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docker: production image + Gitea Actions for monthly refresh
Image rebuild (skip scrape) / build (push) Failing after 1h37m12s
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Browse Source 
Dockerfile: self-contained image with corpus + Chroma + BM25 baked
in. Drawbar's compose pulls + runs without volume mounts. Built from
sources.json (labels schema), PRODUCT_NAME=crop_chem by default,
HYBRID_SEARCH=true (always-on for production quality). RERANK_URL +
OLLAMA_URL get set at compose time.

.gitea/workflows/refresh.yml: monthly cron (1st @ 06:00 UTC) does
full scrape → reindex → image push. Scrapes Bayer (~30 min) +
EPA PPLS row-crop filtered (~7h). Skips reindex+push if no corpus
diff. Tags pushed: :latest, :<sha12>, :corpus-<YYYY.MM.DD>.

.gitea/workflows/image-only.yml: on-demand or auto on code-only
pushes to main (paths: docs_mcp/, rag/, scrape/, requirements.txt,
Dockerfile, sources.json). Reindexes from committed corpus, builds
image, pushes. ~10 min vs ~9h full refresh.

.gitignore: corpus/ now COMMITTED (4,159 labels, 265 MB of .md +
sidecars). Lets image-only.yml rebuild indexes without re-scraping.
chroma/ + bm25/ still gitignored (regenerable binary indexes).

.dockerignore: drops venv, eval results, PLAN/README/CLAUDE.md,
deploy/, .git/ — keeps the image lean. corpus + chroma + bm25
explicitly NOT in dockerignore (those go INTO the image).

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
This commit is contained in:
Justin Paul
2026-05-24 12:32:41 -04:00
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# MON 89034 X TC1507 SEED BLEND
- EPA Reg No: **524-612**
- Registrant: BAYER CROPSCIENCE, LLC
- Signal word: Caution
- Active ingredients: Bacillus thuringiensis Cry1F protein and the genetic material necessary for its production (plasmid insert PHI8999) in corn (0.0012%); Bacillus thuringiensis Cry1A.105 protein and genetic material necessary (vector PV-ZMIR245) for its production in corn (0.0026%); Bacillus thuringiensis Cry2Ab2 protein and the genetic material necessary (vector PV-ZMIR245) for its production in corn (0.0053%)
- Label accepted: 2018-11-07
- Source PDF: https://www3.epa.gov/pesticides/chem_search/ppls/000524-00612-20181107.pdf
---
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460 
OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION 
November 7, 2018
David J. Chi
Regulatory Affairs Manager
Monsanto Company
800 North Lindbergh Blvd.
St. Louis, MO 63137
Subject: Amendment to update the label, compliance terms, and extend the expiration date of MON
89034 x TC1507 Seed Blend
EPA Registration Number: 524-612
Submission Date: 5/23/2018
OPP Decision Number: 542180
Dear Mr. Chi:
The amendment referenced above, submitted in connection with registration under Section
3(c)(5) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), is acceptable provided that
you comply with the updated terms and conditions as described in this letter.
1. The subject registration will automatically expire at midnight on November 30, 2030.
2. The subject registration will be limited to a field corn seed blend of up to 95% Bacillus thuringiensis
Cry1A.105 and Cry2Ab2 proteins and the genetic material (vector PV-ZMIR245) necessary for their
production in corn event MON 89034 (OECD Unique Identifier: MON-89Ø34-3) and Bacillus
thuringiensis Cry1F protein and the genetic material (vector PHP8999) necessary for its production in
corn event TC1507 (OECD Unique Identifier: DAS-Ø15Ø7-1) field corn seed and a minimum of 5%
non-Bt corn seed that when planted creates an interspersed refuge within the field.
3. Submit/cite all data required for registration of your product under FIFRA section 3(c)(5) when the
Environmental Protection Agency (EPA) requires registrants of similar products to submit such data.
4. This plant-incorporated protectant (PIP) may be combined through conventional breeding with other
registered plant-incorporated protectants that are similarly approved for use in combination, through
conventional breeding, with other registered plant-incorporated protectants to produce inbred corn lines
and hybrid corn varieties with combined pesticidal traits.
5. Monsanto Company (hereafter referred to as Monsanto) must commit to do the following Insect
Resistance Management (IRM) Program, consisting of the following elements:
 Requirements relating to a refuge assurance program for ensuring the correct refuge blend
percentage.
Page 2 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
 Requirements relating to creation of a lepidopteran refuge (consisting of corn that does not
contain any Bt trait for lepidopteran control) in cotton growing regions in conjunction with the
planting of any acreage of MON 89034 x TC1507 Seed Blend corn;
 Requirements for Monsanto to prepare and require MON 89034 x TC1507 Seed Blend corn users
to sign grower agreements that impose binding contractual oblig ations on growers to comply
with the refuge requirements.
 Requirements for Monsanto to develop, implement, and report to EPA on programs to
educate growers about IRM requirements.
 Requirements for Monsanto to develop, implement, and report to EPA on programs to
evaluate and promote growers’ compliance with IRM requirements.
 Requirements for Monsanto to develop, implement, and report to EPA on monitoring programs
to evaluate whether there are statistically significant and biologically relevant changes in
susceptibility to the Cry1A.105, Cry1F, or Cry2Ab2 proteins in the target insects.
