1388 lines
76 KiB
Markdown
1388 lines
76 KiB
Markdown
# MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
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- EPA Reg No: **524-670**
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- Registrant: BAYER CROPSCIENCE, LLC
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- Signal word: Caution
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- Active ingredients: Bacillus thuringiensis Cry3Bb1 protein and the genetic material necessary (vector ZMIR39) for its production in corn (0.13%); Bacillus thuringiensis Cry1A.105 protein and genetic material necessary (vector PV-ZMIR245) for its production in corn (0.056%); Bacillus thuringiensis Cry2Ab2 protein and the genetic material necessary (vector PV-ZMIR245) for its production in corn (0.055%); Bacillus thuringiensis Vpb4Da2 protein and the genetic material necessary for its production in corn event MON 95275 (OECD Unique Identifier MON-95275-7) (0.0048%); Brevibacillus laterosporus Mpp75Aa1.1 protein and the genetic material necessary for its production in corn event MON 95275 (OECD Unique Identifier MON-95275-7) (0.025%); DvSnf7.1 RNA in corn event MON 95275 (OECD unique identifier MON-95275-7) (4.2e-05%); Bacillus thuringiensis Vip3Aa20 protein encoded by vector pNOV1300 in event MIR162 corn (SYN-IR162-4), % dw (0.15%)
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- Label accepted: 2026-03-09
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- Source PDF: https://www3.epa.gov/pesticides/chem_search/ppls/000524-00670-20260309.pdf
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---
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U.S. ENVIRONMENTAL PROTECTION AGENCY
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Office of Pesticide Programs
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Biopesticides and Pollution Prevention Division (7511M)
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1200 Pennsylvania Ave., N.W.
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Washington, D.C. 20460
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NOTICE OF PESTICIDE:
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܈Registration
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܆Reregistration
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(under FIFRA, as amended)
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EPA Reg. Number: Date of Issuance:
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524-670 3/9/2026
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Term of Issuance:
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Unconditional
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Name of Pesticide Product:
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MON 89034 x MIR162 x MON 95275
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x MON 88017 Seed Blend
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Name and Address of Registrant (include ZIP Code):
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Bayer CropScience LLC
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700 Chesterfield Parkway West
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Chesterfield, MO 63017
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Note: Changes in labeling differing in substance from those accepted in connection with this registration must be submitted to and ac cepted by the
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Biopesticides and Pollution Prevention Division prior to use of the label in commerce. In any correspondence regarding this product, always refer to the
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above EPA Registration Number.
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On the basis of information furnished by the registrant, the above named pesticide is hereby registered
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under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA or the Act).
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Registration is in no way to be construed as an endorsement or recommendation of this product by the
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U.S. Environmental Protection Agency (EPA). In order to protect health and the environment, the
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Administrator, on his or her motion, may at any time suspend or cancel the registration of a pesticide in
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accordance with the Act. The acceptance of any name in connection with the registration of a product
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under the Act is not to be construed as giving the registrant a right to exclusive use of the name or to its
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use if it has been covered by others.
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This product is unconditionally registered in accordance with FIFRA section 3(c)(5) provided that you:
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1. Submit/cite all data required for registration of your product under FIFRA section 3(c)(5) when
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the Environmental Protection Agency (EPA) requires registrants of similar products to submit
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such data.
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Signature of Approving Official:
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Alan Reynolds, Product Manager 94
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Emerging Technologies Branch
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Biopesticides and Pollution Prevention Division (7511M)
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Office of Pesticide Programs
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Date:
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3/9/2026
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EPA Form 8570-6
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Digitally signed by
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ALAN REYNOLDS
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Date: 2026.03.09
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14:58:29 -04'00'
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Page 2 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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2. The subject registration is limited to Bacillus thuringiensis Cry1A.105 and Cry2Ab2 proteins, Bacillus
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thuringiensis Vip3Aa20 protein, Brevibacillus laterosporus Mpp75Aa1.1 protein, Bacillus thuringiensis
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Vpb4Da2 protein, DvSnf7.1 dsRNA [double-stranded RNA transcript comprising a DvSnf7 inverted
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repeat sequence derived western corn rootworm (Diabrotica virgifera virgifera)], Bacillus
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thuringiensis Cry3Bb1 protein, and the genetic material necessary for their production (vectors PV-
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ZMIR39 pNOV1300, PV-ZMIR525664, and PV-ZMIR39) in MON 89034 × MIR162 × MON 95275 × MON
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88017 (OECD Unique Identifier: MON-89Ø34-3 × SYN-IR162-4 × MON-95275-7 × MON 88Ø17-3) for
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use in field corn, and 5% non-Bt seed that when planted creates an interspersed refuge within the
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field.
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3. The subject registration may be combined through conventional breeding with other registered
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plant-incorporated protectants that are similarly approved for use in combination, through
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conventional breeding, with other registered plant-incorporated protectants to produce inbred corn
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lines and hybrid corn varieties with combined pesticidal traits.
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4. Bayer CropScience LLC (Bayer) must develop and submit a resistance monitoring plan for
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Mpp75Aa1.1 and Vpb4Da2. This plan must include a resistance detection assay that meets EPA's
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criteria (see Section 5)(e)(b) below) and baseline susceptibility data. This plan must be submitted
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within six (6) months of registration.
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5. Bayer must commit to do the following Insect Resistance Management (IRM) Program, consisting of
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the following elements:
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x Requirements for Bayer to implement an IPM-based stewardship program designed to reduce
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selection pressure for corn rootworm (CRW) resistance.
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x Requirements relating to a refuge assurance program for ensuring the correct refuge blend
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percentage.
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x Requirements relating to creation of a lepidopteran refuge (consisting of corn that does not
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contain any Bt trait for lepidopteran control) in cotton growing regions in conjunction with the
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planting of MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend.
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x Requirements for Bayer to prepare and require MON 89034 × MIR162 × MON 95275 × MON
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88017 Seed Blend users to sign grower agreements that impose binding contractual obligations
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on growers to comply with the refuge requirements.
