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                                HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________                   harttrinen@aol.com
Will Hart                                                         (303) 839-0061
Fax: (303) 839-5414



                                February 10, 2014


Jeffrey Gordon
Securities and Exchange Commission
100 F Street, N.E., Stop 4631
Washington, D.C. 20549

      Re:   Flexible Solutions International, Inc.
            Form 10-K for the year ended December 31, 2012
            File No. 1-31540


     This office represents Flexible Solutions  International,  Inc. This letter
is response to the staff's letter dated December 16, 2013. The paragraph numbers
in this letter  correspond  with the numbered  paragraphs in the staff's comment
letter.

     1.  The letter requested by this comment will be sent under separate cover.

     2.  Increases in sales volume were the primary  reason for the increases in
revenue,  which only  increased by 5.8% between 2012 and 2011. All factors which
materially  impacted  sales,  gross profit and operating  profit (loss) for each
period  presented  have  been  disclosed.   See,  for  example,  the  discussion
concerning the decline in the gross profit % during the year.

         See also attached page 15.

     3.  See attached page 16.

         The tables on page 15 of the 10-K report  provide a description of the
components in the statement of cash flows in layman's terms consistent with the
SEC's plain English  language rule. The variations  between the periods are
evident from the numbers in the table.

         See attached page 15.

     4.  Total segment assets as of as of December 31, 2012 and 2011, as shown
in Note 14 to the  Company's  December 31, 2012  financial  statements,  tie to
the amounts shown on the Company's December 31, 2012 and 2011 balance sheets.

     Total  segment  assets as shown in Note 12 to the  Company's  September 30,
2013 financial statements include the cost of patents.



<PAGE>


     As shown on the September 30, 2013 balance sheet:

            Property, equipment and leaseholds        $6,129,966
            Patents                                      179,226
                                                      ----------
                                                      $6,309,192


      5. See attached page 19.

      6. Footnotes 1 and 2 to the Executive Compensation table are worded
exactly as that provided by Item 402(c)(2)(iii) and (iv) of Regulation S-K. The
Executive Compensation table does not include any non-cash compensation.

      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

                                           By
                                                William Hart



<PAGE>



     The factors that will most  significantly  affect future operating  results
will be:

     o    the sale  price  of crude  oil  which  is used in the  manufacture  of
          aspartic acid we import from China.  Aspartic acid is a key ingredient
          in our BCPA product ;

     o    activity in the oil and gas  industry,  as we sell our BCPA product to
          oil and gas companies; and

     o    drought conditions, since we also sell our BCPA product to farmers.

      Other than the foregoing we do not know of any trends, events or
uncertainties that have had, or are reasonably expected to have, a material
impact on our revenues or expenses.


Capital Resources and Liquidity

        Our material sources and (uses) of cash during the year ended December
31, 2012 were:

Cash used by operations                                        $(305,840)
Equipment purchases, primarily related to our
   new facility in Alberta, Canada                              ( 96,721)
Borrowing from short term line of credit                         555,000
Repayment of loans                                              (293,397)
Exchange rate changes                                           (  4,078)
Cash on hand at beginning of period                              145,036

        Our material sources and (uses) of cash during the year ended December
31, 2011 were:

Cash used by operations                                        $(798,800)
Equipment purchases, primarily related to our
    new facility in Alberta, Canada                             (794,848)
Borrowing from short term line of credit                         650,000
Repayment of loans                                              (309,056)
Repurchase of common stock                                    (1,030,349)
Exchange rate changes                                             26,536
Cash on hand at beginning of period                            2,256,517


     In 2007, we began construction of a plant in Taber Alberta.  The plant came
on line during 2012 and we began  depreciating  the plant and related  equipment
effective January 2012. This resulted in a significant  increase in depreciation
expense as shown on our  statement  of cash flows for year  ended  December  31,
2012.

     Inventories  also  increased due to production at our newly opened plant in
Alberta.

     The plant in Alberta is being used to  manufacture  aspartic  acid which is
the major  component of TPAs.  Previously,  we bought  aspartic  acid from China
where the base raw  material  is oil.  Our plant in Taber uses sugar as the base
raw  material.  Although we expect that we will still import some  aspartic acid
from China, using aspartic acid manufactured by our plant from sugar will reduce
our raw material costs,  reduce price  fluctuations  generated by oil prices and
reduce shipping costs.


     We have sufficient cash resources to meets our future  commitments and cash
flow  requirements  for the coming  year.  As of  December  31, 2012 our working
capital was  $3,489,827  and we have no  substantial  commitments  that  require
significant outlays of cash over the coming fiscal year.