 Requirements for Monsanto to develop, and if triggered, to implement a remedial action plan
that would contain measures Monsanto would take in the event that any field-relevant insect
resistance to Cry1A.105, Cry1F, or Cry2Ab2 was detected, as well as to report on activity
under the plan to EPA.
 Requirements for Monsanto to maintain, and provide the Agency upon request, the number
of units sold by state and county, IRM grower agreement results, and substantive changes to
educational programs. Monsanto is required to submit reports within three months of the
Agency’s request.
 Bag Tag Requirements for MON 89034 x TC1507 Seed Blend corn. Seed bags and/or bag tags
for corn hybrids that contain plant- incorporated protectants produced in MON 89034 x
TC1507 Seed Blend corn must display the registration number and active ingredients, and
stipulate that growers read the Monsanto Stewardship Guide (or equivalent guidance) prior to
planting these hybrids. The refuge size requirement must be displayed on the bag or bag tag in
both text and graphic format.
a. Refuge Requirements for MON 89034 x TC1507 Seed Blend Corn
The following information must be included on the product bag o r bag-tag as sold per respective region and in
the Grower Guide:
Corn Belt/Non-Cotton Growing Areas
MON 89034 x TC1507 Seed Blend contains a Lepidopteran refuge that is “in the bag” and is automatically
implemented when the grower plants the product. No additional refuge is required when planting this product.
Foliar insecticide treatments for control of European corn borer, corn earworm, southwestern corn borer, fall
armyworm, black cutworm, western bean cutworm, lesser corn stalk borer, southern corn stalk borer, stalk borer
and sugarcane borer may be applied only if economic thresholds are reached for one or more of these target
Page 3 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
pests. Foliar insecticide treatments are also permitted for control of corn rootworm adults if economic
thresholds are reached. Economic thresholds will be determined using methods recommended by local or
regional professionals (e.g., Extension Service agents, crop consultants).
Cotton-Growing Region Refuge Requirements
These refuge requirements do not apply to seed increase/propagation of inbred and hybrid seed corn up to a
total of 20,000 acres per county and up to a combined United States (U.S.) total of 250,000 acres per plant-
incorporated protectant (PIP) active ingredient per registrant per year. Grower agreements (also known as
stewardship agreements) will specify that growers must adhere to the refuge requirements as described in the
grower guide/product use guide and/or in supplements to the grower guide/product use guide.
In the cotton-growing area where corn earworm is a significant pest:
 A 20% refuge must be planted with non-Bt corn hybrids.
 MON 89034 x TC1507 Seed Blend and the 20% non-Bt refuge should be sown on the same day, or with
the shortest window possible between planting dates.
 External refuges may be planted as an in-field or adjacent (e.g., across the road) refuge or planted as a
separate block within 1/2 mile of the MON 89034 x TC1507 Seed Blend field.
 In field refuge options include blocks, perimeter strips (i.e., along the edges or headlands), or in-field
strips.
 When planting the refuge in strips across the field, refuges must be at least four (4) rows wide.
 Foliar insecticide treatments for control of European corn borer, corn earworm, southwestern corn borer,
fall armyworm, black cutworm, western bean cutworm, lesser corn stalk borer, southern corn stalk
borer, stalk borer and sugarcane borer may be applied only if economic thresholds are reached for one or
more of these target pests. Economic thresholds will be determined using methods recommended by
local or regional professionals (e.g., Extension Service agents, crop consultants). Microbial Bt
insecticides must not be applied to non-Bt corn refuge plants.
 Cotton-growing areas include the following states: Alabama, Arkansas, Georgia, Florida, Louisiana,
North Carolina, Mississippi, South Carolina, Oklahoma (only counties of Beckham, Caddo, Comanche,
Custer, Greer, Harmon, Jackson, Kay, Kiowa, Tillman, and Washita), Tennessee (only the counties of
Carroll, Chester, Crockett, Dyer, Fayette, Franklin, Gibson, Hardeman, Hardin, Haywood, Lake,
Lauderdale, Lincoln, Madison, Obion, Rutherford, Shelby, and Tipton), Texas (except the counties of
Carson, Dallam, Hansford, Hartley, Hutchinson, Lipscomb, Moore, Ochiltree, Roberts, and Sherman),
Virginia (only the counties of Dinwiddie, Franklin City, Greensville, Isle of Wight, Northampton,
Southampton, Suffolk City, Surrey, and Sussex) and Missouri (on
ly the counties of Dunklin, New
Madrid, Pemiscot, Scott, and Stoddard). All other states and counties are considered to be in the corn-
growing area where no structured refuge is required.
b. Grower Agreements for MON 89034 x TC1507 Seed Blend Corn
1. Persons purchasing MON 89034 x TC1507 Seed Blend corn must sign a grower agreement. The term
grower agreement refers to any grower purchase contract, license agreement, or similar legal document.
Page 4 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
2. The grower agreement and/or specific stewardship documents referenced in the grower agreement must
clearly set forth the terms of the current IRM program. By signing the grower agreement, a grower must be
contractually bound to comply with the requirements of the IRM program.
3. Monsanto must continue to integrate this registration into the current system used for its other Bt corn
plant- incorporated protectants, which is reasonably likely to assure that persons purchasing MON 89034 x
TC1507 Seed Blend corn will affirm annually that they are contractually bound to comply with the
requirements of the IRM program.