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x Requirements for Bayer to develop, implement, and report to EPA on programs to educate
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growers about IRM.
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x Requirements for Bayer to develop, implement, and report to EPA on programs to evaluate and
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promote growers’ compliance with IRM requirements.
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x Requirements for Bayer to develop, implement, and report to EPA on monitoring programs to
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evaluate whether there are statistically significant and biologically relevant changes in
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Page 3 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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susceptibility to the Cry1A.105, Cry2Ab2, and Vip3Aa20 proteins in the target insects.
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x Requirements for Bayer to develop, and if triggered, to implement a remedial action plan that
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would contain measures Bayer would take in the event that any field-relevant insect resistance
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to Cry1A.105, Cry2Ab2, and Vip3Aa20 was detected, as well as to report on activity under the
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plan to EPA.
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x Requirements for Bayer to investigate reports of unexpected CRW damage to MON 89034 ×
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MIR162 × MON 95275 × MON 88017 Seed Blend from growers (“performance inquiries”) and
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sample CRW to determine if the insects are resistant to Cry3Bb1, Mpp75Aa1.1/Vpb4Da2, and/or
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DvSnf7.1.
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x Requirements for Bayer to recommend CRW management options to growers in response to
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cases of unexpected CRW damage to MON 89034 × MIR162 × MON 95275 × MON 88017 Seed
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Blend.
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x Requirements regarding mitigation and notification actions that Bayer would take in the event
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that CRW resistance was detected.
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x Requirements for Bayer to make available to the Agency upon request records of the number of
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units of MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend sold or shipped and not
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returned, and the number of such units that were sold to persons who have signed grower
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agreements for the previous growing season, within three months of the request.
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x Requirements for Bayer to submit reports on resistance monitoring within the time frames
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specified in this registration notice.
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x Bag Tag Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend: Seed
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bags and/or bag tags for corn hybrids that contain plant-incorporated protectants produced in
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MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend must display the registration
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number and active ingredients, and stipulate that growers read the Bayer Stewardship Guide (or
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equivalent guidance) prior to planting these hybrids. The refuge size requirement must be
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displayed on the bag or bag tag in both text and graphic format.
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x Requirements for Bayer to submit reports on CRW IPM stewardship and resistance monitoring
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within the time frames specified in this registration notice.
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a. Integrated Pest Management Stewardship Program (IPM)
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1) Bayer must implement an IPM-based stewardship program for MON 89034 × MIR162 × MON 95275
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× MON 88017 Seed Blend. This program must be designed to reduce selection pressure for corn
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rootworm (CRW) resistance by encouraging growers to engage in a multi-year crop rotation strategy
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involving the use of one or more of the following: a non-CRW host crop (e.g., soybean), pyramided Bt
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corn Plant Incorporated Protectants (PIPs), other PIP corn products with different modes of action,
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and/or non-Bt or non-CRW protected Bt corn. As part of the stewardship program, Bayer must
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Page 4 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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update the technology use guide/grower guide and other grower educational materials to indicate
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that application of an insecticide to the soil surface, in furrows, and/or incorporated into the soil
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(referred to as “soil applied insecticide”, “soil insecticide” or “SAI”) with MON 89034 × MIR162 ×
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MON 95275 × MON 88017 Seed Blend is not recommended for control of CRW except under limited
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circumstances and in consultation with extension, crop consultants or other local experts. Grower
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education materials should also state that SAIs should not be necessary for CRW control with
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pyramided CRW trait Bt corn product(s). As part of the stewardship program, Bayer must promote
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the ABSTC/NCGA Best Management Practices (BMPs) for CRW control. Implementation of the IPM
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strategy can include:
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x Grower education initiatives or incentives;
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x Outreach to extension and consultant groups.
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b. Refuge requirements for Bt11 × MIR162 × MZIR098 × DP4114 Refuge Seed Blend Corn:
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The following information must be included on the product bag or bag-tag as sold per respective region and
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in the Grower Guide:
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Corn-Belt/Non-Cotton Growing Areas
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MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend contains a Lepidopteran and corn
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rootworm refuge that is “in the bag” and is automatically implemented when the grower plants the
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product. No additional refuge is required when planting this product.
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Foliar insecticide treatments for control of European corn borer, corn earworm, southwestern corn
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borer, fall armyworm, black cutworm, western bean cutworm, lesser corn stalk borer, southern corn
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stalk borer, common stalk borer and sugarcane borer may be applied only if economic thresholds are
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reached for one or more of these target pests. Foliar insecticide treatments are also permitted for
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control of corn rootworm adults if economic thresholds are reached. Economic thresholds will be
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determined using methods recommended by local or regional professionals (e.g., Extension Service
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agents, crop consultants).
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Cotton-Growing Region Refuge Requirements
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These refuge requirements do not apply to seed increase/propagation of inbred and hybrid seed corn up
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to a total of 20,000 acres per county and up to a combined United States (U.S.) total of 250,000 acres per
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plant incorporated protectant (PIP) active ingredient per registrant per year. Grower agreements (also
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known as stewardship agreements) will specify that growers must adhere to the refuge requirements as
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described in the grower guide/product use guide and/or in supplements to the grower guide/product use
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guide.
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In cotton-growing regions where corn earworm is a significant pest:
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x A 20% refuge must be planted with corn hybrids that do not contain PIP technologies for the
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Page 5 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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control of corn rootworms or corn borers.
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x MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend and the 20% non-Bt refuge
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should be sown on the same day, or with the shortest window possible between planting dates.
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x External refuges may be planted as an in-field or adjacent (e.g., across the road) refuge or as a
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separate block within 1/2 mile of the MON 89034 × MIR162 × MON 95275 × MON 88017 Seed
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Blend field.
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x In field refuge options include: blocks, perimeter strips (i.e., along the edges or headlands), or in-
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field strips.
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x When planting the refuge in strips across the field, refuges must be at least four (4) rows wide.
