crop-chem-docs/corpus/epa_ppls/524-581.md

# MON 89034 X TC1507 X MON 88017 X DAS 59122-7

- EPA Reg No: **524-581**
- 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 Cry34Ab1 and Cry35Ab1 proteins and the genetic material necessary for their production in corn (0.0194%); Bacillus thuringiensis Cry3Bb1 protein and the genetic material necessary (vector ZMIR39) for its production in corn (0.0079%); 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: 2018-11-19
- Source PDF: https://www3.epa.gov/pesticides/chem_search/ppls/000524-00581-20181119.pdf

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EPA Form 8570-6 
U.S. ENVIRONMENTAL PROTECTION AGENCY 
Office of Pesticide Programs 
Biopesticides and Pollution Prevention Division (7511P) 
1200 Pennsylvania Ave., N.W. 
Washington, D.C. 20460
EPA Reg. Number: 
524-581
Date of Issuance: 
11/19/2018 
NOTICE OF PESTICIDE: 
☒Registration
☐Reregis
tration
Term of Issuance: 
Uncondition
al 
(under FIFRA, as amended) Name of Pesticide Product:
MON 89034 × TC1507 × 
MON 88017 × DAS-59122-7 
Name and Address of Registrant (include ZIP Code): 
Monsanto Company 
800 North Lindbergh Blvd 
St. Louis, Missouri 63167 
Note: Changes in labeling differing in substance from that accepted in connection with this registration must be submitted to and accepted by the Biopesticides 
and Pollution Prevention Division prior to use of the label in commerce. In any correspondence on this product, always refer to the above EPA Registration 
Number.
On the basis of infor
mation furnished by the registrant, the above-named pesticide is hereby registered 
under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA or the Act). 
Registration is in no way to be construed as an endorsement or recommendation of this product by the U.S. 
Environmental Protection Agency (EPA). In order to protect health and the environment, the Administrator, 
on his or her motion, may at any time suspend or cancel the registration of a pesticide in accordance with 
the Act. The acceptance of any name in connection with the registration of a product under the Act is not to 
be construed as giving the registrant a right to exclusive use of the name or to its use if it has been covered 
by others. 
This product is unconditionally registered in accordance with FIFRA section 3(c)(5) provided that you 
comply with the following terms: 
1. The subject registration will automatically expire at midnight on Novemb
er 30th, 2026.
Signature of Approving Official:
Alan Reynolds, Team
 Leader 
Emerging Technologies Branch 
Biopesticides and Pollution Prevention Division (7511P) 
Date: 
 11/19/2018

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
2. The subject registration will be limited to 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), Bacillus thuringiensis Cry1F protein and the genetic
material (vector PHP8999) necessary for its production in corn event TC1507 (OECD Unique Identifier:
DAS-Ø15Ø7-1), Bacillus thuringiensis Cry3Bb1 protein and the genetic material (vector PV-ZMIR39)
necessary for its production in corn event MON 88017 (OECD Unique Identifier: MON-88Ø17-3) and
Bacillus thuringiensis Cry34Ab1 and Cry35Ab1 proteins and the genetic material (vector PHP17662)
necessary for their production in corn event DAS-59122-7 (OECD Unique Identifier: DAS-59122-7) for
use in MON-89034 × TC1507 × MON-88017 × DAS-59122-7 (OECD Unique Identifier: MON-89Ø34-
3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) field corn.
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 protect ant (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. The Monsanto Company (hereafter referred to as Monsanto) must commit to do the following Insect
Resistance Management (IRM) Program, consisting of the following elements:
 Requirements for Monsanto to implement an IPM-based stewardship program designed to
reduce selection pressure for corn rootworm (CRW) resistance.
 Requirements relating to creation of a non-Bt refuge in conjunction with the planting of any
acreage of MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn;
 Requirements for Monsanto to prepare and require MON 89034 x TC 1507 x MON 88017 x
DAS-59122-7 corn users to sign grower agreements that impose binding contractual obligations
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 Cry1F, Cry1A.105, and 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 Cry1F, Cry1A.105, and Cry2Ab2 was detected, as well as to report on activity
under the plan to EPA.
 Requirements for Monsanto to investigate reports of unexpected CRW damage to MON
89034 x TC1507 x MON 88017 x DAS-59122-7 corn from growers (“performance