4. Monsanto must continue to use its current grower agreement for MON 89034 x TC1507 Seed Blend corn.
If Monsanto wishes to change any part of the grower agreement or any specific stewardship documents
referenced in the grower agreement that would affect either the content of the IRM program or the legal
enforceability of the provisions of the agreement relating to the IRM program, then thirty (30) days prior to
implementing a proposed change, Monsanto must submit to EPA the text of such changes to ensure that it
is consistent with the terms and conditions of this amended registration.
5. Monsanto shall maintain records of all MON 89034 x TC1507 Seed Blend corn grower agreements for a
period of three (3) years from December 31st of the year in which the agreement was signed.
6. Monsanto shall make available to the Agency upon request records of the number of units of MON 89034
x TC1507 Seed Blend corn seed sold or shipped and not returned, and the number of such units that were
sold to persons who have signed grower agreements for the previous growing season. Monsanto is required
to submit reports within three months of the Agency’s request.
7. Monsanto must allow a review of the grower agreements and grower agreement records by EPA or by a
State pesticide regulatory agency if the State agency can demonstrate that confidential business
information, including names, personal information, and grower license numbers of the growers, will be
protected.
c. IRM Education and IRM Compliance Monitoring Program for MON 89034 x TC1507 Seed
Blend Corn in EPA-designated Cotton Counties
1. Monsanto must implement and enhance (as set forth in paragraph 17 of this section) a comprehensive,
ongoing IRM education program designed to convey to MON 89034 x TC1507 Seed Blend corn users the
importance of complying with the IRM program, as well as seed blend product performance expectations
and guidance to growers on actions to take when unexpected damage occurs. The program shall include
information encouraging MON 89034 x TC1507 Seed Blend corn users to pursue optional elements of the
IRM program relating to refuge configuration and proximity to MON 89034 x TC1507 Seed Blend corn
fields. The education program shall involve the use of multiple media, e.g. face-to-face meetings, mailing
written materials, EPA-reviewed language on IRM requirements on the bag or bag tag, and electronic
communications such as by internet, radio, or television commercials. The program shall involve at least
one written communication annually to each MON 89034 x TC1507 Seed Blend corn user separate from
the grower technical guide. The communication shall inform the user of the current IRM requirements and
specifically the need to plant a lepidopteran refuge in cotton growing regions. Monsanto shall coordinate
its education program with the educational efforts of other registrants and other organizations, such as the
National Corn Growers Association and state extension programs.
2. Monsanto shall revise, and expand as necessary, its education program to take into account the information
Page 5 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
collected through the compliance survey, required under paragraphs 6–9 of this section, and from other
sources. The changes shall address aspects of grower compliance that are not sufficiently high.
3. Upon EPA request, Monsanto shall provide copies of grower education materials and information on
grower education activities including any substantive changes to these materials and activities conducted
either individually or as part of the industry working group Agricultural Biotechnology Stewardship
Technical Committee (ABSTC). Monsanto is required to submit reports within three months of the
Agency’s request. The required features of the compliance assurance program are described in paragraphs
4–22 of this section.
4. Monsanto must implement and improve an ongoing IRM compliance assurance program designed to
evaluate the extent to which growers purchasing MON 89034 x TC1507 Seed Blend corn are compliant
with the requirement of a 20% refuge for lepidopteran pests in cotton growing areas, and that takes such
actions as are reasonably needed to assure that growers who have not complied with the program either do
so in the future or lose their access to Monsanto’s Bt corn products. Monsanto shall coordinate with other
Bt corn registrants in improving its compliance assurance program and integrate this registration into the
current compliance assurance program used for its other Bt corn plant-incorporated protectants. Other
required features of the program are described in paragraphs 5–22 of this section.
5. Monsanto must maintain and publicize a phased compliance approach (i.e., a guidance document that
indicates how it will address instances of non-compliance with the terms of the IRM program and general
criteria for choosing among options for responding to any non-compliant growers after the first year of
non-compliance). While recognizing that for reasons of difference in business practices there are needs for
flexibility between different companies, Monsanto must use a consistent set of standards for responding to
non-compliance. An individual grower found to be significantly out of compliance two (2) years in a row
would be denied access the next year to Monsanto’s Bt corn products for which the grower is required to
plant a separate structured refuge. Similarly, seed dealers who are not fulfilling their obligations to
inform/educate growers of their IRM obligations will lose their opportunity to sell Bt corn.
6. The IRM compliance assurance program shall include an annual survey, conducted by an independent third
party, of a statistically representative sample of growers MON 89034 x TC1507 Seed Blend corn. The
survey shall be conducted in odd-numbered years beginning in 2019 and shall include growers who plant
100 or more acres of corn in the Southern U.S. corn-cotton areas. Monsanto may collaborate with other
registrants of Bt corn [for example, through the industry working group the Agricultural Biotechnology
Stewardship Technical Committee (ABSTC)] to conduct the survey.
