ESA Requirements for Isocycloseram: Runoff, Drift, and Compliance Explained
Stay Updated on ESA Restrictions
Abbreviations Used in this Article
EPA — Environmental Protection Agency
ESA — Endangered Species Act
PULA — Pesticide Use Limitation Area
BLT — Bulletins Live! Two
BMP — Best Management Practice
DSD — Droplet Size Distribution
Highlights
- All applications — even outside PULAs — require a minimum of 2 runoff mitigation points.
- Inside PULAs, additional runoff points are required (4 or 6 depending on label/bulletin).
- Spray drift buffers are mandatory, with distances depending on application method.
- Drift buffers can be reduced or eliminated using mitigation practices from EPA’s Mitigation Menu.
- Some uses include pollinator timing restrictions (e.g., no use on cucurbits in bloom during peak bee activity hours).
EPA’s Insecticide Strategy
Isocycloseram is one of the first insecticides approved operating under EPA's insecticide strategy, released April 2025, and it brings a major shift in applicator responsibility: all applications — even outside a PULA — require 2 runoff mitigation points, and when operating inside a PULA, the required total may increase to 4 or even 6 points, depending on the specific bulletin limitation. In addition, spray drift buffers are mandatory, but unlike past fixed-distance buffers, these can be reduced or eliminated using approved mitigation practices from EPA's Mitigation Menu. This aligns closely with Liberty Ultra, which was the first herbicide approved under the herbicide strategy.

EPA’s ESA Findings – and Why Mitigation Must Occur
In its registration announcement, EPA noted that:
“With these mitigation measures and Bulletins with associated PULAs for seven listed species in place, EPA's final biological evaluation predicts that the use of isocycloseram will not result in a likelihood of future jeopardy for the survival of any listed species, or a likelihood of adverse modification for any designated critical habitat.”
Meaning:
- mitigation is not a suggestion,
- mitigation is not an optional best practice,
- mitigation is a condition of lawful use.
Additionally, EPA clarified that:
“EPA has initiated ESA consultation and shared its findings with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service…”
And importantly:
“…the Services are responsible for making the actual final jeopardy/adverse modification findings and have the sole authority to do so.”
So even after registration approval, ESA-driven limitations and required mitigations can still evolve.
Mandatory Runoff Mitigation
Runoff mitigation is universal to Isocycloseram-based products.
Outside a PULA:
TWO mitigation points are required for all crops listed on this label.
This applies to every every application made with Isocycloseram-based products that contain that language on the label.
These points may be earned using measures such as:
- county level runoff relief points
- grassed waterways
- soil incorporation
- cover cropping
- tailwater recovery
- drainage control
- berms and infiltration features
Note: A full list of mitigation measures can be found on the EPA Mitigation Menu
Inside a PULA:
BLT bulletins require additional runoff points:
- some bulletins require 4 total points
- some require 6 total points
Note: This is the first product that contains additional runoff/erosion mitigation in the bulletins, that are greater than on the label.
Examples of bulletin language:
“As this crop use is located within a PULA, 4 TOTAL points of runoff/erosion mitigations must be achieved…”
“As this crop use is located within a PULA, 6 TOTAL points of runoff/erosion mitigations must be achieved…”
Related: How to Determine if Runoff Mitigation Is Required
Spray Drift Restrictions
To prevent off-target drift exposure, especially into aquatic or pollinator habitat, spray drift rules include:
- sustained wind speeds between 3–15 mph
- no temperature inversions
- wind measurement at application height
- nozzle selection to ensure coarse or medium-coarse droplets
Buffer distances by application method typically include:
| Method | Buffer |
|---|---|
| Aerial | 300 ft |
| Airblast | 85 ft |
| Ground boom | 25 ft |
But critically:
Buffer distances may be reduced using mitigation practices from EPA’s Mitigation Menu.
Applicators can reduce or eliminate buffers by utilizing:
- windbreaks
- hedgerows
- coarse droplet size
- lower boom height
- targeted spraying
- reduced rate
- high humidity (>60%)
- canopy-directed spray in airblast applications
ℹ️ Note:
You may only use mitigation options to reduce or eliminate the ecological drift buffer if the label or bulletin explicitly references EPA’s Mitigation Menu. Always check the product label or BLT bulletin for language allowing the use of buffer mitigation practices. If there is no such reference, the default buffer distance applies with no reductions allowed.
BLT Lookup Requirement – Every Application
Before each use, users must:
- check BLT within the last 6 months
- confirm whether the field is inside a PULA
- review all applicable bulletins
- follow the most restrictive conditions
Failure to check is equivalent to a label violation and subsequently a violation of federal law.
Timing Restrictions for Pollinators
Some bulletin text includes:
“DO NOT use on cucurbits in bloom from two hours after sunrise until two hours before sunset.”
These time constraints prevent peak-daylight pollinator exposure — particularly for ground-nesting bees, honeybees, and native solitary pollinators.
Other restrictions apply to:
- orchard crops in bloom
- indeterminate blooming crops
- bloom-dependent hazard windows
PULA Acreage Scale

Total acres falling within designated Pesticide Use Limitation Areas (PULAs):
- Alabama — 16,654 acres
- California — 2,037,411 acres
- Illinois — 1,168,754 acres
- Indiana — 25,652 acres
- Iowa — 594,839 acres
- Maine — 1,758 acres
- Maryland — 14,299 acres
- Massachusetts — 2,656 acres
- Michigan — 24,068 acres
- Minnesota — 1,324,226 acres
- Missouri — 40,291 acres
- Ohio — 2,567 acres
- Oregon — 17,393 acres
- Virginia — 289,003 acres
- West Virginia — 360,618 acres
- Wisconsin — 2,738,495 acres
Note: These acreages represent the total area covered by PULAs in each state — not the total crop acres affected or the acres in active agricultural production.
How Acre Blitz Supports ESA Compliance
Acre Blitz enables users to:
- instantly determine PULA status
- retrieve bulletin limitations
- calculate required runoff points
- track drift buffer obligations
- document mitigation measures used
- record BLT lookup timestamps
- maintain auditable compliance logs
Our tools help ensure that the applicator has not only followed the label —
but can prove that they followed the label.
