1

SPECIFIC EXEMPTION REQUEST

40 CFR 166.20 SUBPART B

USE OF COUNTER 20G FOR CONTROL OF SOUTHERN ROOT KNOT NEMATODES ON 

COTTON IN GEORGIA

FEBRUARY 21, 2014
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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 ..................................................................... 13

Coordination with Other Affected Federal or state agencies .................................... 19

Acknowledgement by Registrant .................................................................... 19

Enforcement Program ................................................................................. 19

Repeated Uses .......................................................................................... 20

Progress Towards Registration ....................................................................... 20

Nature of the Emergency .............................................................................. 20

Appendix A- Emergency Exemption Draft Label .................................................. 23

Appendix B- Counter 20G Federal Label ............................................................ 26

Appendix C- Registrant Acknowledgement .........................................................41

Appendix D- Efficacy Data ............................................................................43
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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

Telephone: 229-386-3355

Fax: 229-386-7415

Dr. Ned French

Product Development Manager, Southern Region 

AMVAC

15200 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, Emanuel, 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, Wheeler, 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-Production-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 Counter 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 nematode 

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 nematode but does not 

eliminate the threat of root damage in subsequent crops. Certain fields for specific production 

reasons cannot be rotated regularly.
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Host-Plant Resistance: Progress is being made in the development of cotton lines expressing 

some level 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 performance 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. Further, 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 registration 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 growers by an alternative manufacturer. On December 22, 2011 US-EPA approved 

registration of Meymik 15G (aldicarb) by AgLogic, LLC (http://www.aglogicchemical.com/); 

however, no clear and favorable indications have been made regarding the manufacturing or 

availability of Meymik 15G since that announcement. Dr. Scott Stewart (University of 

Tennessee) commented “Way back in December of 2011, I posted the article below. 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 the 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 Science & 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://dtnpfdigital.com/article/Nematode+Nemesis/1563182/184326/article.html). 

Seed Treatments: AerisTM 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 protection” (Overstreet & Kirkpatrick 2011). The overall performance of 
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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 over 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 application 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 control. 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 that 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 performance 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 adequate” (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 cm3 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 cm3 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 treatments 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 evaluated, 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. Telone 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 to 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))

Counter® 20G Systemic Insecticide-Nematicide (EPA Reg. No. 5481-562) has been evaluated 

for many years, particularly in corn which is a registered use, and in recent years, Counter 20G 

has been tested in field experiments in cotton for management of nematodes and thrips. Counter 

20G is an organophosphate insecticide which 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 Counter 20G on cotton. 

• 2011: Counter 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 

Counter 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. Counter applied in-furrow offered 

reductions in nematodes. 

GREENHOUSE: In greenhouse trials conducted by Lawrence, 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. 

Counter and Temik were highly efficacious against root knot nematode (Figure 2); Counter

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 conducted in 2011 and 2013, nematode 

evaluations were recorded following at-planting, in-furrow treatment with Counter 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 Counter

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). Counter at a rate of 

at least 6.5 lbs./A and Temik at 7 lbs./A averaged reductions 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 second 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 treatments of 

Counter 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 Counter 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 Counter 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, Counter 20G was 

evaluated against 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), Counter

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). Counter (5, 

6.5 or 10 lbs./A) results 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 Counter and mirrored 

findings with Temik at 5 lbs. per acre. Summary charts of these experiments against tobacco 

thrips can be provided upon request. 

SUMMARY: Based on greenhouse and field trial evaluations of Counter 20G in 2011 and 

2013, the efficacy of Counter against root-knot nematode was similar to but slightly less than 

that observed with Temik 15G at 7 lbs. per acre. Counter 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, Counter 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 demonstrate 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 

terbufos 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 Section 18 label similarly is only for a single application at planting. The 

description and results of those residue trials are in the table below. 
11
12

References:

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.; RES-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 Division, 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 Division, 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, Agricultural 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 greater than what is already in place; and there would be no 

associated incremental dietary risk calculated 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 “over-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 would 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 degradates of terbufos associated with potential groundwater contamination). 

http://ga.water.usgs.gov/edu/nitrogen.html The overlay between 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 area 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/wpcontent/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 similar 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 Maps of Cotton Use, Groundwater Vulnerability and Corn Use

1A
17

 

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 the 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 approved corn and sorghum rates. So there should not 

be any significant incremental risk associated with the proposed use. Additionally, the EECs 
18

associated with cotton use in Georgia would still be lower because the Georgia aquifers are not 

as vulnerable to groundwater 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 Concerns:

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 additional 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 Area
19

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 | Columbia, 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 | Jenkins, 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 | Randolph, 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 the 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 closed 

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-Load 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 Section 18 would also use the same 48-hour Restricted Entry Interval on the currently 

approved 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 authority 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 pests. 

ACKNOWLEDGEMENT BY REGISTRANT (166.20(a)(9))

The basic manufacturer, AMVAC 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 

this 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 enforcement of FIFRA by the United States 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 Enforcement 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. EPA 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 about 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 nematodes. 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 nematodes. 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. Based 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). Treatment with Temik 15G was the 

standard for both management of plant-parasitic nematodes and also thrips.