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x Insecticide treatments for control of European corn borer, corn earworm, southwestern corn
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borer, fall armyworm, black cutworm, western bean cutworm, lesser corn stalk borer, southern
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corn stalk borer, stalk borer and sugarcane borer may be applied only if economic thresholds are
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reached for one or more of these target pests. Economic thresholds will be determined using
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methods recommended by local or regional professionals (e.g., Extension Service agents, crop
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consultants). Microbial Bt insecticides must not be applied to non-Bt corn refuge plants.
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x Cotton-growing areas include the following states: Alabama, Arkansas, Georgia, Florida, Louisiana,
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North Carolina, Mississippi, South Carolina, Oklahoma (only the counties of Beckham, Caddo,
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Comanche, Custer, Greer, Harmon, Jackson, Kay, Kiowa, Tillman, and Washita), Tennessee (only
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the counties of Carroll, Chester, Crockett, Dyer, Fayette, Franklin, Gibson, Hardeman, Hardin,
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Haywood, Lake, Lauderdale, Lincoln, Madison, Obion, Rutherford, Shelby, and Tipton), Texas
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(except the counties of Carson, Dallam, Hansford, Hartley, Hutchinson, Lipscomb, Moore,
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Ochiltree, Roberts, and Sherman), Virginia (only the counties of Dinwiddie, Franklin City,
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Greensville, Isle of Wight, Northampton, Southampton, Suffolk City, Surrey, and Sussex) and
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Missouri (only the counties of Dunklin, New Madrid, Pemiscot, Scott, and Stoddard).
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c. Grower Agreements for MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
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1) Persons purchasing MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend must sign a
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grower agreement. The term grower agreement refers to any grower purchase contract, license
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agreement, or similar legal document.
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2) The grower agreement and/or specific stewardship documents referenced in the grower agreement
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must clearly set forth the terms of the current IRM program. By signing the grower agreement, a
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grower must be contractually bound to comply with the requirements of the IRM program.
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3) Bayer must continue to integrate this registration into the current system used for its other Bt corn
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plant-incorporated protectants, which is reasonably likely to assure that persons purchasing MON
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Page 6 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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89034 × MIR162 × MON 95275 × MON 88017 Seed Blend will affirm annually that they are
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contractually bound to comply with the requirements of the IRM program.
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4) If Bayer wishes to change any part of the grower agreement or any specific stewardship documents
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referenced in the grower agreement that would affect either the content of the IRM program or the
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legal enforceability of the provisions of the agreement relating to the IRM program, thirty (30) days
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prior to implementing a proposed change, Bayer must submit to EPA the text of such changes to
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ensure it is consistent with the terms and conditions of this registration.
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5) Bayer shall maintain records of all MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
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grower agreements for a period of three (3) years from December 31st of the year in which the
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agreement was signed.
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6) Bayer shall make available to the Agency upon request records of the number of units of MON 89034
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× MIR162 × MON 95275 × MON 88017 Seed Blend seed sold or shipped and not returned, and the
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number of such units that were sold to persons who have signed grower agreements for the
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previous growing season, within three (3) months of the Agency’s request.
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7) Bayer must allow a review of the grower agreements and grower agreement records by EPA or by a
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State pesticide regulatory agency if the State agency can demonstrate that confidential business
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information, including names, personal information, and grower license numbers of the growers, will
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be protected.
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d. IRM Education and Compliance Monitoring Programs for MON 89034 × MIR162 × MON 95275 ×
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MON 88017 Seed Blend
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1) Bayer must implement and enhance (as set forth in paragraph 17 of this section) a comprehensive,
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ongoing IRM education program designed to convey to MON 89034 × MIR162 × MON 95275 × MON
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88017 Seed Blend users the importance of complying with the IRM program, as well as seed blend
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product performance expectations and guidance to growers on actions to take when unexpected
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damage occurs. The program shall include information encouraging MON 89034 × MIR162 × MON
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95275 × MON 88017 Seed Blend users to pursue optional elements of the IRM program relating to
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refuge configuration and proximity to MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
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fields. The education program shall involve the use of multiple media (e.g., face-to-face meetings,
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mailing written materials, EPA-reviewed language on IRM requirements on the bag or bag tag, and
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electronic communications such as by Internet, radio, or television commercials). The program shall
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involve at least one (1) written communication annually to each MON 89034 × MIR162 × MON 95275
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× MON 88017 Seed Blend user separate from the grower technical guide. The communication shall
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inform the user of the current IRM requirements and specifically the need to plant a lepidopteran
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refuge in cotton growing regions. Bayer shall coordinate its education programs with educational
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efforts of other registrants and organizations, such as the National Corn Growers Association and
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state extension programs.
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Page 7 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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2) Bayer shall revise, and expand as necessary, its education program to take into account the
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information collected through the compliance survey, required under paragraphs 6–9 of this
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section, and from other sources. The changes shall address aspects of grower compliance that are
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not sufficiently high.
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3) Upon EPA request, Bayer shall provide copies of grower education materials and information on
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grower education activities including any substantive changes to these materials and activities
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conducted either individually or as part of a report from the industry working group, Agricultural
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Biotechnology Stewardship Technical Committee (ABSTC). Bayer is required to submit reports within
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three (3) months of the Agency’s request. The required features of the compliance assurance
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program are described in paragraphs 4–22 of this section.
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4) Bayer must implement and improve an ongoing IRM compliance assurance program designed to
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evaluate the extent to which growers purchasing MON 89034 × MIR162 × MON 95275 × MON 88017
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Seed Blend are compliant with the requirement of a 20% refuge for lepidopteran pests in cotton
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growing areas, and that takes such actions as are reasonably needed to assure that growers who have
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not complied with the program either do so in the future or lose their access to Bayer’s Bt corn
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products. Bayer shall coordinate with other Bt corn registrants in improving its compliance assurance
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program and integrate this registration into the current compliance assurance program used for its
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other Bt corn plant-incorporated protectants. Other required features of the program are described
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in paragraphs 5–22 of this section.