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
inquiries”) and sample CRW to determine if the insects are resistant to Cry34/35Ab1 or 
Cry3Bb1. 
 Requirements for Monsanto to recommend CRW management options to growers in response
to cases of unexpected CRW damage to MON 89034 x TC1507 x MON 88017 x DAS-59122-
7 corn.
 Requirements regarding mitigation and notification actions that Monsanto would take in
the event that CRW resistance was detected.
 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 x MON 88017 x DAS-59122-7 corn. Seed
bags and/or bag tags for corn hybrids that contain plant- incorporated protectants produced in
MON 89034 x TC1507 x MON 88017 x DAS-59122-7 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.
 Requirements for Monsanto to submit reports on CRW IPM stewardship and resistance
monitoring within the time frames specified in this registration notice.
a. Integrated Pest Management Stewardship Program
1. Monsanto must implement an IPM-based stewardship program for MON 89034 x TC1507 x MON 88017 x
DAS-59122-7 corn. This program must be designed to reduce selection pressure for corn rootworm (CRW)
resistance by encouraging growers to engage in a multi-year crop rotation strategy involving the use of one
or more of the following: a non-CRW host crop (e.g., soybean), pyramided Bt corn Plant Incorporated
Protectants (PIPs), other PIP corn products with different modes of action, and/or non-Bt or non-CRW
protected Bt corn. As part of the stewardship program, Monsanto must update the technology use
guide/grower guide and other grower educational materials to indicate that application of an insecticide to
the soil surface, in furrows, and/or incorporated into the soil (referred to as “soil applied insecticide”, “soil
insecticide” or “SAI”) with MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn is not
recommended for control of CRW except under limited circumstances and in consultation with extension,
crop consultants or other local experts. Grower education materials should also state that SAIs should not be
necessary for CRW control with pyramided CRW trait Bt corn product(s). As part of the stewardship
program, Monsanto must promote the ABSTC/NCGA Best Management Practices (BMPs) for CRW
control. Implementation of the IPM strategy can include:
 Grower education initiatives or incentives.
 Outreach to extension and consultant groups.
2. Monsanto must submit an annual report to EPA documenting activities conducted under the IPM
stewardship program. This report must include an anonymous survey of grower practices, including
adoption levels of the various crop rotation options (if employed) and other elements of the stewardship

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
program. Monsanto may combine this product with other registered products to submit one annual report. 
The report must be submitted by January 31st each year. 
b. Refuge Requirements for MON 89034 x TC1507 x MON 88017 x DAS-59122-7 Corn
The following information must be included on the product bag or bag-tag as sold per respective region and in 
the Grower Guide: 
These refuge requirements do not apply to seed propagation of inbred and hybrid corn seed up to a total of 
20,000 acres per county and up to a combined U S total of 250,000 acres per PIP active ingredient per registrant 
per year Grower agreements (also known as stewardship agreements) will specify that growers must adhere to 
the following refuge requirements as described in the grower guide/product use guide and/or in supplements to 
the grower guide/product use guide. 
A common refuge must be planted for both corn borers and corn rootworms. The refuge must be planted with 
corn hybrids that do not contain Bt technologies for the control of corn rootworms or corn borers. The refuge 
and MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn should be sown on the same day or with the 
shortest window possible between planting dates to ensure that corn root development is similar among 
varieties. If the refuge is planted on rotated ground, then the MON 89034 x TC1507 x MON 88017 x DAS-
59122-7 corn must also be planted on rotated ground. If the combined refuge is planted on continuous corn the 
MON 89034 x TC1507 x MON 88017 x DAS-59122-7 field may be planted on either continuous or rotated 
land (option encouraged where WCRW rotation resistant biotype may be present). Refuge options are based on 
the planting of MON 89034 x TC1507 x MON 88017 x DAS-59122-7 in cotton or non-cotton growing regions 
and the insect pressure present in those locations. The refuge sizes for these regions are either 20% in cotton 
growing regions (i.e. 20 acres of non Bt corn for every 80 acres planted) or 5% in non-cotton growing regions (5 
acres of non Bt corn for every 95 acres of MON 89034 x TC1507 x MON 88017 x DAS-59122-7 planted). If 
corn rootworms are significant within a region the structured refuge must be planted as an in-field or adjacent 
refuge using corn hybrids that do not contain Bt technologies for the control of corn borers or corn rootworms. 
It can be planted as a block within or adjacent (e.g. across the road) to the MON 89034 x TC1507 x MON 
88017 x DAS-59122-7 corn 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 consecutive rows wide. 
The refuge can be protected from lepidopteran damage by use of non Bt insecticides if the population of one or 
more target lepidopteran pests of MON 89034 x TC1507 x MON 88017 x DAS-59122-7 in the refuge exceeds 
economic thresholds. In addition, the refuge can be protected from CRW damage by an appropriate seed 
treatment or soil insecticide however insecticides labeled for adult CRW control must be avoided in the refuge 
during the period of CRW adult emergence. If insecticides are applied to the refuge for control of CRW adults 
the same treatment must also be applied in the same timeframe to MON 89034 x TC1507 x MON 88017 x 
DAS-59122-7. Economic thresholds will be determined using methods recommended by local or regional 
professionals (e.g. Extension Service agents crop consultants). If corn rootworms are not significant within a 
region the structured refuge may be planted as an in-field or adjacent refuge or as a separate block that is within 
1/2 mile of the MON 89034 x TC1507 x MON 88017 x DAS-59122-7 field. The structured refuge must be 
planted with corn hybrids that do not contain Bt technologies for the control of corn borers or corn rootworms. 
Economic thresholds will be determined using methods recommended by local or regional professionals (e.g. 
Extension Service agents crop consultants).

