Mail Stop 0306


April 8, 2005


Via Facsimile and U.S. Mail

Mr. Ronald H. Spair
Chief Financial Officer
Orasure Technologies, Inc.
220 East First Street
Bethlehem, PA 18015

	Re: 	Orasure Technologies, Inc.
		Form 10-K for the year ended December 31, 2004
      SEC File No. 1-16537


Dear Mr. Spair:

      We have reviewed your filings and have the following
comments.
We have limited our review to those issues we have addressed in
our
comments.  Where indicated, we think you should revise your future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.





Form 10-K for the Fiscal Year Ended December 31, 2004

Item 9A. Controls and Procedures - Page 51

1. We note your statement that the chief executive officer and
company comptroller have concluded that the company`s disclosure
controls and procedures are "effective in timely alerting them to
material information relating to the Company that is required to
be
included in its periodic filings with the Securities and Exchange
Commission." It does not appear that your certifying officers have
reached a conclusion that your disclosure controls and procedures
are
effective.  Please revise future filings to address your officers`
conclusions regarding the effectiveness of your disclosure
controls
and procedures.  In addition, please note that the definition of
disclosure controls and procedures is included in Rule 13a-15(e)
of
the Exchange Act.  However, if you wish to include the definition
in
your conclusion, please ensure the definition is consistent with
the
definition included in Rule 13a-15(e) of the Exchange Act.

2. Please revise the language in future filings used in your
disclosure concerning changes in your internal control over
financial
reporting to indicate whether there was any change, not only those
that "were identified as having occurred," to your internal
control
over financial reporting that has materially affected, or that is
reasonably likely to materially affect, your internal control over
financial reporting, consistent with the language used in amended
Item 308(c) of Regulation S-K.


Financial Statements - Page F-1

Note 2. Summary of Significant Accounting Policies - Page F-7

Revenue Recognition - Page F-9

3. Please respond to the following comments with respect to your
revenue recognition policies:

(A) We note that you provide rebates to your customers.  Please
tell
us and disclose in future filings, if material, the nature and
terms
of your rebates and how you account for them. Supplementally
provide
us with the amount of rebates recognized in each period presented
and
the basis for your accounting method.
(B) We note from page 6 that you enter into multi-year sales
agreements with your customers.  These agreements include a
minimum
number of tests that must be purchased over a two-to-five-year
period. The agreements may also include the option of a reagent
rental agreement under which you sell the tests at an increased
price
over a fixed period of time, which includes an additional
equipment
charge for providing the customer with the required laboratory
equipment. You obtain the equipment from a third-party vendor.
Please
tell us and disclose in future filings, if material, the nature
and
significant terms of these agreements and how you account for
them.
Supplementally provide us with the amount of revenues recognized
under these agreements in each period presented and the basis for
your accounting method.
(C) We note from the disclosure on page 10 that you also market
your
kits with laboratory testing services. As a result, you entered
into
agreements with laboratories to provide prepackaged test kits with
prepaid laboratory testing and specimen shipping costs included.
Please tell us and disclose in future filings, if material, the
nature and significant terms of these agreements and how you
account
for the related revenues. Supplementally provide us with the
amount
of revenues recognized under these agreements in each period
presented and the basis for your accounting method. Your response
should address how you consider each of the separate elements of
these arrangements in your revenue recognition policies. Include a
discussion of the timing and measurement of the related revenue.
(D) We note from the disclosure on pages 11 and 15 that you also
sell
third-party software and equipment. Please tell us and disclose in
future filings, if material, the nature and significant terms of
these sales and how you account for the related revenues.
Supplementally provide us with the amount of revenues recognized
for
sales of third-party equipment and software in each period
presented
and the basis for your accounting method. Address the accounting
for
both sales and rentals of the equipment.




*    *    *    *



      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your response to our
comments
and provides any requested supplemental information.  Detailed
cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
      You may contact Heather Tress, Staff Accountant, at (202)
824-
5263 or me at (202) 942-2861 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, the Senior Assistant Chief
Accountant, at (202) 942-1984.

							Sincerely,



							Kate Tillan
							Assistant Chief Accountant
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Mr. Ronald H. Spair
Orasure Technologies, Inc.
April 8, 2005
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