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5) Bayer must maintain and publicize a phased compliance approach (i.e., a guidance document that
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indicates how it will address instances of non-compliance with the terms of the IRM program and
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general criteria for choosing among options for responding to any non-compliant growers after the
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first year of non- compliance). While recognizing that for reasons of difference in business practices
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there are needs for flexibility between different companies, Bayer must use a consistent set of
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standards for responding to non-compliance. An individual grower found to be significantly out of
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compliance two (2) years in a row would be denied access to Bayer’s Bt corn products the next year.
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Similarly, seed dealers who are not fulfilling their obligations to inform/educate growers of their IRM
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obligations will lose their opportunity to sell Bt corn.
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6) The IRM compliance assurance program shall include an annual survey, conducted by an
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independent third party, of a statistically representative sample of growers of MON 89034 × MIR162
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× MON 95275 × MON 88017 Seed Blend. The survey shall be conducted in odd-numbered years
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beginning in 2027 and shall include growers who plant 100 or more acres of corn in the Southern
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U.S. corn-cotton areas. Bayer may collaborate with other registrants of Bt corn [for example, through
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the industry working group the Agricultural Biotechnology Stewardship Technical Committee
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(ABSTC)] to conduct the survey.
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In the U.S. Corn Belt, no anonymous grower survey is required for MON 89034 × MIR162 × MON
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95275 × MON 88017 Seed Blend if Bayer can demonstrate that the industry-wide adoption of
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integrated refuge products (i.e., refuge seed blends) is equal to or greater than 70% of Bt corn acres
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Page 8 of 25
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EPA Reg. No. 524-670
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OPP Action Case No. 00659693
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in the Corn Belt. If industrywide adoption of integrated refuge products (i.e., refuge seed blends)
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falls below 70% of Bt corn acres in the Corn Belt, an anonymous grower survey shall also be
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conducted in this region during the next growing season using a statistically representative sample
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of growers who plant 200 or more acres of corn, and grower surveys shall be continued every odd-
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numbered year until the industry-wide adoption of integrated refuge products (i.e., refuge seed
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blends) is again equal to or greater than 70% of Bt corn acres in this region. Bayer may collaborate
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with other registrants of Bt corn (for example, through the industry working group the ABSTC) to
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compile the integrated refuge adoption data and to conduct the surveys.
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Alternatively, if Bayer is not a participant of an industry working group (e.g., the ABSTC) and Bayer’s
|
||
sales of integrated refuge products are equal to or greater than 70% of the Bayer’s total Bt corn sales
|
||
in the prior year, then no anonymous grower survey is required in the U.S. Corn Belt. If the Bayer’s
|
||
sales of integrated refuge products fall below 70% of the Bayer’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 Bayer’s total Bt corn sales in this region.
|
||
|
||
x A third party is classified as a party other than Bayer, 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, Bayer shall provide a final written summary of the results
|
||
of the prior year’s survey (together with a description of the regions, the methodology used, and the
|
||
supporting data) to EPA on or before January 31st of each year. Bayer shall confer with other
|
||
registrants and EPA on the design and content of the survey prior to its implementation.
|
||
|
||
10) Bayer 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. Bayer must confer with EPA prior to adopting any changes.
|
||
|
||
11) Bayer shall conduct an annual on-farm assessment program. Bayer shall train its representatives who
|
||
make on-farm visits with MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend 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
|
||
|
||
Page 9 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
with the IRM program, Bayer shall take appropriate action, consistent with its phased compliance
|
||
approach, to promote compliance.
|
||
|
||
12) Bayer shall carry out a program for investigating legitimate tips and complaints that MON 89034 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend 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, Bayer shall take appropriate action, consistent with its phased
|
||
compliance approach.
|
||
|
||
13) If a grower, who purchases MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend for
|
||
planting, was specifically identified as not being in compliance during the previous year, Bayer 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, Bayer must provide a report to EPA summarizing the MON
|
||
89034 × MIR162 × MON 95275 × MON 88017 Seed Blend compliance assurance program activities
|
||
and results for the prior year and plans for the MON 89034 × MIR162 × MON 95275 × MON 88017
|
||
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 seed on the basis of continued
|
||
non-compliance with the insect resistance management refuge requirements. Bayer may elect to
|
||
coordinate information with other registrants and report collectively the results of compliance
|
||
assurance programs.
|
||
|
||
15) Bayer and the seed corn dealers for Bayer 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) Bayer shall revise and expand its existing compliance assurance program to include the following
|
||
elements. Bayer must prepare and submit a written description of its revised compliance assurance
|
||
program. Bayer may coordinate with other registrants in designing and implementing its compliance
|
||
assurance program.
|
||
|
||
17) Bayer will enhance the refuge education program throughout the seed delivery channel to:
|
||
|
||
x 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.
|
||
|
||
x Implement a “bag tag” that will be attached to all bags of MON 89034 × MIR162 × MON 95275 ×
|
||
MON 88017 Seed Blend seed sold and delivered. The purpose of this bag tag is to remind
|
||
growers that MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend products require a
|
||
|
||
Page 10 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
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) Bayer will focus the majority of on-farm assessments on regions with the greatest risk for resistance:
|
||
|
||
x Use Bt corn adoption, pest pressure information, and other available information to identify
|
||
regions where the risk of resistance is greatest.
|
||
|
||
x Focus approximately two-thirds of on-farm assessments on these regions, with the remaining
|
||
assessments conducted across other regions where MON 89034 × MIR162 × MON 95275 × MON
|
||
88017 Seed Blend is used.
|
||
|
||
19) Bayer will use its available MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend sales
|
||
records and other information to refine grower lists for on-farm assessments of their compliance
|
||
with refuge requirements to:
|
||
|
||
x Identify for potential on-farm assessment growers whose sales information indicates they have
|
||
purchased MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend product but may have
|
||
purchased little or no refuge seed from Bayer, licensees, or affiliated companies.