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
Region Refuge Size In field adjacent 
refuge is allowed 
Refuge separated 
by up to ½ mile is 
allowed 
Cotton growing where CEW is a significant pest 
and WCRW, NCRW, and MCRW are not 
significant: AR, NC, SCGA, FL, TN (only the 
counties of Carroll, Chester, Crockett, Dyer, 
Fayette, Franklin, Gibson, Hardeman, Hardin, 
Haywood, Lake, Lauderdale, Lincoln, Madison, 
Obion, Rutherford, Shelby, and Tipton) AL, MS, 
LA, VA (only the counties of Dinwiddie, 
Franklin City, Greensville, Isle of Wight, 
Northampton, Southampton, Suffolk City, Surrey, 
and Sussex). 
20% non Bt corn Yes Yes 
Cotton growing where CEW is a significant pest 
and WCRW, NCRW, and/or MCRW are 
significant: TX (except the counties of Carson, 
Dallam, Hansford, Hartley, Hutchinson, 
Lipscomb, Moore, Ochiltree, Roberts, and 
Sherman), OK (only the counties of Beckham, 
Caddo, Comanche, Custer, Greer, Harmon, 
Jackson, Kay, Kiowa, Tillman, and Washita), MO 
(only the counties of Dunklin, New Madrid, 
Pemiscot, Scott, and Stoddard). 
20% non-Bt corn Yes No 
Cotton growing where CEW is not a significant 
pest and WCRW, NCRW, and MCRW are not 
significant: NM, AZ, CA, NV. 
5% non- Bt corn Yes Yes 
Non-cotton growing where WCRW. NCRW. and 
MCRW are not significant: OR, WA, ID, MT, 
WY, UT, VA (except the counties of Dinwiddie, 
Franklin City, Greensville, Isle of Wight, 
Northampton, Southampton, Suffolk City, Surrey, 
and Sussex), WV, PA, MD, DE, CT, RI, NJ, NY, 
ME, MA, NH, VT, HI, AK, TN (except the 
counties of Carroll, Chester, Crockett, Dyer, 
Fayette, Franklin, Gibson, Hardeman, Hardin, 
Haywood, Lake, Lauderdale, Lincoln, Madison, 
Obion, Rutherford, Shelb
y, and Tipton) 
5% non- Bt corn Yes Yes 
Non-cotton growing where WCRW, NCRW, 
and/or MCRW are significant: KS, NE, SD, ND, 
MN, IA, MO (except the counties of Dunklin, 
New Madrid, Pemiscot, Scott, and Stoddard), IL, 
WI, MI, IN, OH, KY, CO, OK (except the 
counties of Beckham, Caddo, Comanche, Custer, 
Greer, Harmon, Jackson, Kay, Kiowa, Tillman, 
and Washita), TX (only the counties of Carson, 
Dallam, Hansford, Hartley, Hutchinson, 
Lipscomb, Moore, Ochiltree, Roberts, and 
Sherman) 
5% non- Bt corn Yes No

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
c. Grower Agreements for MON 89034 x TC1507 x MON 88017 x DAS-59122-7 Corn
1. Persons purchasing MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn must sign a grower
agreement. The term grower agreement refers to any grower purchase contract, license agreement, or
similar legal document.
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 x MON 88017 x DAS-59122-7 corn will affirm annually that they are contractually bound to
comply with the requirements of the IRM program.
4. Monsanto must continue to use it s current grower agreement for MON 89034 x TC1507 x MON 88017 x
DAS-59122-7 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 x MON 88017 x DAS-59122-7 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 x MON 88017 x DAS-59122-7 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.
d. IRM Education and IRM Compliance Monitoring Program for MON 89034 x TC1507 x MON
88017 x DAS-59122-7 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 x MON 88017 x DAS-
59122-7 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 x MON 88017 x DAS-59122-7
corn users to pursue optional elements of the IRM program relating to refuge configuration and proximity
to MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn fields. The education program shall involve

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
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 x MON 88017 x DAS-59122-7 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
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 x MON 88017 x DAS-59122-7
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 x MON 88017 x DAS-
59122-7 corn. The survey shall be conducted in odd-numbered years beginning in 2017 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 x MON 88017
x DAS-59122-7 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

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
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 
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 designe d 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 u sefulness 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 x MON 88017 x DAS-59122-7 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 x MON 88017 x DAS-59122-7 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