In the U.S. Corn Belt, no anonymous grower survey is required for MON 89034 x TC1507 Seed Blend
corn if Monsanto can demonstrate that the industry-wide adoption of integrated refuge products (i.e.,
refuge seed blends) is equal to or greater than 70% of Bt corn acres in the Corn Belt. If industry- wide
adoption of integrated refuge products (i.e., refuge seed blends) falls below 70% of Bt corn acres in the
Corn Belt, an anonymous grower survey shall also be conducted in this region during the next growing
season using a statistically representative sample of growers who plant 200 or more acres of corn, and
grower surveys shall be continued every odd-numbered year until the industry-wide adoption of integrated
refuge products (i.e., refuge seed blends) is again equal to or greater than 70% of Bt corn acres in this
region. Monsanto may collaborate with other registrants of Bt corn (for example, through the industry
working group the ABSTC) to compile the integrated refuge adoption data and to conduct the surveys.
Alternatively, if Monsanto is not a participant of an industry working group (e.g., the ABSTC) and
Monsanto’s sales of integrated refuge products are equal to or greater than 70% of Monsanto’s total Bt corn
Page 6 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
sales in the prior year, then no anonymous grower survey is required in the U.S. Corn Belt. If Monsanto’s
sales of integrated refuge products fall below 70% of Monsanto’s total Bt corn sales, an anonymous grower
survey shall also be conducted in this region during the next growing season using a statistically
representative sample of growers who plant 200 or more acres of corn, and grower surveys shall be
continued every odd-numbered year until sales of integrated refuge products (i.e., refuge seed blends) are
again equal to or greater than 70% of Monsanto’s total Bt corn sales in this region.
 A third party is classified as a party other than the registrant, the grower, or anyone else with a
direct interest in IRM compliance for Bt corn.
7. The survey shall be designed to provide an understanding of any difficulties growers encounter in
implementing IRM requirements. An analysis of survey results must include the reasons, extent, and
potential biological significance of any implementation deviations.
8. The survey shall be designed to obtain grower feedback on the usefulness of specific educational tools and
initiatives.
9. In years in which the survey is conducted, Monsanto shall provide a final written summary of the results of
the survey (together with a description of the regions, the methodology used, and the supporting data) to
EPA on or before January 31st of the following year. Monsanto shall confer with other registrants and EPA
on the design and content of the survey prior to its implementation.
10. Monsanto shall revise, and expand as necessary, its compliance assurance program to take into account the
information collected through the compliance survey, required under paragraphs 6–9 of this section, and
from other sources. The changes shall address aspects of grower compliance that are not sufficiently high.
Monsanto must confer with EPA prior to adopting any changes.
11. Monsanto shall conduct and enhance an annual on-farm assessment program. Monsanto shall train its
representatives who make on-farm visits with MON 89034 x TC1507 Seed Blend corn growers to perform
assessments of compliance with IRM requirements. There is no minimum corn acreage size for this
program. Therefore, growers will be selected for this program from across all farm sizes. In the event that
any of these visits result in the identification of a grower who is not in compliance with the IRM program,
Monsanto shall take appropriate action, consistent with its phased compliance approach, to promote
compliance.
12. Monsanto shall implement a program for investigating legitimate tips and complaints that MON 89034 x
TC1507 Seed Blend corn growers are not in compliance with the IRM program. Whenever an investigation
results in the identification of a grower who is not in compliance with the IRM program, Monsanto shall
take appropriate action, consistent with its phased compliance approach.
13. If a grower, who purchases MON 89034 x TC1507 Seed Blend corn for planting, was specifically
identified as not being in compliance during the previous year, Monsanto shall visit with the grower and
evaluate whether the grower is in compliance with the IRM program for the current year.
14. Annually, by January 31st each year, Monsanto must provide a report to EPA summarizing the MON
89034 x TC1507 Seed Blend compliance assurance program activities and results for the prior year and
plans for the MON 89034 x TC1507 Seed Blend compliance assurance program for the current year.
Within one month of submitting this report to EPA, the registrant shall meet with EPA to discuss its
findings. The report must inform EPA of the number of growers deemed ineligible to purchase Bt corn
Page 7 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
seed on the basis of continued non-compliance with the insect resistance management refuge requirements.
Monsanto may elect to coordinate information with other registrants and report collectively the results of
compliance assurance programs.
15. Monsanto and the seed corn dealers for Monsanto must allow a review of the compliance records by EPA
or by a State pesticide regulatory agency if the State agency can demonstrate that confidential business
information, including the names, personal information, and grower license numbers of the growers, will
be protected.
16. Monsanto shall revise and expand its existing Compliance Assurance Program to include the following
elements. The registrant may coordinate with other registrants in designing and implementing its
Compliance Assurance Program.
17. Monsanto will enhance the refuge education program throughout the seed delivery channel:
 Ensure sales representatives, licensees, seed dealers, and growers recognize the importance of
correct refuge implementation and potential consequences of failure to plant the required refuge.
 Implement a “bag tag” that will be attached to all bags of MON 89034 x TC1507 Seed Blend
seed sold and delivered. The purpose of this bag tag is to remind growers that MON 89034 x
TC1507 Seed Blend products require a separate 20% lepidopteran refuge in cotton growing
areas. The PIP product label accepted by EPA must include how this information will be
conveyed to growers via text and graphics.
18. Monsanto will focus the majority of on-farm assessments on regions with the greatest risks for resistance:
 Use Bt corn adoption, pest pressure information, and other available information to identify
regions where the risk of resistance is greatest;
 Focus approximately two-thirds of on-farm assessments on these regions, with the remaining
assessments conducted across other regions where MON 89034 x TC1507 Seed Blend is used.
