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simplicity, I have presumed the wax is not a federally listed'hazardous waste. Also for simplicity, I have presumed the wax does not exhibit either the characteristic of reactivity or corrosivity - both of which would be unlikely. That leaves the characteristics of ignitability and toxicity. Focusing on the ignitability characteristic first, it would be unlikely that the wax would be an ignitable solid. In order for the wax to be ignitable (see 40 cfr 261.21), it would have to combust as a result of friction, spontaneous chemical change, or absorption of moisture, and then burn vigorously. The burn rate test (EPA method 1030) could be used to demonstrate that the wax does not meet the second element of this characteristic and therefore, was not ignitable. Regarding the toxicity characteristic, unless contaminated with toxic chemical(s) or metal(s), it is unlikely that the wax would be toxic in and of itself. A total waste analysis (method 3050) and perhaps a TCLP (method 1311) could be performed to demonstrate that the waste did not contain toxic constituents above the regulatory thresholds and that the wax, therefore, did not exhibit the characteristic of toxicity. In California, an aquatic bioassay [22 CCR 6666261.24(a)(6)] could also help demonstarte that the wax did not exhibit the toxicity characteristc. Lastly, the notion that something is a hazardous waste simply because it contains petroleum substances is simply incorrect. As stated above, a waste is identified as a hazardous waste either because it exhibits one or more of the characteristics of a hazardous waste or because it is (or it contains) a listed hazardous waste. These criteria are very specifcally defined in regulation. I hope this helps. Charles Corcoran, Chief Waste Idenitifcation and Recycling Section Department of Toxic Substances Control (916) 327-4499