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EPA Reg. No. 524‐581 
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program, Monsanto shall take appropriate action, consistent with its phased compliance approach. 
13. If a grower, who purchases MON 89034 x TC1507 x MON 88017 x DAS-59122-7 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 x MON 88017 x DAS-59122-7 compliance assurance program activities and results for
the prior year and plans for the MON 89034 x TC1507 x MON 88017 x DAS-59122-7 compliance
assurance program for the current year. Within one month of submitting this report to EPA, the Monsanto
shall meet with EPA to discuss its findings. The report must inform EPA of the number of growers deemed
ineligible to purchase Bt corn 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 x MON 88017
x DAS-59122-7 sold and delivered. The purpose of this bag tag is to remind growers that MON
89034 x TC1507 x MON 88017 x DAS-59122-7 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 x MON 88017 x
DAS-59122-7 is used.
19. Monsanto will use its available MON 89034 x TC1507 x MON 88017 x DAS-59122-7 sales records and
other information to refine grower lists for on-farm assessments of their compliance with refuge
requirements:

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EPA Reg. No. 524‐581 
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 Identify for potential on-farm assessment growers whose sales information indicates they have
purchased MON 89034 x TC1507 x MON 88017 x DAS-59122-7 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 x MON
88017 x DAS-59122-7 corn product to reflect the adoption rate and level of refuge compliance for the
product.
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.
e. Insect Resistance Monitoring and Mitigation Plan for MON 89034 x TC1507 x MON 88017 x
DAS-59122-7 Corn
1. EPA is imposing the following conditions for the Cry1F, Cry1A.105, and Cry2Ab2 toxins expressed
in MON 89034 x TC1507 x MON 88017 x DAS-59122-7
Monsanto w
ill monitor for resistance to Cry1F, Cry1A.105, or Cry2Ab2 expressed in MON 89034 x TC1507 
x MON 88017 x DAS-59122-7 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 sam
ple 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

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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 x MON 88017 x DAS-59122-7 corn and/or changes in resistance allele frequency in 
response to the use of MON 89034 x TC1507 x MON 88017 x DAS-59122-7 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 
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 x MON 88017 x DAS-59122-7 
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 Cry1F, Cry1A.105, and 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 x MON 88017 x DAS-59122-7 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

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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 resistance 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 w
ill 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 
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 m
ean 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 x MON 88017 
x DAS-59122-7 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 x MON 88017 x DAS-59122-7 corn
fields in the affected region to control the target pest during the immediate growing season.
 Destroy MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn crop residues in the affected

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EPA Reg. No. 524‐581 
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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 m
ean, 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).
 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 fo
llowing 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;

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 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. 
2. EPA is imposing the following conditions for the Cry34/35Ab1 and Cry3Bb1 toxins expressed in MON
89034 x TC1507 x MON 88017 x DAS-59122-7 corn: 
a) Investigation of Reports of Unexpected Levels of Damage (UXD) by Corn Rootworm (CRW):
Performance Inquiries
(1) Monsanto is required to investigate "perform
ance inquiries" (i.e., reports of unexpected CRW
damage to MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn) from growers. Fields
(defined as a tract separated by permanent boundaries such as fences, permanent waterways,
woodlands, croplines not subject to change because of farming practices, or other similar
features) with unexpected damage that meet both of the criteria below must be subjected to the
follow-up actions in part 2) below:
a. The affected plants are confirmed to be MON 89034 x TC1507 x MON 88017 x DAS-
59122-7 corn plants (take leaf samples to determine the presence of the CRW-active Bt
protein); and
b. Corn rootworm feeding caused root damage with a Node Injury Score (NIS) > 0.5 on
at least 50% of plants surveyed in a transect sampling of the damaged site(s) within the
field.
(2) Follow-up actions (performance inquiries). For MON 89034 x TC1507 x MON 88017 x DAS-
59122-7 corn fields meeting the criteria in part 1) above, Monsanto must take the following
actions:
a. Collect at least 250 (ideally 500 or more) CRW adult individuals from the damaged
site within the field in question. Collections may be extended to the whole field, if
necessary to obtain sufficient CRW adult individuals. Collected populations must be
subjected to the steps described for "investigation of populations of concern" in section
e(2)(b) below.
o If collections are unsuccessful, visit affected farm or field the following year

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(assuming the grower continues to be a customer and repurchases seed and does 
not rotate the field to a non-host crop) and attempt to collect CRW adults. If beetles 
are not present the subsequent year, see section e(2)(b)(3)(c) below. 
b. Review with the grower their CRW management practices and provide CRW
management recommendations including an assessment of corn fields with similar
trait(s) adjacent to the affected corn field that are managed by the same grower.
c. Use of single trait products containing the CRW traits in MON 89034 x TC1507 x
MON 88017 x DAS-59122-7 in fields with unexpected damage in previous years
should be discouraged. Recommended management options include, but are not
limited to, the following:
o Primary option:
• Rotation to non-host crop (e.g., soybean)
o Secondary options:
• Use of pyramided Bt corn products one or more different CRW PIP trait(s)
• Use of different single-CRW PIP traits (i.e., an alternative CRW-active PIP)
• Use of non-Bt or non-CRW protected corn
o Tertiary options:
• If additional pest management need is determined beyond the secondary
options listed above, use of the same pyramided Bt corn product is acceptable if
it is very unlikely that both of the traits are affected (e.g., the affected field
experienced UXD to one of the traits in the product in the previous year, the
NIS is less than 1.0, there has been no continuous use of the second trait in the
product in the affected field, and Monsanto has not been informed of resistance
to the second trait in the county)
• Additional corn rootworm control tools (e.g., soil applied insecticides,
chemigation) should be considered
d. If field(s) with UXD is/are planted to a non-host crop (e.g., soybean) the following
year, then the area will be considered “mitigated” (as discussed in section e(2)(b)(3)(d)
below) even if subsequent bioassay results show that the population was resistant. No
further action will be required by Monsanto for the UXD case.
(3) Monsanto must submit an annual report to EPA detailing activities related to investigations of
unexpected damage (UXD). This report will include the information from the most recent and
previous corn growing seasons:
a. Information from the most recent season:

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EPA Reg. No. 524‐581 
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o The number of UXD reports investigated.
o Location (by county and state).
o CRW sampling (number and location of populations collected).
b. Information from the previous season:
o The final disposition of UXD fields from the previous season (i.e., the management
practices employed in response to UXD if the grower continues to be a customer.
o Results from bioassays conducted on CRW populations from UXD fields where the
primary management option, rotation to non-host crop, was not used.
c. Grower information, such as farm addresses or other personally identifiable information,
or other sensitive business/customer information must not be included in this report. This
report must be submitted by November 30th each year.
b) Investigation of Population of Concern
1. Monsanto must conduct investigations of all CRW populations collected as part of the perform
ance
inquiry process in section e(2)(a) above. These investigations must include the use of an EPA-approved
bioassay to determine if sampled CRW populations are resistant to any of the CRW PIP toxins in MON
89034 x TC1507 x MON 88017 x DAS-59122-7. Acceptable assays must be able to function as
diagnostic tools capable of distinguishing resistant populations from susceptible ones. Unless previously
approved, Monsanto must consult with EPA on their bioassay prior to its use.
2. A CRW population will be considered by EPA to be resistant to a CRW PIP toxin if the following
criteria are met and additional collections and testing are not deemed to be necessary (based on part 3)
below):
a. An initial performance inquiry investigation results in a finding of Unexpected Damage; and
b. Where green tissues are available and if plants are unusually stressed due to agronomic and/or
environmental factors, Bt protein levels in affected plants are found to be within the
documented range for that hybrid (if data are available); and
c. Either (A): On-plant bioassays of insect collections from the UXD fields result in the
following two statistically relevant comparisons
i. A statistically significant difference in measures of either mortality or sublethal effects
(growth/development) between the field population and a relevant susceptible control
population (i.e., one that responds as a typical susceptible field population) on Bt corn
containing the single PIP and/or lack of a statistically significant difference in measures
of mortality or sublethal effect between the field population and a resistant positive
control population1; and
1 If a resistant positive control population is not available or accessible, Monsanto must consult with EPA prior to initiating bioassays 
and work to develop an appropriate resistant positive control population.

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ii. A lack of a statistically significant difference in the same measures of the field population
raised on Bt corn containing the single PIP and non-Bt corn plants.
Or (B): Sublethal seedling bioassay of insect collections from the UXD fields result in two 
statistically relevant comparisons 
i. A statistically significant difference in measures of sublethal effects
(growth/development) for populations on Bt corn containing the single PIP (normalized
using non-Bt) seedlings between the field population and a relevant susceptible control
population where available or historical field populations and/or lack of a statistically
significant difference in measures between the field population and a resistant positive
control population1; and
ii. A lack of a statistically significant difference in the same measures of the field
population raised on Bt corn seedlings containing the single PIP and non-Bt corn
seedlings
Or (C): Diet-based bioassays of insect collections from the UXD fields result in two 
statistically relevant comparisons 
i. A statistically significant difference in measures of lethal or sublethal effects
(growth/development) on diet containing the Bt protein (diagnostic concentration or
concentration-response measures) between the field population and a relevant
susceptible control population where available or historical field populations and/or
lack of a statistically significant difference in measures between field population and a
resistant positive control population1; and
ii. Either a lack of a statistically significant difference in the same measures of the field
population exposed to diet containing the Bt protein (diagnostic concentration) and diet
not containing the Bt protein and/or lack of a statistically significant difference in
measures between the field population and a resistant positive control population, or
lack of a statistically significant concentration and/or lack of a statistically significant
difference in concentration response between the field and a resistant positive control
population1.
3. Mitigation, as detailed in section e(2)(c) below, is required for any CRW population that meets EPA’s
resistance criteria above for any of the CRW traits in MON 89034 x TC1507 x MON 88017 x DAS-
59122-7, unless the circumstances described below are applicable.
a. To minimize the potential for incorrectly reaching a conclusion of resistance, another year of
CRW adult collections and additional testing is needed to determine resistance if:
i. The results of the bioassays are inconclusive (e.g., the results of the statistical analysis are
unclear because of low sample sizes) or
ii. Another reasonable explanation for the unexpected damage exists (e.g., high pest pressure
and/or high plant stress).

