Mail Stop 0306


May 18, 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 response letter dated April 22, 2005
and
have the following additional 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

Item9A. Controls and Procedures - Page 51

1. See prior comment 1. We note your response. If you wish to
include
the definition following your conclusion, please ensure the
definition is consistent with the definition included in Rule 13a-
15(e) of the Exchange Act. That is, revise future filings to also
clarify, if true, that your officers concluded that your
disclosure
controls and procedures are effective to ensure that information
required to be disclosed in the reports that you file or submit
under
the Exchange Act is accumulated and communicated to your
management,
including your chief executive officer and chief financial
officer,
to allow timely decisions regarding required disclosure.

Financial Statements - Page F-1

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

Revenue Recognition - Page F-9

2. See prior comment 3.

a. See prior comment 3(B). It appears that your agreements include
a
lease arrangement with respect to the equipment for which you are
not
providing separate accounting. If material, please revise
historical
and future filings to properly account for these transactions, or
tell us why the current accounting is appropriate.
b. See prior comment 3(C). It appears that you are providing three
separate elements: (1) prepackaged test kits, (2) laboratory
testing
services, and (3) shipping. If material, please revise historical
and
future filings to properly account for each element, or tell us
why
the current accounting is appropriate. In addition, please explain
why you refer to recording revenue for testing services over a
four-
to-six month period and not as the services are performed.



*    *    *    *


      As appropriate, please respond to these comments 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.

      You may contact Heather Tress, Staff Accountant, at (202)
551-
3624 or me at (202) 551-3604 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Michele Gohlke, Accounting Branch Chief,
at
(202) 551-3327.

							Sincerely,



							Kate Tillan
							Assistant Chief Accountant
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Mr. Ronald H. Spair
Orasure Technologies, Inc.
May 18, 2005
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