THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE FOR, ANY AND ALL LOSS OR DAMAGE WHICH RESULTS FROM THE US E OF THIS PRODUCT IN ANY MANNER WHICH IS INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS OR CAUTIONS.
TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S EXCLUSIVE REMEDY AND MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL CLAIMS, LOSSES , DAMAGES, OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR OTHERWISE, SHALL BE LIMITED, AT THE MANUFACTURER'S OPTION, TO REPLACEMENT OF, OR THE REPAYMENT OF THE PURCH ASE PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT TO WHICH DAMAGES ARE CLAIMED. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, MANUFACTURER OR SELLER SHALL NOT BE LIABLE FOR SPECIAL, INDIRECT OR CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT.
AMVAC offers this product, and Buyer accepts it, subject to the foregoing Limited Warranty which may be varied only by agreement in writing signed by an authorized representative of AMVAC. COUNTER, LOCK’n LOAD, SMARTBOX, AMBUSH and DISCIPLI NE are registered trademarks of AMVAC Chemical Corporation. Celebrity and Lightning are registered trademarks of BASF Corporation. Accent, Accent Gold, Basis Gold and Steadfast are registered trademarks of E.I. DuPont de Nemours & Co., Inc. Agrisure, Beaco n, Exceed, Northstar and Spirit are registered trademarks of a Syngenta Group Company. Herculex, Hornet and Scorpion III are registered trademarks of Dow Agrosciences LLC. Permit is a registered trademark of Nissan Chemical Industries, Ltd.
YieldGard is a registered trademark of Monsanto Technology LLC.

AMVAC Chemical Corporation 4100 E. Washington Blvd. Los Angeles, CA 90023 USA
1

- 888

- 462

- 682243 APPENDIX C

REGISTRANT ACKNOWLEDGEMENT4445 APPENDIX D

EFFICACY DATA46 EFFICACY DATA TABLES AND FIGURES

Table 1. Estimated losses in cotton yield to root

- knot nematode (RKN), reniform nematode (RN), and other species from 2009 to 2012.

YEAR ESTIMATED LOSSES IN COTTON YIELD IN GEORGIA BY YEAR (AS PERCENT AND TOTAL COTTON BALES) ESTIMATED COTTON

YIELD TOTAL RKN RN OTHERS
% BALES % BALES % BALES % BALES BALES 2009 9.5 210,237 7.0 154,911 2.0 44,260 0.5 11,065 2,213,010

2010 8.5 212,500 6.5 162,500 1.5 37,500 0.5 12,500 2,500,000

2011 11.5 352,312 8.5 260,405 2.5 76,590 0.5 15,318 3,063,584

2012 13.0 450,000 10.0 346,154 2.5 86,538 0.5 17,308 3,464,538
Source: Beltwide Cotton Conferences, Cotton Disease Loss Estimate Committee Report, 2010

- 2013.47 Figure 1. Estimated losses in cotton yield to nematodes from 1952 to 2008. Available from http://www.cotton.org/tech/pest/nematode/losses.cfm . [10 February 2014].48 Figure 2.49 Figure 3

.50 Figure 4.51 Figure 5.52 Figure 6.53 Figure 7.54 Figure 8.55 Figure 9.56 Figure 10.57 References used to support Section 18 request:

Allen, T. and D. Dodds. 2012, June 30. Root

- knot nematode observed in some delta cotton fields. Posted to Mississippi Crop Situation, Mississippi State Univ. Extension Service, Mississippi State, MS. Retrieved from ( http://www.mississippi

- crops.com/2012/06/30/root

- knot

- nematode

- observed

- in

- some

delta

- cotton

- fields/ ).

Cattaneo, M.G., T. A. Wheeler, and J. E. Woodward. 2011. 2010 Evaluation of cotton cultivar tolerance and ch emical management of southern root

- knot nematodes, pp. 175

- 177. In Proceedings Beltwide Cotton Production Research Conferences, Atlanta, GA. National Cotton Council of America, Memphis, TN.