19. Monsanto will use its available MON 89034 x TC1507 Seed Blend sales records and other information to
refine grower lists for on-farm assessments of their compliance with refuge requirements:
 Identify for potential on-farm assessment growers whose sales information indicates they have
purchased MON 89034 x TC1507 Seed Blend corn product but may have purchased little or no
refuge seed from the registrant, licensee, or affiliated company.
20. Monsanto will contract with third parties to perform on-farm assessments of compliance with refuge
requirements:
 The third-party assessors will conduct all first-time on-farm assessments as well as second-year
on-farm assessments of those growers found out of compliance in a first- time assessment.
21. Monsanto will annually refine the on-farm assessment program for the MON 89034 x TC1507 Seed Blend
corn product to reflect the adoption rate and level of refuge compliance for the product.
Page 8 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
22. Monsanto will follow up with growers who have been found significantly out of compliance under the on-
farm assessment program and are found to be back in compliance the following year:
 All growers found to be significantly out of compliance in a prior year will annually be sent
additional refuge assistance information for a minimum of two years by Monsanto, seed
supplier, or third-party assessor, after completing the assessment process;
 Monsanto will conduct follow-up checks on growers found to be significantly out of compliance
within three years after they are found to be back in compliance;
 A grower found with a second incident of significant non-compliance with refuge requirements
for the Bt corn product within a five-year period will be denied access to Monsanto’s Bt corn
products the next year. Similarly, seed dealers who are not fulfilling their obligations to
inform/educate growers of their IRM obligations will lose their opportunity to sell Bt corn.
d. Insect Resistance Monitoring and Mitigation Plan for MON 89034 x TC1507 Seed Blend Corn
1. EPA is imposing the following conditions for the Cry1A.105, Cry1F, and Cry2Ab2 toxins expressed
in MON 89034 x TC1507 Seed Blend
Monsanto will monitor for resistance to Cry1A.105, Cry1F, or Cry2Ab2 expressed in MON 89034 x TC1507
Seed Blend corn. The monitoring program shall consist of two approaches: (1) focused population sampling
and laboratory testing; and (2) investigation of reports of less-than expected control of labeled insects.
Should field-relevant resistance be confirmed, an appropriate resistance management action plan will be
implemented.
Focused Population Sampling
Monsanto shall annually sample and bioassay populations of the key target pests: Ostrinia nubilalis
(European corn borer; ECB), Diatraea grandiosella (southwestern corn borer; SWCB), and Helicoverpa zea
(corn earworm; CEW). Sampling for the target pests will be focused in areas identified as those with the
highest risk of resistance development (e.g., where lepidopteran active Bt hybrids are planted on a high
proportion of the corn acres, and where the insect species are regarded as key pests of corn). Bioassay
methods must be appropriate for the goal of detecting field-relevant shifts in population response to MON
89034 x TC1507 Seed Blend corn and/or changes in resistance allele frequency in response to the use of
MON 89034 x TC1507 Seed Blend corn and, as far as possible, should be consistent across sampling years to
enable comparisons with historical data.
The number of populations to be collected shall reflect the regional importance of the insect species as a pest,
and specific collection regions will be identified for each pest. For ECB, a minimum of twelve (12)
populations across the sampling region will be targeted for collection at each annual sampling. For SWCB,
the target will be a minimum of six (6) populations. For CEW, the target will be a minimum of ten (10)
populations. Pest populations should be collected from multiple corn-growing states reflective of different
geographies and agronomic conditions. To obtain sufficient sensitivity to detect resistance alleles before they
become common enough to cause measurable field damage, each population collection shall attempt to target
400 insect genomes (egg masses, larvae, mated females, and/or mixed-sex adults), but a successful
Page 9 of 13 
EPA Reg. No. 524‐612 
OPP Decision No. 542180   
population collection will contain a minimum of 100 genomes. It is recognized that it may not be possible to
collect the target number of insect populations or genomes due to factors such as natural fluctuations in pest
density, environmental conditions, and area-wide pest suppression.
The sampling program and geographic range of collections may be modified as appropriate based on changes
in pest importance and for the adoption levels of MON 89034 x TC1507 Seed Blend corn. EPA shall be
consulted prior to the implementation of such modifications.
Monsanto will report to EPA, on or before August 31st of each year, the results of the population sampling
and bioassay monitoring program.
Any incidence of unusually low sensitivity to the Cry1A.105, Cry1F, or Cry2Ab2 proteins in bioassays shall
be investigated as soon as possible to understand any field relevance of such a finding. Such investigations
shall proceed in a stepwise manner until the field relevance can be either confirmed or refuted, and results of
these shall be reported to EPA annually on or before August 31st. The investigative steps will include the
following:
i. Re-test progeny of the collected population to determine whether the unusual bioassay
response is reproducible and heritable. If it is not reproducible and heritable, no further action
is required.
ii. If the unusual response is reproducible and heritable, progeny of insects that survive the
diagnostic concentration will be tested using methods that are representative of exposure to
MON 89034 x TC1507 Seed Blend corn under field conditions. If progeny do not survive to
adulthood, any suspected resistance is not field relevant and no further action is required.
iii. If insects survive steps 1 and 2, resistance is confirmed, and further steps will be taken to
evaluate the resistance. These steps may include the following:
a. Determining the nature of the resistance (i.e., recessive or dominant, and the level of
functional dominance);
b. Estimating the resistance allele frequency in the original population;
c. Determining whether the resistance allele frequency is increasing by analyzing field
collections in subsequent years sampled from the same site where the resistance
allele(s) was originally collected;
d. Determining the geographic distribution of the resistance allele by analyzing field
collections in subsequent years from sites surrounding the site where the resistance
allele(s) was originally collected.