|
||
|
||
20) Bayer will contract with third parties to perform on-farm assessments of compliance with refuge
|
||
requirements:
|
||
|
||
x 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) Annually, Bayer will refine the on-farm assessment program for MON 89034 × MIR162 × MON
|
||
95275 × MON 88017 Seed Blend product to reflect the adoption rate and level of refuge compliance
|
||
for the product.
|
||
|
||
22) Bayer 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:
|
||
|
||
x 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 (2) years by Bayer, a seed
|
||
supplier, or a third-party assessor, after completing the assessment process.
|
||
|
||
|
||
x Bayer will conduct follow-up checks on growers found to be significantly out of compliance
|
||
within three (3) years after they are found to be back in compliance.
|
||
|
||
x 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 Bayer’s Bt corn
|
||
products the next year. Similarly, seed dealers who are not fulfilling their obligations to
|
||
|
||
Page 11 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
inform/educate growers of their IRM obligations will lose their opportunity to sell Bt corn.
|
||
|
||
e. Insect Resistance Monitoring and Remedial Action Plans for MON 89034 × MIR162 × MON 95275 ×
|
||
MON 88017 Seed Blend
|
||
|
||
1) EPA is imposing the following conditions for the Cry1A.105, Cry2Ab2, and Vip3Aa20 toxins expressed
|
||
in MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend:
|
||
|
||
Bayer will monitor for resistance to Cry1A.105, Cry2Ab2, and Vip3Aa20 expressed in MON 89034 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend. The monitoring program European corn borer (Ostrinia
|
||
nubilalis; ECB) and southwestern corn borer (Diatraea grandiosella; SWCB) 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. Corn earworm (Helicoverpa zea;
|
||
CEW) will be monitored using sentinel plots and reports of unexpected injury to MON 89034 × MIR162 ×
|
||
MON 95275 × MON 88017 corn.
|
||
|
||
Focused Population Sampling
|
||
|
||
Bayer shall annually sample and bioassay populations of the key target pests: Ostrinia nubilalis
|
||
(European corn borer; ECB and Diatraea grandiosella (southwestern corn borer; SWCB). 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 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend and/or changes in resistance allele frequency in
|
||
response to the use MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend 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. 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 × MIR162 × MON 95275 × MON
|
||
88017 Seed Blend. EPA shall be consulted prior to the implementation of such modifications.
|
||
|
||
Page 12 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
|
||
Bayer 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, Cry2Ab2, and Vip3Aa20 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:
|
||
|
||
1. 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.
|
||
|
||
2. 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 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend under field conditions. If progeny do not survive
|
||
to adulthood, any suspected resistance is not field relevant and no further action is required.
|
||
|
||
3. 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:
|
||
|
||
x Determining the nature of the resistance (i.e., recessive or dominant, and the level of functional
|
||
dominance);
|
||
|
||
x Estimating the resistance allele frequency in the original population;
|
||
|
||
x 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;
|
||
|
||
x 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,
|
||
Bayer will consult with EPA to develop and implement a case-specific remedial action plan.
|
||
|
||
Investigation of Reports of Unexpected Levels of Damage by the Target Pests (ECB and SWCB)
|
||
|
||
Bayer will follow up on grower, extension specialist, or consultant reports of unexpected levels of
|
||
damage by the lepidopteran pests listed on the pesticide label. Bayer will instruct its customers to
|
||
contact them if such incidents occur and provide guidance to growers on seed blend product
|
||
performance expectations and actions to take when unexpected damage occurs. Bayer will investigate
|
||
|
||
Page 13 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
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 and SWCB), Bayer will implement the actions described below, based on the following
|
||
definitions of suspected resistance and confirmed resistance.
|
||
|
||
Suspected Resistance (ECB and SWCB)
|
||
|
||
EPA defines suspected resistance to mean field reports of unexpected levels of insect-feeding
|
||
damage for which:
|
||
|
||
x The corn in question has been confirmed to be lepidopteran-active Bt corn;
|
||
|
||
x The relevant plant tissues are expressing the expected level of Bt protein;
|
||
|
||
x 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
|
||
|
||
x That 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 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend in commercial production fields before responsive
|
||
measures are undertaken.
|
||
|
||
If resistance is suspected, Bayer will instruct growers to do the following:
|
||
|
||
x Use alternative control measures in MON 89034 × MIR162 × MON 95275 × MON 88017 Seed
|
||
Blend fields in the affected region to control the target pest during the immediate growing
|
||
season.
|
||
|
||
x Destroy MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend 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, Bayer 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 (ECB and SWCB)
|
||
|
||
Page 14 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
EPA defines confirmed resistance to mean, in the case of field reports of unexpected levels of damage
|
||
from the key target pests, that all of the following criteria are met:
|
||
|
||
x 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.
|
||
|
||
x 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 ш 0.1 in the sampled
|
||
population.
|
||
|
||
x In standardized laboratory bioassays, the LC
|
||
50 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 for ECB or SWCB (as defined above), the following steps will be taken
|
||
by Bayer:
|
||
|
||
x EPA will receive notification within 30 days of resistance confirmation;
|
||
|
||
x Affected customers and extension agents will be notified about confirmed resistance within 30
|
||
days;
|
||
|
||
x 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;
|
||
|
||
x 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), alternate 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;
|
||
|
||
x 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;
|
||
|
||
x Bayer will develop a case-specific remedial action plan within 90 days according to the
|
||
|
||
Page 15 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
characteristics of the resistance event and local agronomic needs. Bayer 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;
|
||
|
||
x Bayer 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
|
||
|
||
x 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.