Faske, T. R. and J. L. Starr. 2007. Cotton root protection from plant

- parasitic nematodes by abamectin

treated Seed. J. Nematol. 39: 27

- 30.
Golden, P. 2006. Root out options for nematode control. Southern Farmer. Retrieved from http://magissues.farmprogress.com/STF/SF03Mar06/stf15.pdf

. Kerns, D., J. Woodward, and T. Wheeler. 2011. Farming cotton without Temik. Terry County Ag News, Texas A&M Agrilife Extension, Brownfield, TX. Retrieved from ( http://terry.agrilife.org/files/2011/03/April2011.pdf ).
Koenning, S. R., C. Overstreet, J. W. Noling, P. A. Donald, J. O. Becker, and B. A. Fortnum. 1999. Survey of crop losses in response to phy to p arasitic nematodes in the United States for 1994. Supplement J. Nematol. 31: 587

- 618.
Lawrence, K. S., G. W. Lawrence, and S. R. Moore. 2011. New nematicide potentials in cotton in the southeast and mid south, pp.178

- 182. In Proceedings Beltwide Cotton Production Research Conferences, Atlanta, GA. National Cotton Council of America, Memphis, TN.
Martin, S.B., J. D. Mueller, J. A. Sanders, and W. I. Jones. 1004. A survey of South Carolina cotton fields for plant parasitic nematodes. Plant Dis . 78:717

- 719.
Mueller, J. D. 2011. The use of Temik® 15G on cotton and soybean in the southeast, pp.208

- 214. In Proceedings Beltwide Cotton Production Research Conferences, Atlanta, GA. National Cotton Council of America, Memphis, TN.

Overstreet, C. , E. C. McGawley, M. T. Kularathna, D. M. Xavier, C. M. Martin, and R. A. Haygood. 2013. Nutrient and nematicide effects against reniform and root

- knot nematodes in cotton, pp.906

- 910. In Proceedings Beltwide Cotton Production Research Conferences, San Antonio, TX. National Cotton Council of America, Memphis, TN.
Overstreet, C. and T. L. Kirkpatrick. 2011. Managing nematodes without Temik, p. 216. In Proceedings Beltwide Cotton Production Research Conferences, Atlanta, GA. National Cotton Council

o f America, Memphis, TN.58 Overstreet, C., E. C. McGawley, D. Burns, R. L. Frazier, R. Barbosa. 2012. The influence of apparent electrical conductivity on the soil on nematicides in cotton, pp. 288

- 292. In Proceedings Beltwide Cotton Production Research C onferences, Orlando, FL. National Cotton Council of America, Memphis, TN.
Starr, J. L., S. R. Koenning, T. L. Kirkpatrick, A. F. Robinson, P. A. Roberts, and R. L. Nichols. 2007. The future of nematode management in cotton. J. Nematol. 39: 283

- 294.
The Extension Cotton Team. 2013. 2014 Georgia cotton production guide. (Publication CSS

- 14

- 01). Univ. Georgia Extension Service Athens, GA. Retrieved from http:// www.ugacotton.com/vault/file/2014

- UGA

- Cotton

- Production

- Guide.pdf

. Wheeler, T.A., K. S. Lawrence, D. O. Porter, W. Keeling, and B. G. Mullinix, Jr. 2013. The relationship between environmental variables and response of cotton to nematicides. J. Nematol . 45: 8

– 16.
Wheeler, T.A., K. Siders, and M. Anderson. 2012. Management of root

- knot nematode without Temik, pp. 325

- 328. In Proceedings Beltwide Cotton Production Research Conferences, Orlando, FL. National Cotton Council of America, Memphis, TN.

W illiams

- Woodward, J. 2013. 2011 Georgia plant disease loss estimates, p. 8. Annual publication 102

- 4. Univ. Georgia Extension Service. Athens, GA. Retrieved from http://www.caes.uga.edu/applications/publications/files/pdf/AP%20102

- 4_1.PDF

. Stewart, S. 2013, Jan. 28. Meymik 15G (Temik Reincarnate). Posted to UTcrops News Blog, Univ. of Tennessee Institute of Agriculture, Knoxville, TN. Retrieved from http://news.utcrops.com/2013/01/meymik

- 15g

- temik

- reincarnate/#sthash.GqZYOtXx.dpuf

.