In 2011 Bayer CropScience, manufacturer of Temik 15G, announced that it would voluntarily 

discontinue the production of Temik 15G, despite the popularity 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 on 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 on growers to effectively and economically manage this family 

of pests. Although new varieties of cotton are being released that have some level of resistance to 

the southern root-knot nematode, such resistance is far from complete and use of nematicides is 
22

still warranted. Also, yield potential in the newer, more resistant varieties is not equal to those of 

the best varieties. It is important to note that no varieties are currently resistant to the reniform, 

Columbia lance, or sting nematodes.

Fumigation with Telone 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 

populations 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 growers 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 damaging 

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 outyielded 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 profitable cotton production in Georgia.

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

i. Yield anticipated in the 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 Complete 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 yields 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 the 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 to 
23

return value to the grower. For this reason, it is critically important for 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 will provide increased efficacy at comparable prices. 

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

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

APPENDIX A

DRAFT EMERGENCY EXEMPTION USE DIRECTIONS
25

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 Counter ® 20G Systemic Insecticide - Nematicide (EPA 

Reg. No. 5481-562), as well as the Section 18 directions, must be followed. 

This section 18 label contains directions for use that do not appear on the EPA registered label of 

Counter 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 INSECTICIDENEMATICIDE (per acre)

REMARKS

Nematodes1:

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 

temperature, moisture and tilth should 

be favorable for good germination and 

emergence1

Counter 20G at 6.5 to 10 

Thrips 5 – 6.5 lbs./A
26

lbs./A suppresses root knot nematodes.

Use Restrictions:

• The maximum single at-plant application rate is 10 lbs. Counter 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-applied 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 application. 

Counter 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 trademarks 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 LABEL
28

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 INSECTICIDE – 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-AL1

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 increase 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 respiration 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

1-888-462-6822
30

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 immediately. 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 (or 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 rather 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), theophylline, 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, gastric 

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 adult, 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-PAM; 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 administered 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 SENSITIVITY 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 until 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, emergency 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, children, 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 handlers 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

• Chemical-resistant footwear plus socks

• Chemical-resistant gloves
32

• 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 pesticides 

(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 cleaning 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 heavily 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 available, 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 vaporremoving 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.

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 provides 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 NIOSHapproved 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 pesticide 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 streams.

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 USE REQUIREMENTS

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

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

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

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

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

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 anything 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 storage 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 

statements 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 and 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.

All 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, rinse, 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 TABLE

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 inplant corn 

rootworm 

protection 

traits, such as 

YieldGard®, 

Herculex® and 

Agrisure® 

traits),

FIELD CORN 

GROWN FOR 

SEED, 

POPCORN 

AND SWEET 

CORN

At Planting

Corn Rootworms1

Wireworms

White Grubs

Seedcorn Maggots

Seedcorn Beetles

Corn Flea Beetles

Grape Colaspis

Maize Billbugs

Southern Corn 

Billbugs

Thrips

Symphylans

Chinchbugs2

Banded or InFurrow

4.5 to 61,3 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 situations where crop 

debris or winds can prevent proper 

placement of granules, in-furrow 

applications are recommended. Infurrow 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 Mexican corn 

rootworms. Rates less than 6 oz per 
36

Nematodes 3:

Lance

Lesion

Root Knot

Spiral

Stunt

Sting

Stubby root

Dagger

Suppression of:

Cutworms4

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, Louisiana, 

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 only.

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 postemergence 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, postemergence 

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 proper 

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 within 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 YEAR MAY BE MADE FOR SUGAR BEETS.
38

SUGAR BEETS

At Planting

Sugar beet root 

maggots5

Sugar beet 

leafhopper6

Aphids6

Wireworms5

White Grubs5

Crown borer

Banded or 

Modified InFurrow

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 InFurrow

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 beet root 

maggots

Sugar beet 

leafhopper

Aphid

Sugar beet root 

aphid

Crown borer7

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 

planting 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 YEAR 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 or grain within 100 

days after treatment.

GRAIN 

SORGHUM

At Planting

Corn rootworms 

including:

Southern corn 

rootworms

Wireworms

White Grubs

Nematodes

Greenbugs

Corn leaf aphids

Chinchbugs9

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.

Banded8

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.

Restriction: 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 crop 
40

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 persons, 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 used 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 residues 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 CONSISTENT 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, AND 
42

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 USE 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 PURCHASE 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 DISCIPLINE 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, Beacon, 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

1-888-462-6822
43

APPENDIX C

REGISTRANT ACKNOWLEDGEMENT
44
45

APPENDIX D

EFFICACY DATA
46

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-somedelta-cotton-fields/). 

Cattaneo, M.G., T. A. Wheeler, and J. E. Woodward. 2011. 2010 Evaluation of cotton cultivar 

tolerance and chemical 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 abamectintreated 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 phytoparasitic 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 

of 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 Conferences, 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.

Williams-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.