|
||
|
||
Corn Earworm (CEW) Resistance Monitoring
|
||
|
||
x No annual CEW insect collections and subsequent bioassays are required for the Cry1A.105,
|
||
Cry2Ab2, and/or Vip3Aa20 proteins;
|
||
|
||
x A network of sentinel plots must be established in cotton growing states to monitor CEW
|
||
resistance in PIP corn products containing the Vip3Aa20 protein, including MON 89034 × MIR162
|
||
× MON 95275 × MON 88017 Seed Blend, that follows EPA approved methods defined in the
|
||
protocol for the establishment of sentinel plots, evaluation of CEW against the Vip3Aa20 protein
|
||
only, and calculation of a phenotypic a resistance ratio (MRID 52144201);
|
||
|
||
x Bayer must follow up on grower, extension specialist, or consultant reports of unexpected injury
|
||
(UXI) by CEW to MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend that meet the
|
||
criteria below. Bayer will instruct its customers to contact them if such incidents occur. Bayer
|
||
will investigate all legitimate reports submitted to the company or the company's
|
||
representatives.
|
||
|
||
o To investigate potential UXI to products containing Vip3Aa20, a minimum of a 100-ear sample
|
||
collected from the affected area of the field will be taken. UXI is confirmed if at least 10% of
|
||
individual ears sampled meet both of the following criteria: (1) one or more CEW larvae (ш 3rd
|
||
instar) or exit holes are present; and (2) there is at least 2 cm
|
||
2 of CEW feeding injury.
|
||
|
||
x If UXI triggers for CEW above are exceeded, Bayer must implement the mitigation actions below:
|
||
|
||
o Report the results of any investigations confirming the UXI and the affected county where
|
||
the report occurred in an annual resistance monitoring report to EPA;
|
||
|
||
o Inform affected customer(s) and state extension agents of the UXI within 30 days within 30
|
||
days of the UXI confirmation; and
|
||
|
||
Page 16 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
o Where in-season management tactics are possible, the recommended management options
|
||
include, but are not limited to the following:
|
||
|
||
Apply an appropriate foliar chemical insecticide (only if economically viable in corn);
|
||
If additional pest management is needed, additional control tactics as appropriate (e.g.,
|
||
additional foliar insecticide applications, tillage practices).
|
||
If in-season management tactics are not possible, the recommended management
|
||
options for the next growing seasons include, but are not limited to the following:
|
||
|
||
x Switching to a different Bt mode of action or planting non-Bt corn;
|
||
x Encourage timely planting to avoid primary risk window for primary pests;
|
||
x Encourage growers to monitor for adults and intensify field scouting for
|
||
injury in corn fields;
|
||
x Use appropriately timed foliar insecticide application based on field scouting
|
||
for insect injury;
|
||
x If additional pest management is needed, additional control tactics as
|
||
appropriate (e.g., additional foliar insecticide applications, tillage practices).
|
||
|
||
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
|
||
Cry3Bb1, Mpp75Aa1.1/Vpb4Da2, and DvSnf7.1 toxins
|
||
expressed in MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend:
|
||
|
||
a) Investigation of Reports of Unexpected Levels of Damage (UXD) by Corn Rootworm (CRW):
|
||
Performance Inquiries
|
||
|
||
1. Bayer is required to investigate "performance inquiries" (i.e., reports of unexpected CRW
|
||
damage to MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend) from growers.
|
||
Fields (defined as a tract separated by permanent boundaries such as fences, permanent
|
||
waterways, woodlands, crop lines 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 × MIR162 × MON 95275 × MON
|
||
88017 Seed Blend 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 × MIR162 × MON 95275 × MON
|
||
88017 Seed Blend fields meeting the criteria in part 1) above, Bayer must take the following
|
||
|
||
Page 17 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
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
|
||
(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 × MIR162 × MON
|
||
95275 × MON 88017 Seed Blend 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 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 Bayer 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.
|
||
|
||
Page 18 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
|
||
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 Bayer for the UXD case.
|
||
|
||
3. Bayer 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:
|
||
|
||
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 Populations of Concern
|
||
|
||
1. Bayer must conduct investigations of all CRW populations collected as part of the
|
||
performance 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 × MIR162 × MON 95275 × MON 88017 Seed Blend.
|
||
Acceptable assays must be able to function as diagnostic tools capable of distinguishing
|
||
resistant populations from susceptible ones. Unless previously approved, Bayer 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):
|
||
|
||
Page 19 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
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 population
|
||
1; and
|
||
|
||
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
|
||
|
||
1 If a resistant positive control population is not available or accessible, Bayer must consult with EPA prior to initiating bioassays
|
||
and work to develop an appropriate resistant positive control population.
|
||
|
||
Page 20 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
resistant positive control population;1 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
|
||
population.1
|
||
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 × MIR162 ×
|
||
MON 95275 × MON 88017 Seed Blend, 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).
|
||
|
||
b. In these cases, Bayer 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 Bayer 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 more of the CRW traits in MON 89034 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend under EPA’s criteria described in section e(2)(b)
|
||
above, Bayer must take the following steps:
|
||
|
||
a. Bayer must inform EPA of the results of the bioassays as soon as possible, but at least within
|
||
|
||
Page 21 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
thirty (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 thirty (30) days of informing EPA of the results of the bioassays, Bayer must notify
|
||
state extension agents and crop consultants who operate within the county resistance was
|
||
identified. Information shared must include identification of the county in which resistance
|
||
was detected and trait(s) affected.
|
||
|
||
d. Within the MAA, Bayer 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).
|
||
Bayer must also inform neighboring growers if those growers are customers of Bayer.
|
||
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. Bayer 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 Bayer 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;
|
||
|
||
v. For Bayer’s affected customer’s field(s), the mitigation goal is to control the resistant
|
||
CRW population. Within the MAA Bayer 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
|
||
|
||
Page 22 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
89034 × MIR162 × MON 95275 × MON 88017 Seed Blend is not met, continued use
|
||
of the product with a 20% refuge;
|
||
|
||
c. Use of different 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 are 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 MON
|
||
89034 × MIR162 × MON 95275 × MON 88017 Seed Blend as a primary tool for CRW
|
||
management in the MAA, only when Bayer demonstrates that successful mitigation as
|
||
described in part e above has been achieved.
|
||
|
||
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),
|
||
|
||
Page 23 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
and other control tactics.