Should field-relevant resistance be confirmed, and the resistan
ce appears to be increasing or spreading,
Monsanto will consult with EPA to develop and implement a case-specific resistance management action
plan.
Investigation of Reports of Unexpected Levels of Damage by the Target Pests
Monsanto will follow up on grower, extension specialist, or consultant reports of unexpected levels of
damage by the lepidopteran pests listed on the pesticide label. Monsanto will instruct its customers to contact
them if such incidents occur. Monsanto will investigate all legitimate reports submitted to the company or the
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EPA Reg. No. 524‐612 
OPP Decision No. 542180   
company's representatives.
If reports of unexpected levels of damage lead to the suspicion of resistance in any of the key target pests
(ECB, SWCB, and CEW), Monsanto will implement the actions described below, based on the following
definitions of suspected resistance and confirmed resistance.
Suspected Resistance
EPA defines suspected resistance to mean field reports of unexpected levels of insect-feeding damage for
which:
 The corn in question has been confirmed to be lepidopteran-active Bt corn;
 The seed used had the proper percentage of corn expressing Bt protein;
 The relevant plant tissues are expressing the expected level of Bt protein; and
 It has been ruled out that species not susceptible to the protein could be responsible for the damage,
that no climatic or cultural reasons could be responsible for the damage, and
 That there could be no other reasonable causes for the damage.
EPA does not interpret suspected resistance to mean grower reports of possible control failures or suspicious
results from annual insect monitoring assays, nor does EPA intend that extensive field studies and testing be
undertaken to confirm scientifically the presence of insects resistant to MON 89034 x TC1507 Seed Blend
corn in commercial production fields before responsive measures are undertaken.
If resistance is suspected, Monsanto will instruct growers to do the following:
 Use alternative control measures in MON 89034 x TC1507 Seed Blend corn fields in the affected
region to control the target pest during the immediate growing season.
 Destroy MON 89034 x TC1507 Seed Blend corn crop residues in the affected region within one (1)
month after harvest with a technique appropriate for local production practices to minimize the
possibility of resistant insects over- wintering and contributing to the next season's target pest
population.
Additionally, if possible, and prior to the application of alternative control measures or destruction of crop
residues, Monsanto will collect samples of the insect population in the affected fields for laboratory rearing
and testing. Such rearing and testing shall be conducted as expeditiously as practical.
Confirmed Resistance
EPA defines confirmed resistance to mean, in the case of field reports of unexpected levels of damage from
the key target pests, that all the following criteria are met:
 There is >30% insect survival and commensurate insect feeding in a bioassay, initiated with
neonate larvae, that uses methods that are representative of exposure to Bt corn hybrids under field
conditions (ECB and SWCB only).
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OPP Decision No. 542180   
 In standardized laboratory bioassays using diagnostic concentrations of the Bt protein suited to the
target pest in question, the pest exhibits resistance that has a genetic basis and the level of survivorship
indicates that there may be a resistance allele frequency of ≥ 0.1 in the sampled population.
 In standardized laboratory bioassays, the LC50 exceeds the upper limit of the 95% confidence interval
of the LC50 for susceptible populations surveyed both in the original baselines developed for this pest
species and in previous years of field monitoring.
Response to Confirmed Resistance in a Key Target Pest as the Cause of Unexpected Levels
of Damage in the Field
When field resistance is confirmed (as defined above), the following steps will be taken by Monsanto:
 EPA will receive notification within 30 days of resistance confirmation;
 Affected customers and extension agents will be notified about confirmed resistance within 30 days;
 Monitoring will be increased in the affected area and local target pest populations will be
sampled annually to determine the extent and impact of resistance;
 If appropriate (depending on the resistant pest species, the extent of resistance, the timing of
resistance, and the nature of resistance, and the availability of suitable alternative control measures),
alternative control measures will be employed to reduce or control target pest populations in the
affected area. Alternative control measures may include advising customers and extension agents in
the affected area to incorporate crop residues into the soil following harvest to minimize the
possibility of over-wintering insects, and/or applications of chemical insecticides;
 Unless otherwise agreed with EPA, stop sale and distribution of the relevant lepidopteran-active Bt
corn hybrids in the affected area immediately until an effective local mitigation plan, approved by
EPA, has been implemented;
 Monsanto will develop a case-specific resistance management action plan within 90 days according
to the characteristics of the resistance event and local agronomic needs. Monsanto will consult with
appropriate stakeholders in the development of the action plan, and the details of such a plan shall be
approved by EPA prior to implementation;
 Monsanto will notify affected parties (e.g., growers, consultants, extension agents, seed
distributors, university cooperators, and state/federal authorities as appropriate) in the region of
the resistance situation and approved action plan; and
 In subsequent growing seasons, maintain sales suspension and alternative resistance management
strategies in the affected region(s) for the Bt corn hybrids that are affected by the resistant
population until an EPA-approved local resistance management plan is in place to mitigate the
resistance.