                                       15
<PAGE>


     We are  committed  to minimum  rental  payments  for  property and premises
aggregating  approximately  $203,259  over  the  term of two  leases,  the  last
expiring on July 31, 2014.

      Commitments in each of the next five years are as follows:

                  2013            $155,295
                  2014            $ 47,964

     Other than as disclosed  above,  we do not anticipate any material  capital
requirements for the twelve months ending December 31, 2013.


     Other than as  disclosed  in Item 7 of this  report,  we do not know of any
trends,  demands,  commitments,  events or uncertainties that will result in, or
that are reasonable likely to result in, our liquidity  increasing or decreasing
in any material way.

      Other than as disclosed in Item 7 of this report, we do not know of any
significant changes in our expected sources and uses of cash.


     We do not have any commitments or  arrangements  from any person to provide
us with any equity capital.

     See Note 2 to the financial  statements included as part of this report for
a description of our significant accounting policies.

Critical Accounting Policies And Estimates

     Allowances for Product Returns. We grant certain of our customers the right
to return product which they are unable to sell. Upon sale, we evaluate the need
to record a provision for product  returns based on our  historical  experience,
economic trends and changes in customer demand.

     Allowances  for  Doubtful  Accounts  Receivable.  We evaluate  our accounts
receivable to determine if they will  ultimately be collected.  This  evaluation
includes  significant   judgments  and  estimates,   including  an  analysis  of
receivables aging and a review of large accounts. If, for example, the financial
condition of a customer  deteriorates  resulting in an impairment of its ability
to pay or a pattern of late payment develops, an allowance may be required.

     Provisions  for Inventory  Obsolescence.  We may need to record a provision
for  estimated  obsolescence  and shrinkage of  inventory.  Our estimates  would
consider the cost of inventory,  the estimated  market value,  the shelf life of
the  inventory  and our  historical  experience.  If there are  changes to these
estimates, provisions for inventory obsolescence may be necessary.

Recent Accounting Pronouncements

     We have evaluated recent accounting  pronouncements issued since January 1,
2012 and determined that the adoption of this recent  accounting  pronouncements
will not have a material effect on our financial statements.

ITEM 7A.  QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK.

      Not applicable.


                                       16
<PAGE>


      We believe our directors benefit us for the following reasons:

         Name                       Reason
         ---------------            ----------------

         Daniel B. O'Brien          Long standing relationship with us.

         John J. Bientjes           Long standing relationship with us.

         Dr. Robert N. O'Brien      Long standing relationship with us.

         Dale Friend                Long standing relationship with us.

         Robert Helina              Corporate finance experience.

         Dr. Thomas Fyles           Scientific expertise.

ITEM 11.  EXECUTIVE COMPENSATION.

Summary Compensation Table

      The following table shows in summary form the compensation earned by (i)
our Chief Executive Officer and (ii) by each other executive officer who earned
in excess of $100,000 during the two fiscal years ended December 31, 2012.

<TABLE>
<S>                    <C>     <C>      <C>       <C>        <C>       <C>          <C>
                                                                       All
                                              Restricted              Other
Name and                                         Stock     Options    Annual
Principal             Fiscal  Salary   Bonus     Awards     Awards  Compensation
Position               Year     (1)     (2)       (3)        (4)       (5)          Total
------------------------------------------------------------------------------------------

Daniel B. O'Brien      2012  $612,184    --        --     $ 17,742      --        $629,926
President and Chief    2011  $174,505    --        --       29,799      --        $204,304
  Executive Officer
</TABLE>

(1) The dollar value of base salary (cash and non-cash) earned.

(2) The dollar value of bonus (cash and non-cash) earned.

(3) During the periods covered by the table, the value of the shares of
    restricted stock issued as compensation for services to the persons listed
    in the table.

(4) The value of all stock options granted during the periods covered by the
    table.

(5) All other compensation received that we could not properly report in any
    other column of the table.


      During the year ended December 31, 2012, the Company determined that
Daniel B. O'Brien, the Company's President and Chief Executive Officer, was
underpaid. Accordingly, the Company increased Mr. O'Brien's annual salary to
twice that which was paid to the highest paid employee of the Company. The
Company expects that Mr. O'Brien's salary for the year ending December 31, 2014
will again be twice the annual salary paid to the Company's highest paid
employee, excluding Mr. O'Brien.


Stock Option Program

      Our Stock Option Program involves the issuance of options, from time to
time, to our employees, directors, officers, consultants and advisors. Options
are granted by means of individual option agreements. Each option agreement
specifies the shares issuable upon the exercise of the option, the exercise
price and expiration date and other terms and conditions of the option.


                                       19

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