|
||
|
||
f. Refuge Assurance Program for MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
|
||
|
||
Bayer must implement a Blended Seed Refuge Assurance Program designed to ensure MON 89034 ×
|
||
MIR162 × MON 95275 × MON 88017 Seed Blend 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.
|
||
|
||
x Calibration records - Bayer will retain documentation for a specified period of time on the
|
||
equipment calibration including the procedure, when it was conducted and the results.
|
||
|
||
x Blend proportion records (weight and kernel based) – Bayer 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 × MIR162 × MON 95275 × MON 88017 Seed Blend product by seed lot.
|
||
|
||
All records must be maintained by the Bayer blending facility, third party contractors, and Bayer
|
||
licensees and must be available for the EPA review upon request.
|
||
|
||
Should Bayer or Bayer's Licensees be notified by the USDA/AMS or State Seed Control Officials that
|
||
your seed blend products have been found to have a lower percentage of the refuge component
|
||
than is represented on the label, they must notify EPA within thirty (30) days. This would constitute
|
||
information reportable under FIFRA section 6(a)(2).
|
||
|
||
g. Annual Reporting Requirements for MON 89034 × MIR162 × MON 95275 × MON 88017 Seed
|
||
Blend
|
||
|
||
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 of each year.
|
||
|
||
2) Insect Resistance Monitoring Results (Cry1A.105, Cry2Ab2, and Vip3Aa20 only): Results of
|
||
|
||
Page 24 of 25
|
||
EPA Reg. No. 524-670
|
||
OPP Action Case No. 00659693
|
||
|
||
|
||
|
||
monitoring and investigations of damage reports, on or before August 31st of each year.
|
||
|
||
3) Unexpected Damage Investigations (Cry3Bb1, Mpp75Aa1.1/Vpb4Da2, and DvSnf7.1 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 terms. If these terms are not
|
||
complied with, this registration will be subject to cancellation in accordance with FIFRA section 6.
|
||
A stamped copy of the labeling is enclosed for your records. Please also note that the record for this
|
||
product currently contains the following acceptable Confidential Statement of Formula (CSF):
|
||
|
||
x Basic CSF dated May 15, 2025
|
||
|
||
If you have any questions, please contact Stephanie Kelly of my team by phone at (202) 566-0890 or via
|
||
email at kelly.stephanie@epa.gov.
|
||
|
||
Sincerely,
|
||
|
||
|
||
|
||
|
||
Alan Reynolds, Product Manager 94
|
||
Emerging Technologies Branch
|
||
Biopesticides and Pollution
|
||
Prevention Division
|
||
Office of Pesticide Programs
|
||
|
||
|
||
Enclosure: MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend Stamped Label
|
||
Digitally signed by
|
||
ALAN REYNOLDS
|
||
Date: 2026.03.09
|
||
14:59:23 -04'00'
|
||
|
||
Plant-Incorporated Protectant Label
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 Seed Blend
|
||
(OECD Unique Identifier: MON-89Ø34-3 × SYN-IR162-4 × MON-95275-7 × MON-
|
||
88Ø17-3)
|
||
Active Ingredients:
|
||
Bacillus thuringiensis Cry1A.105 protein and the geneti c material necessary for its
|
||
production (vector PV-ZMIR245) in corn event MON 89034 (OECD Unique Identifier
|
||
021
|
||
Bacillus thuringiensis Cry2Ab2 protein and the geneti c material necessary for its
|
||
production (vector PV-ZMIR245) in corn event MON 89304 (OECD Unique Identifier
|
||
021
|
||
Bacillus thuringiensis Vip3Aa20 insecticidal protein and the genetic material necessary for
|
||
its production (via elements of vector pNOV1300) in corn event MIR162 (OECD Unique
|
||
,GHQWLILHU 6<1,5
|
||
Brevibacillus laterosporus Mpp75Aa1.1 protein and the genetic material necessary for its
|
||
production (vector PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier
|
||
021 ««««««««««««««««««««««««
|
||
Bacillus thuringiensis Vpb4Da2 protein and the geneti c material necessary for its
|
||
production (vector PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier
|
||
021 «««««««««««««««««««««««
|
||
dsRNA transcript comprising a DvSnf7.1 in verted repeat sequence derived from
|
||
Diabrotica virgifera , and the genetic material nece ssary for its production (vector
|
||
PV-ZMIR525664) in corn event MON 95275 (OECD Unique Identifier MON-95275-7)
|
||
|
||
Bacillus thuringiensis Cry3Bb1 protein and the geneti c material necessary for its
|
||
production (vector PV-ZMIR39) in corn event MON 88017 (OECD Unique Identifier
|
||
021 «««««««««««««««««««««««««
|
||
Other Ingredients:
|
||
CP4 EPSPS protein (5-enolpyruvylshikimate- 3-phosphate synthase) and the genetic
|
||
material necessary for its production (vec tor PV-ZMIR39) in corn event MON 88017
|
||
2(&' 8QLTXH ,GHQWLILHU 021 ««««««««««««««
|
||
03/09/2026
|
||
524-670
|
||
|
||
PMI protein (phosphomannose isomerase) and the genetic material necessary for its
|
||
production (via elements of vector pNOV 1300) in corn event MIR162 (OECD Unique
|
||
,GHQWLILHU6<1,5 «««««««««««««««««««««
|
||
|
||
*Percentage (wt/wt) on a dry weight ba sis for whole plant (forage) of MON 89034 ×
|
||
MIR162 × MON 95275 × MON 88017 plants.
|
||
The MON 89034 × MIR162 × MON 95275 × MON 88017 seed with this refuge
|
||
configuration contains 95% MON 89034 × MIR162 × MON 95275 × MON 88017 mixed
|
||
with 5% non-PIP corn within a single lot of seed.
|
||
KEEP OUT OF REACH OF CHILDREN
|
||
Caution
|
||
EPA Registration No. 524-ATN
|
||
EPA Establishment No. 524-MO-002
|
||
Bayer CropScience LLC
|
||
700 Chesterfield Pkwy W
|
||
Chesterfield, MO 63017
|
||
U.S.A.
|
||
NET CONTENTS__________
|
||
DIRECTIONS FOR USE
|
||
It 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.
|
||
This Plant-Incorporated Protectant (PIP ) may be combined or produced through
|
||
conventional breeding with other registered PIPs that are si milarly approved for use in
|
||
combination, through conventional breeding, with other registered PIPs.