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b. In these cases, Monsanto and EPA will discuss and align on next steps before reaching any
resistance conclusion.
c. If CRW collections are not possible in the current year or subsequent year due to successful
management practices, then no further investigation is needed. The population would be
considered "mitigated" meaning, in this case, that the population is suppressed or extirpated for
the UXD field. However, EPA recommends that Monsanto continue to be vigilant in areas where
CRW populations were successfully mitigated.
d. If a UXD field receives non-host crop (e.g., soybean) rotation the following year as described in
Section e(2)(a)(2) above, no additional mitigation is subsequently required.
c) Mitigation of CRW Populations Meeting EPA’s Resistance Criteria
1. For any CRW population found to be resistant to one or m
ore of the CRW traits in MON 89034 x
TC1507 x MON 88017 x DAS-59122-7 under EPA’s criteria described in section e(2)(b) above,
Monsanto must take the following steps:
a) Monsanto must inform EPA of all the results of the bioassays as soon as possible, but at least
within 30 days if measures are triggered.
b) The mitigation action area (MAA) is defined as the growers’ farming operation up to a ½ mile
radius from the damaged site that produced the resistant population.
c) Within 30 days of informing EPA of the results of the bioassays, Monsanto must notify state
extension agents and crop consultants who operate within the county in which resistance was
identified. Information shared must include identification of the county in which resistance was
detected and trait(s) affected.
d) Within the MAA, Monsanto must do the following:
i. Prior to finalizing the grower’s seed order for the following season, inform the affected
grower and other registrants that hold registrations containing the compromised trait(s).
Monsanto must also inform neighboring growers if those growers are customers of
Monsanto. Information shared must include identification of the county in which
resistance was detected and trait(s) affected;
ii. Discontinue sales/planting of products containing the compromised trait(s) without
additional/alternative (i.e. non-compromised) CRW traits until resistance has been
demonstrated to have been mitigated. Other Bt registrants selling such products in the
MAA are encouraged, but cannot be required, to follow suit;
iii. Monsanto must monitor the resistant population in the MAA, as long as grower remains a
customer of the company, until mitigation has been demonstrated as described in part e
below unless otherwise agreed with EPA.
iv. Require any pyramids sold by Monsanto containing the compromised trait(s) be planted
with a 20% refuge until resistance has been demonstrated to have been mitigated. Other
Bt corn registrants selling such pyramided products in the MAA are encouraged, but
cannot be required by this term of registration, to follow suit;

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v. For Monsanto’s affected customer’s field(s), the mitigation goal is to control the resistant
CRW population. Within the MAA Monsanto shall encourage the use of “Mitigation
Practices” including:
1. Primary option: Rotation to a non-host crop (e.g., soybean);
2. Secondary options:
a. Use of pyramided Bt corn products with different CRW PIP traits;
b. Only in the case that the resistance definition for one of the CRW traits in the
MON 89034 x TC1507 x MON 88017 x DAS-59122-7 is not met, continued
use of the product with a 20% refuge;
c. Use of different single-CRW PIP traits (i.e., an alternative CRW-active PIP);
d. Use of non-Bt corn or non-CRW protected corn (with/without soil-applied
insecticide);
3. Tertiary options:
a. If additional pest management need is determined beyond the secondary
options listed above, additional CRW control tools (e.g., soil insecticides,
seed-applied insecticides, chemigation) should be used.
b. Use of foliar applications to control adults (when appropriate economic
thresholds have been met) may be used in conjunction with one or more of
the above;
e) A resistant CRW population in the MAA will be considered mitigated if one of the following
criteria is met:
i. Corn fields within the MAA are rotated to a non-host crop (e.g. soybean) for one
growing season.
ii. After implementation of mitigation practices (part d.v above), resistance
monitoring (sampling) is conducted but few CRW are found (i.e., <0.1 adults per
plant) and environmental conditions (e.g., weather) are unlikely to be responsible
for the lack of adult CRW presence. If environmental conditions are a factor, then
monitoring should continue for another season.
iii. After implementation practices (part d.v above), resistance monitoring (sampling)
is conducted, CRW are found and collected, and bioassays (section e(2)(b)(2)
above) show that the population susceptibility to the compromised trait(s) has
returned to baseline levels.
f) The mitigation actions in part d above can be lifted, and growers can resume the use of MON
89034 x TC1507 x MON 88017 x DAS-59122-7 corn as a primary tool for CRW management in
the MAA, only when Monsanto demonstrates that successful mitigation as described in part e
above has been achieved.

