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<FILENAME>filename1.txt
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                                HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203

William T. Hart, P.C.              ________           Email:  harttrinen@aol.com
Will Hart                                             Facsimile:  (303) 839-5414

                                 (303) 839-0061

                                December 2, 2013

Jeffrey Gordon
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Flexible Solutions International, Inc.
            December 31, 2012 Form 10-K
            June 30, 2013 Form 10-Q
            File No. (001-31540)

     This office represents  Flexible  Solutions,  Inc. This letter provides the
Company's  responses  to the  comments  received  from the staff by letter dated
October 30,  2013.  The  paragraph  numbers in this letter  correspond  with the
paragraph numbers in the staffs' letter.


     1. The Company's  future filings will address the  disclosure  requested by
this comment. We believe the Company's disclosure concerning the reasons for any
material  changes in  financial  statement  line items is  adequate.  Insofar as
disclosing the amount of each significant  change between periods,  we call your
attention to  instruction 4 to Item 303(a) of Regulation  S-K, which provides in
part, the following:

     "Registrants need not recite the amounts of changes from year to year which
are readily computable from the financial  statements.  The discussion shall not
merely  repeat   numerical   data  contained  in  the   consolidated   financial
statements."

     The only line item in the Company's statement of operations which
has more than one reason for the change is "Sales". The changes in sales for the
Company's EWCP and BCPA product lines between 2012 and 2011 have been listed as
separate line items in the disclosure regarding material changes in statement of
operations.


     2. The draft disclosure requested by this comment will be sent shortly.

     3. The Company's  future filings will address the  disclosure  requested by
this comment. Please see footnote 8 to the Company's financial statements filed
with the Company's 10-Q report for the period ended September 30, 2013.

     4. Please see the Company's 10-Q report for the period ended  September 30,
2013.

     5. Please see the Company's 10-Q report for the period ended  September 30,
2013.

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     6. The  reference  to December 31, 2011 was in error.  Future  filings will
reference the correct date.

     7. The  Company's  next 10-K  report  will  state  that Dan  O'Brien is the
Company's Chief Financial Officer.

     8. The draft disclosure requested by this comment will be sent shortly.

     9. The draft disclosure requested by this comment will be sent shortly.

     10.  The  Company's  future  filings  will  reference   Exchange  Act  Rule
15d-15(e),  as well as 13a-15(e).  See the  certifications in the Company's 10-Q
report for the period ended September 30, 2013.

     11. Comment noted.

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                    Very Truly Yours,

                                    HART & HART, LLC

                                    /s/ William T. Hart

                                    William T. Hart
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