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend protects corn crops from
|
||
leaf, stalk, and ear damage caused by lepidopter an corn pests listed on this label and root
|
||
damage caused by corn rootworm larvae listed on this label. In order to minimize the risk
|
||
of these pests developing resista nce to MON 89034 × MIR162 × MON 95275 ×
|
||
|
||
MON 88017 seed blend, an insect resistanc e management (IRM) plan must be
|
||
implemented as defined in the registration terms and conditions.
|
||
INSECT RESISTANCE MANAGEMENT
|
||
Grower agreements will specify that growers mu st adhere to the refuge requirements that
|
||
will be described on the bag or ba g/tag for MON 89034 × MIR162 × MON 95275 ×
|
||
MON 88017 seed blend or other applicable product use documents.
|
||
Maize seed bags or bag tags for products containing MON 89034 × MIR162 × MON 95275
|
||
× MON 88017 seed blend must include the refuge size requirement in text and graphical
|
||
format.
|
||
These refuge requirements do not apply to planting of inbred/hybrid corn seed productions,
|
||
breeding, and small-scale research trials on 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 PIP active ingredient per
|
||
registrant per year.
|
||
Growers are instructed to read information on IRM on the bag and/or bag-tag.
|
||
The seed producer must ensure a minimum of 5% non-PIP refuge seed is included with
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 in each lot of seed corn. The refuge
|
||
seed in the seed mixture may not be treate d with seed-applied insecticides for corn
|
||
rootworm (CRW) control unless the MON 89034 × MIR162 × MON 95275 × MON 88017
|
||
seed in the seed mixture receives the same treatment.
|
||
The IRM/Grower Guide for MON 89034 × MIR162 × MON 95275 × MON 88017 seed
|
||
blend or comparable information presented on the product bag or bag-tag, must contain the
|
||
following information:
|
||
This product is a seed mixture c ontaining MON 89034 × MIR162 × MON 95275 ×
|
||
MON 88017 and a minimum of 5% non-PIP seed that when planted creates an interspersed
|
||
refuge within the field. There are no require ments for a separate structured refuge for
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend when planted in the U.S.
|
||
corn-growing region, including Alaska and Hawa ii, because the refuge seed is contained
|
||
within the bag/container.
|
||
The interspersed refuge can only be used by pl anting seed corn specifically generated by
|
||
qualified seed producers/conditione rs licensed by the registrant. Insecticidal treatments
|
||
labeled for adult CRW control are discouraged during the time of adult CRW emergence.
|
||
The seed mix refuge option for MON 89034 × MIR162 × MON 95275 × MON 88017
|
||
seed blend satisfies th e refuge requirements in all re gions other than in the cotton-
|
||
growing region where corn earworm is a significant pest as defined below.
|
||
|
||
Additional refuge requirements in the cotton-growing region where corn earworm is
|
||
a significant pest
|
||
In the cotton-growing region where corn earwor m is a significant pest , as defined below,
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend requires the planting of
|
||
an additional 20% structured refuge (i.e. 20 acres of non-PIP corn for every 80 acres of
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend planted).
|
||
The 20% refuge must be planted with corn hybrids that do not contain PIP technologies for
|
||
the control of corn rootworms or corn bor ers. The refuge and the MON 89034 × MIR162
|
||
× MON 95275 × MON 88017 seed blend 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. The stru ctured refuge may be planted as an in-field or adjacent
|
||
(e.g., across the road) refuge or planted as a separate block that is within ½ mile of the
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend field. In-field refuge
|
||
options include blocks, perimeter strips (i.e., strips around the fi eld), 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 × MIR162 ×
|
||
MON 95275 × MON 88017 seed blend in the ref uge 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 adul t emergence. Economic thresholds will be
|
||
determined using methods recommended by local or regional professionals (e.g., Extension
|
||
Service agents, crop consultants).
|
||
The cotton-growing region requiring the additi onal 20% refuge consists 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), Tennessee (only the counties of
|
||
Carroll, Chester, Crockett, Dyer, Fayette, Franklin, Gibson, Hardeman, Hardin, Haywood,
|
||
Lake, Lauderdale, Lincoln, Madison, Ob ion, 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 (only the counties 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
|
||
Sugarcane borer (SCB) Diatraea saccharalis
|
||
Beet armyworm Spodoptera exigua
|
||
True armyworm Pseudelatia unipuncta
|
||
Black cutworm Agrotis ipsilon
|
||
Western bean cutworm (WBC) Striacosta albicosta
|
||
Lesser cornstalk borer Elasmopalpus lignosellus
|
||
Dingy Cutworm Feltia jaculifera
|
||
Western corn rootworm (WCRW) Diabrotica virgifera virgifera
|
||
Mexican corn rootworm (MCRW) Diabrotica virgifera zeae
|
||
Northern corn rootworm (NCRW) Diabrotica barberi
|
||
Sales of corn hybrids that c ontain Bayer’s PIPs must be accompanied by either a grower
|
||
guide or bag tag which includes informat ion on planting, production, and IRM and notes
|
||
that routine applications of insecticides to control these insects are usually unnecessary
|
||
when corn containing the PIPs are planted.
|
||
__________________________
|
||
MON 89034 × MIR162 × MON 95275 × MON 88017 seed blend is a product of Bayer’s research program
|
||
offering unique genetic characteristics for specific grower needs and may be protected by one or more of the
|
||
following U.S. patents that can be found at http://cs.bayerpatents.bayer.com
|