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2. Based on further research to understand CRW resistance to Bt PIPs, EPA will consider refinements to
the resistance mitigation program. Such research may include characterizing the genetics of resistance
(e.g., number of genes, functional dominance, mechanism of resistance, and cross-resistance) and the
biology of resistant insects (e.g., fitness in the presence and absence of the product), and other control
tactics.
f. Annual Reporting Requirements for MON 89034 x TC1507 x MON 88017 x DAS-59122-7 corn
The following annual reports must be submitted: 
1. Compliance Assurance Plan: Compliance Assurance Program activities, including IRM Grower Survey
results (only for years in which the survey was conducted) 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 Monitori ng Results (Cry1A.105, Cry2Ab2, and Cry1F only): results of monitoring and
investigations of damage reports, August 31st of each year. 
3. IPM Stewardship Program (Cry34/35Ab1 and Cry3Bb1 only): Activities conducted under the IPM
stewardship program, including an anonymous survey of grower practices, adoption levels of the various
crop rotation options (if employed) and other elements of the stewardship program, on or before January
31st of each year.
4. Unexpected Damage Investigations (Cry34/35Ab1 and Cry3Bb1 only): Activities related to
investigations of unexpected damage (UXD), including number and location of UXD cases, insect
sampling, bioassays, and final disposition of UXD fields from the most recent and previous corn
growing seasons, on or before November 30th 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. 
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 30, 2013 is on file for this product.

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EPA Reg. No. 524‐581 
OPP Decision No. 542181 
If you have any questions, please contact Matt Weiner by phone at (703) 347-0333 or via email at 
weiner.matthew@epa.gov. 
S
i n c e r e l y , 
A
l a n R eynolds, Team Leader 
E
m e r g i n g T e chnologies Branch 
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 × MON 88017 × DAS-59122-7 
Insect-Protected, Herbicide-Tolerant Corn 
(OECD Unique Identifier: MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) 
Active Ingredients: 
Bacillus thuringiensis Cry1A.105 protein and the genetic material necessary for its p roduction (vector 
PV-ZMIR245) in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn (OECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ...................................... ≤ 0.0026%* 
Bacillus thuringiensis Cry2Ab2 protein and the genetic material necessary for its pro duction (vector PV-
ZMIR245) in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn ( OECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ..................................... ≤ 0.0053%* 
Bacillus thuringiensis Cry1F protein and the genetic material necessary for its production (vector 
PHP8999) in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn ( OECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ...................................... ≤ 0.0012%* 
Bacillus thuringiensis Cry3Bb1 protein and the genetic material necessary for its pro duction (vector PV-
ZMIR39) in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn (O ECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ...................................... ≤ 0.0079%* 
Bacillus thuringiensis Cry34Ab1 protein and the genetic material necessary (vector PHP17662) for its 
production in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn (OECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ..................................... ≤ 0.0194%* 
Bacillus thuringiensis Cry35Ab1 protein and the genetic material necessary (vector PH P17662) for its 
production in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn (OECD Unique Identifier: 
MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) ..................................... ≤ 0.0042%* 
Other Ingredients: 
CP4 EPSPS protein (5-enolpyruvylshikimate-3-phosphate synthase) and the genetic material necessary 
(vector PV-ZMIR39) for its production in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn 
(OECD Unique Identifier: MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7) .............. 
 ..................................................................................................................................................... ≤ 0.0052%* 
PAT protein (phosphinothricin acetyl transferase) and the genetic material necessary (vectors PHP17622 
and PHP8999) for its production in MON 89034 × TC1507 × MON 88017 × DAS-59122-7 corn (OECD 
Unique Identifier: MON-89Ø34-3 × DAS- Ø15Ø7-1 × MON-88Ø17-3 × DAS-59122-7).. .... ≤ 0.00045%* 
* Perc
entage (wt/wt) on a dry weight basis for whole plant (forage)
KEEP OUT OF REACH OF CHILDREN 
CAUTION
EPA Registration No. 524-581 
EPA Establishment No. 524-MO-002
EPA Establishment No. 029964-IA-001 
Monsanto Company 
800 North Lindbergh Blvd. 
St. Louis, MO 63167 
NET CONTENTS:__________ 
11/19/2018
524-581