A report on results of resistance monitoring and investigations of damage reports must be submitted to EPA,
on or before August 31st of each year, for the duration of the registration.
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OPP Decision No. 542180   
e. Refuge Assurance Program for MON 89034 x TC1507 Seed Blend corn
Monsanto must implement a Blended Seed Refuge Assurance Program designed to ensure MON 89034 x
TC1507 Seed Blend corn products are formulated with the appropriate rate of refuge seeds. The program
must include the following four elements:
1. Trait purity check on seed lots prior to blending;
2. Standard Operating Procedures for the blending process;
3. Calibration of blending equipment; and
4. Records and data retention records for seed blend products.
 Calibration records - Monsanto will retain documentation for a specified period of time on the
equipment calibration including the procedure, when it was conducted and the results.
 Blend proportion records (weight and kernel based) - Monsanto will retain documentation for a
specified period of time on the kernel per pound data of the components, the calculations to
determine the proportions based on weight and the actual weights that are blended together to
make up an MON 89034 x TC1507 Seed Blend corn product by seed lot.
All records must be maintained at the Monsanto blending facility and must be available for the EPA review
upon request.
f. Annual Reporting Requirements for MON 89034 x TC1507 Seed Blend corn
The following annual reports must be submitted:
1. Compliance Assurance Plan: Compliance Assurance Program activities, including IRM Grower Survey
results and on-farm assessment results for the prior year and plans for the compliance assurance program
for the current year, on or before January 31st each year.
2. Insect Resistance Monitoring Results (Cry1A.105, Cry1F, and Cry2Ab2): results of monitoring and
investigations of damage reports, August 31st of each year.
Should you wish to add/retain a reference to your company’s website on your label, then please be aware that
the website becomes labeling under FIFRA and is subject to review by the EPA. If the website is false or
misleading, the product will be considered to be misbranded and sale or distribution of the product is unlawful
under FIFRA section 12(a)(1)(E). 40 CFR § 156.10(a)(5) lists examples of statements the EPA may consider
false or misleading. In addition, regardless of whether a website is referenced on your product’s label, claims
made on the website may not substantially differ from those claims approved through the registration process.
Therefore, should the EPA find or if it is brought to our attention that a website contains false or misleading
statements or claims substantially differing from the EPA-approved registration, the website will be referred to
the EPA’s Office of Enforcement and Compliance Assurance.
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OPP Decision No. 542180   
Your release for shipment of this product constitutes acceptance of these conditions. If you fail to satisfy these
terms and conditions, the EPA will consider appropriate regulatory action including, among other things,
cancellation under FIFRA section 6(e).
A stamped copy of the label is enclosed for your records. A previously approved Confidential Statement of
Formula dated November 14, 2013 is on file for this product.
S i n c e r e l y ,
A l a n R e ynolds, Team Leader
M i c r o b i a l P e s t i c i d e s B r a n c h
Biopesticides and Pollution
P r e v e n t i o n D i v i s i o n ( 7 5 1 1 P )
Office of Pesticide Programs
Enclosure
Plant-Incorporated Protectant Label
MON 89034 × TC1507 Seed Blend
Insect-Protected, Herbicide-Tolerant Corn with an Interspersed Refuge
(OECD Unique Identifier: MON-89Ø34-3 × DAS-Ø15Ø7-1)
Active Ingredients:
Bacillus thuringiensis Cry1A.105 protein and the genetic material (vector PV-ZMIR245)
necessary for its production in corn event MON 89034 (OECD Uniq ue Identifier: MON-
89Ø34-3) ........................................................................................................... ≤ 0.0026%*
Bacillus thuringiensis Cry2Ab2 protein and the genetic material (vector PV-ZMIR245)
necessary for its production in corn event MON 89034 (OECD Uniq ue Identifier: MON-
89Ø34-3) ........................................................................................................... ≤ 0.0053%*
Bacillus thuringiensis Cry1F protein and the genetic material (vector PHP8999)
necessary for its production in corn event TC1507 (OECD Unique Identifier: DAS-
Ø15Ø7-1) .......................................................................................................... ≤ 0.0012%*
Other Ingredients:
The marker protein, Phosphinothricin Acetyltransferase (PAT), a nd the genetic material
(vector PHP8999) necessary for its production in corn event TC1507(OECD Unique
Identifier: DAS- Ø15Ø7-1) ............................................................................ ≤ 0.00045%*
*Maximum percent (wt/wt) of dry forage
MON 89034 × TC1507 Seed Blend contains 95% MON 89034 x TC1507 mixed with at
least 5% non-B.t. corn within a single lot of seed.
KEEP OUT OF REACH OF CHILDREN
CAUTION
EPA Registration No. 524-612
EPA Establishment No. 524-MO-002
Monsanto Company
800 North Lindbergh Blvd.
St. Louis, MO 63167
NET CONTENTS_______
11/07/2018
524-612
DIRECTIONS FOR USE
It is a violation of Federal law to use this seed in any manner inconsistent with this
labeling. Information regarding commercial production must be i ncluded in the
Technology Use Guide and/or Insect Resistance Management (IRM) Grower Guide.
MON 89034 x TC1507 Seed Blend can be used to protect corn plant s from leaf, stalk,
and ear damage caused by lepidopteran corn pests listed on this label. To help preserve
the effectiveness of B.t. corn technologies, growers planting MON 89034 x TC1507 Seed
Blend are required to follow an Insect Resistance Management (IRM) Plan.
