SecProbe.io

October  18, 2012

Via E -mail
Douglas A. Michels
President and Chief Executive Officer
OraSure Technologies, Inc.
220 East First Street
Bethlehem, PA  18015

Re: OraSure Technologies, Inc.
Registration Statement on Form S-3
Filed September 28, 2012
  File No.  333-184190

Dear Mr. Michels :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your discl osure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell u s why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

Who We Are, page 3

1. Please disclose prominently in your prospectus s ummary your history of losses and
accumulated deficit.  Quantify these items at least for the periods included in the financial
statements that you incorporate by reference.

Incorporation by Reference, page 36

2. Please refer to Form S -3, Item 12(a)(2), w hich indicates that you are required to
incorporate by reference all Exchange Act reports filed pursuant to Section 13(a) since
the end of the fiscal year covered by your annual report.  Given that your most recent
annual report covers the period ending De cember 31, 2011, please revise to incorporate
by reference your Form 8 -K filed on February 27, 2012 or advise.

Douglas A. Michels
OraSure Technol ogies, Inc.
October 18, 2012
Page 2

 Exhibit 5.1

3. Please file an opinion that addresses whether the rights are binding obligations of the
registrant under the law of the jurisdictio n governing the rights.  Please refer to Section
II.B.1.f of Staff Legal Bulletin No. 19 (Oct. 14, 2011).

4. Refer to the last paragraph on page 6 of this exhibit.  The opinion that you file to satisfy
your obligations under Regulation S -K Item 601(b)(5) may  not include any limitation on
reliance.  Note Section II.B.3.d of Staff Legal Bulletin No. 19 (Oct. 14, 2011).  Please file
a revised opinion.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be ce rtain that the filing includes the information the Securities Act of 1933 and
all applicable Securities Act rules 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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging t hat:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting purs uant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration.  We will consider a
written request for a cceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they r elate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Douglas A. Michels
OraSure Technol ogies, Inc.
October 18, 2012
Page 3

 Please contact Jose ph McCann at (202)  551-6262 or me at (202) 551 -3617  with any
questions.

     Sincerely,

/s/ Russell Mancuso

Russell Mancuso
 Branch Chief

cc (via email):  Ella DeTrizio , Esq. – Dechert  LLP