DIRECTIONS FOR USE 
I
t is a violation of Federal law to use this product in any manner inconsistent with its labeling. 
Information regarding commercial production reflected here and in the terms and conditions of 
this registration must be included in the Technology Use Guide. 
MON 89034 × TC1507 × MON 88017 × DAS-59122-7 protects corn crop s from leaf, stalk, and 
ear damage caused by corn borers and root damage caused by corn rootworm larvae. In order to 
minimize the risk of these pests developing resistance to MON 8 9034 × TC1507 × MON 88017 
× DAS-59122-7 corn, an insect resistance management plan must b e implemented which 
includes planting of a structured refuge. Growers who fail to comply with the IRM requirements 
risk losing access to Monsanto’s corn Plant-Incorporated Protectant (PIP) products. 
These refuge requirements do not apply to seed increase/propaga tion of inbred and hybrid seed 
corn and small scale research trials for observation. 
Several options for deployment of the refuge for MON 89034 × TC1507 × MON 88017 × DAS-
59122-7 are available to growers. These options are based on t he planting of MON 89034 × 
TC1507 × MON 88017 × DAS-59122-7 in cotton or non-cotton growin g regions and the insect 
pressure present in those locations. The refuge sizes for thes e regions are either 5% (i.e., 5 acres 
of non- Bt corn for every 95 acres MON 89034 × TC1507 × MON 88017 × DAS-59122-7 
planted) or 20% (20 acres of non- Bt corn for every 80 acres of MON 89034 × TC1507 × 
MON 88017 × DAS-59122-7 planted), and are presented in the table below: 
Region Refuge size In-field or 
adjacent refuge 
Refuge separated 
by up to ½ mile 
Cotton belt where CEW is a significant 
pest and WCRW, NCRW and MCRW are 
not significant: NC, SC, GA, FL, TN, AL, 
MS, LA, AR, northern TX 
20% non-Bt 
corn 
Yes Yes 
Cotton belt where CEW is a significant 
pest and MCRW is significant: southern 
TX 
20% non-Bt 
corn 
Yes No 
Cotton belt where CEW is not a significant 
pest and WCRW, NCRW and MCRW are 
not significant: NM, AZ, CA, NV 
No
n-cotton states where WCRW, NCRW 
and MCRW are not significant: OR, WA, 
ID, MT, WY, UT, CO, OK, VA, WV, PA, 
MD, DE, CT, RI, NJ, NY, ME, MA, NH, 
VT, HI, AK 
5% non-Bt 
corn 
Yes Yes 
Non-cotton-growing where WCRW, 
NCRW and/or MCRW are significant: KS, 
NE, SD, ND, MN, IA, MO, IL, WI, MI, 
IN, OH, KY 
5% non-Bt 
corn 
Yes No

If corn rootworms are significant within a region, the structur ed refuge must be planted as an in-
field or adjacent refuge using corn hybrids that do not contain Bt technologies for the control of 
corn borers or corn rootworms. It can be planted as a block wi thin or adjacent ( e.g., across the 
road) to the MON 89034 × TC1507 × MON 88017 × DAS-59122-7, peri meter strips (i.e., strips 
around the field), or in-field strips. If perimeter or in-fiel d strips are implemented, the strips 
must be at least four (4) consecutive rows wide. The refuge ca n be protected from lepidopteran 
damage by use of non- Bt insecticides if the population of one or more target lepidopte ran pests 
of MON 89034 × TC1507 × MON 88017 × DAS-59122-7 in the refuge e xceeds economic 
thresholds. In addition, the refuge can be protected from CRW damage by an appropriate seed 
treatment or soil insecticide; however, insecticides labeled fo r adult CRW control should be 
avoided in the refuge during the period of CRW adult emergence . Economic thresholds will be 
determined using methods recommended by local or regional profe ssionals ( e.g., Extension 
Service agents, crop consultants). A schematic of one common r efuge deployment option is 
shown below: 
If corn rootworms are not significant within a region, the stru ctured refuge may be planted as an 
in-field or adjacent refuge, or as a separate block that is wit hin ½ mile of the MON 89034 × 
TC1507 × MON 88017 × DAS-59122-7 field. The structured refuge must be planted with corn 
hybrids that do not contain Bt technologies for the control of corn borers or corn rootworms. 
Economic thresholds will be determined using methods recommende d by local or regional 
professionals (e.g., Extension Service agents, crop consultants ). A schematic of one refuge 
option with the refuge planted within a ½ mile of the MON 89034 × TC1507 × MON 88017 × 
DAS-59122-7 field is shown below: 
 MON 89034 x TC1507 x 
MON 88017 x DAS-59122-7 
Refuge 
Non - Bt Corn 
Structured Refuge 
Separated Structured Refuge 
Refuge 
Non - Bt corn 
Refuge 
Non - Bt corn 
MON 89034 x TC1507 x 
MON 88017 x DAS-59122-7 
≤ ½ mile

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 
 
 
Western corn rootworm (WCRW) Diabrotica virgifera virgifera 
Northern corn rootworm (NCRW) Diabrotica barberi 
Mexican corn rootworm (MCRW) Diabrotica virgifera zeae 
 
Sales of corn hybrids that contain Monsanto’s Bt corn plant pesticide must be accompanied by a 
Grower Guide which includes information on planting, production and insect resistance 
management and notes that routine applications of insecticides to control these insects are 
usually unnecessary when corn containing the Bt proteins is planted. 
 
MON 89034 x TC1507 x MON 88017 x DAS-59122-7 is a product of Mo nsanto's and Dow 
AgroSciences' research programs, offering unique genetic charac teristics for specific grower 
needs and may be protected by one or more of the following U.S. patents found at the following 
web page: www.monsantotechnology.com