Grower agreements will specify that growers must adhere to the refuge requirements that
will be described on the bag or bag-tag for MON 89034 x TC1507 Seed Blend corn or
other applicable product use documents.
Sales of corn hybrids that contain Monsanto’s B.t. corn plant-incorporated protectants
must be accompanied by information on planting, production, and insect resistance
management. This information may appear on either an IRM Growe r Guide or on the
corn seed bag or bag-tag.
Corn seed bags or bag-tags for products containing MON 89034 x TC1507 Seed Blend
must include the refuge requirement.
INSECT RESISTANCE MANAGEMENT
Growers are instructed to read information on insect resistance management in the IRM
Grower Guide or the bag or bag-tag.
This product is a seed mixture containing up to 95% MON 89034 × TC1507 and a minimum
of 5% non-B.t. seed that when planted creates an interspersed refuge within the field. There
are no requirements for a separa te structured refuge for MON 89 034 × TC1507 Seed Blend
corn when planted in the U.S. corn growing area, including Alas ka and Hawaii, because the
refuge seed is contained within the bag/container.
The i n t e rspersed refuge can only be u sed b y planting seed corn specifically generated by
qualified seed producers/conditioners licensed by the registran t. The seed producer must
ensure a minimum of 5% non -B.t. refuge seed is included with the MON 89034 ×
TC1507 in each lot of seed corn.
The 95/5% MON 89034 x TC1507 Seed Blend product may be planted in cotton growing
areas; however, planting the 95/5% MON 89034 x TC1507 Seed Blend in cotton growing
areas still requires planting an additional 20% structured refu ge (block, strips, or border)
as defined for MON 89034 x TC1507 EPA Registration No. 524-585. The interspersed
refuge option for MON 89034 x TC1507 Seed Blend does not alone comply with
refuge requirements in cotton growing areas.
Additional refuge requirements in the cotton-growing area where corn earworm is a
significant pest
In the cotton-growing area, as defined below, MON 89034 × TC150 7 Seed Blend
requires the planting of an additional 20% structured refuge (i.e. 20 acres of non-B.t. corn
for every 80 acres of MON 89034 × TC1507 Seed Blend planted).
The 20% refuge must be planted with corn hybrids that do not co ntain B.t. technologies
for the control of lepidopteran pests.
The 20% refuge and the MON 89034 × TC1507 Seed Blend should be sown on the same
day, or with the shortest window possible between planting date s to ensure that corn root
development is similar among varieties. The 20% refuge may be p lanted as an in-field or
adjacent (e.g., across the road) refuge or planted as a separat e block that is within
1/2 mile of the MON 89034 × TC1507 Seed Blend field. In-field r efuge options include
blocks, perimeter strips (i.e., strips around the field), or in -field strips. If perimeter or in-
field strips are implemented, the strips must be at least 4 con secutive rows wide. The
refuge can be protected from lepidopteran damage by use of non- B.t. insecticides if the
population of one or more target pests of MON 89034 × TC1507 Se ed Blend in the
refuge exceeds economic thresholds. Insecticide treatments for control of insects listed
on this label may be applied only if economic thresholds are re ached for one or more of
these target pests. Economic thresholds will be determined using methods recommended
by local or regional professionals (e.g., Extension Service age nts, crop consultants).
Microbial B.t. insecticides must not be applied to the field containing a see d mix
interspersed refuge.
The cotton-growing area requiring the additional 20% refuge con sists of the following
states: Alabama, Arkansas, Georgia, Florida, Louisiana, North Carolina, Mississippi,
South Carolina, Oklahoma (only the counties of Beckham, Caddo, Comanche, Custer,
Greer, Harmon, Jackson, Kay, Kiowa, Tillman, and Washita), Tenn essee (only the
counties of Carroll, Chester, C rockett, Dyer, Fayette, Franklin , Gibson, Hardeman,
Hardin, Haywood, Lake, Lauderdale, Lincoln, Madison, Obion, Rut herford, Shelby, and
Tipton), Texas (except the counties of Carson, Dallam, Hansford , Hartley, Hutchinson,
Lipscomb, Moore, Ochiltree, Roberts, and Sherman), Virginia (on ly the counties of
Dinwiddie, Franklin City, Greensville, Isle of Wight, Northampt on, Southampton,
Suffolk City, Surrey, and Sussex) and Missouri (only the counti es of Dunklin, New
Madrid, Pemiscot, Scott, and Stoddard).
Corn Insects Controlled or Suppressed
European corn borer (ECB) Ostrinia nubilalis
Southwestern corn borer (SWCB) Diatraea grandiosella
Southern cornstalk borer (SCSB) Diatraea crambidoides
Corn earworm (CEW) Helicoverpa zea
Fall armyworm (FAW) Spodoptera frugiperda
Stalk borer Papaipema nebris
Lesser corn stalk borer Elasmopalpus lignosellus
Sugarcane borer (SCB) Diatraea saccharalis
Black cutworm Agrotis ipsilon
MON 89034 × TC1507 Seed Blend is a product of Monsanto’s and Dow AgroSciences’
research programs, offering unique genetic characteristics for specific grower needs and
may be protected by one or more U.S. patents found at the following web page:
www.monsantotechnology.com