Studies carried out show that the Vip3Aa19 protein poses a negligible risk to non-target birds, wild mammals, aquatic organisms and non-target foliar and beneficial soil organisms. Concentrations of Vip3Aa19 available in cotton-based animal feed fabrics were far below the highest doses of Vip3Aa19 tested, which had no adverse effects on the species tested. The Vip3Aa19 protein is expressed at low concentrations in cotton pollen SYN-IR102-7 and the properties of cotton pollen (heavy, sticky and not carried by the wind) result in a low potential for dispersal for aquatic organisms. In tests with pollinators (bees) and beneficial omnivorous insects (ladybugs and lacewings), incorporation of pollen expressing high concentrations of Vip3Aa19 into their diets did not result in adverse effects at concentrations greater than what these organisms are exposed to from SYN-IR102 cotton. -7. Likewise, tests with earthworms did not demonstrate any adverse effects when they were exposed to the Vip3Aa19 protein in the soil at concentrations higher than those found in SYNIR102-7 cotton. Collembola did not demonstrate any adverse effects when exposed to dietary concentrations of Vip3Aa19 greater than expected from ingestion of material from SYN-IR102-7 cotton. Furthermore, testing in aquatic environments using high concentrations of Vip3Aa19, much higher than in pollen from SYN-IR102-7 cotton, did not result in an adverse effect on sensitive indicator invertebrate species. All available evidence indicates that no non-Lepidopteran species will be directly impacted by cotton plants that express the Vip3Aa19 protein.