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[FLEXIBLE SOLUTIONS
LETTERHEAD]

August 11, 2005

VIA EDGAR – CORRESPONDENCE FILING

Securities and Exchange Commission

Judiciary Plaza

450 Fifth Street, N.W., Mail Stop 0510

Washington D.C., 20549

Attn: Ms. Pamela A. Long

Re:
Flexible Solutions International, Inc.

Registration Statement on Form S-3, filed on May 10, 2005 (SEC File No. 333-124751); Annual Report on Form 10-KSB for the Fiscal Year Ended December 31, 2004, filed on March 24, 2005 (SEC File No. 1-31540;) and Quarterly Report on Form 10-QSB for the Fiscal Quarter Ended March 31, 2005, filed on May 13, 2005
(SEC File No. 1-31540)

Dear Ms. Long:

        Flexible
Solutions International, Inc. (the “Company”), has reviewed the
Securities and Exchange Commission (the “Commission”) letter dated July
12, 2005 (the “July 12 Comment Letter”) regarding the Company’s
Registration Statement on Form S-3 (the “Form S-3”), the Company’s
Annual Report on Form 10-KSB for the fiscal year ended December 31, 2004 (the
“Form 10-KSB”) and the Company’s Quarterly Report on
Form 10-QSB for the fiscal quarter ended March 31, 2005 (the “Form
10-QSB”), filed by the Company on May 10, 2005, March 24, 2005 and May 13, 2005,
respectively. The Company responds to the July 12 Comment Letter as follows:

A.
Response
to SEC Comment 1

        The
SEC has replied that it is still unclear, given the guidance in Rule 11-01(d) of
Regulation S-X, how the Company determined that the acquisition of the Donlar assets was
not a purchase of a business. We believe that there are two primary factors that support
our position that Donlar was not an acquisition of a business. First, the business of
Donlar was bankrupt with no existing or projected profitable operations. Secondly,
substantially all of the customers of Donlar ceased doing business with the Company and
all relationships with previous customers had to be completely rebuilt.

        Rule
11-01(d) of Reg. S-X lists several factors to be considered in determining whether a
“business” has been acquired, the overall focus being whether there is a
sufficient continuity of the acquired entity’s operations prior to and after a
transaction such that the disclosure of the prior financial information is material to an
understanding of future operations. For purposes of such determinations, Rule 11.01(d) of
Reg. S-X sets forth the applicable measures, which are as follows:

Ms. Pamela A. Long

Securities and Exchange Commission

August 11, 2005

Page 2

         (a)
          whether the nature of the revenue-producing activity acquired is generally the
          same as before the transaction; or

         (b)
          whether any of the following attributes of the acquired operations were
          transferred: (i) physical facilities, (ii) employee base, (iii) market
          distribution system, (iv) sales force, (v) customer base, (vi) operating rights,
          (vii) production techniques, or (viii) trade names.

        It
is under this framework that the Company concluded it did not acquire a
“business” when it acquired the Donlar assets.

        Purchase
of the Assets. In May 2004 the Company acquired substantially all of the assets of
Donlar for the purchase price of $6.15 million. Consideration for the purchase price was
the payment of $3 million in cash, and the issuance of a secured promissory note to
Tennessee Farmers Life Insurance Company (“TFL”) for the remainder,
bearing interest at 4% per annum and due June 2, 2005.

        At
the time of Donlar’s bankruptcy, TFL was Donlar’s largest creditor and was
granted security interests, mortgages and other liens on substantially all of
Donlar’s assets. Due to a lack of profitable operations and negative cash flow Donlar
defaulted on its loans. TFL then commenced foreclosure proceedings and, in April 2004, the
United States Bankruptcy Court for the Northern District of Illinois, Eastern Division,
authorized the sale of the Donlar assets through a bidding process.

        Through
the auction process the receivers were unable to obtain any bidder for the assets of
Donlar. Although it had many patents and unique production processes the receivers were
unable to find any synergistic or otherwise potential purchaser who could utilize the
patents and processes developed by Donlar. As a result, FSI was the only bidder for the
assets of Donlar.

        When
the Company acquired the assets of Donlar, knowing full well that the business of Donlar
had ceased, it had as its primary objective the consolidation of the distribution and all
feasible manufacturing operations of the Company in one facility in the United States.
Prior to the acquisition of the Donlar assets the Company had a research facility in
Victoria, British Columbia, Canada, a manufacturing plant in Calgary, Alberta, Canada, a
distribution centre in Richmond, British Columbia, Canada, an additional distribution
centre in Chicago, Illinois, and an additional distribution center in Blaine, Washington.
Although the majority of the Company’s manufacturing and distribution centers were
located in Canada, the majority of the Company’s current and potential market share
resided in the United States.

        One
of the contributing factors for acquiring the operating assets and plant of Donlar was the
cancellation of the Sun Solar Energy Technologies and Ondeo Nalco distribution agreements.
Prior to the first quarter of 2004 the Heat$avr and Tropical Fish products were
distributed in North America by Sun Solar Technologies. During the fiscal year 2003 73% of
the Company’s total sales were through this company. The exclusive distribution
agreement with Sun Solar Technologies was entered into in February 1998. In order to
maintain the exclusivity of such agreement, Sun Solar Technologies had to order and pay
for at least 860,000 units during the year ended February 29, 2004. The agreement
terminated on February 29, 2004. Because the Company believed that it could distribute the
Tropical Fish products more economically than Sun Solar Technologies through its own
channels and Sun Solar Technologies did not meet the sales quota, the distribution
agreement was not renewed. The Company intended to distribute the Tropical Fish products,
renamed to Eco$avr, through the new Donlar plant.

Ms. Pamela A. Long

Securities and Exchange Commission

August 11, 2005

Page 3

        In
June 2002 the Company introduced the Water$avr product. This product utilizes the
Company’s technology to reduce water evaporation. It is marketed as a water
conservation product for use where water is standing or gently flowing and the need for
water can justify the cost of purchase and deployment of the product. The potential
applications for the product include reservoirs, potable water storage, aqueducts and
canals, agricultural irrigation, flood water crops, lawn and turf care and mining. The
Water$avr is sold in granular form and can be applied either by hand or through a fully
automated dispersal system. The primary markets for the Water$avr products are expected to
be Australia, Spain and the United States.

        In
September 2002 the Company granted Ondeo Nalco, of Naperville, Illinois, the exclusive and
non-exclusive distribution rights in Canada, the United States and most other countries
other than India and its surrounding countries. To maintain the exclusive rights to
distribute the Water$avr product Ondeo Nalco had to meet certain sales targets. If these
targets were not met then the exclusive rights would convert to non-exclusive rights.
Prior to September 30, 2003 Ondeo Nalco was successful in meeting its sales targets. In
September 2003 Ondeo Nalco missed a milestone sales level. As a result, the exclusive
rights reverted to non-exclusive rights and the options of the Company stock granted to
Ondeo Nalco were cancelled. The Company also has the Water$avr product manufactured by
Ondeo Nalco through a separate manufacturing agreement.

        The
Company announced the cancellation of the Ondeo Nalco exclusive distribution agreement in
a press release dated October 9, 2003. In this press release the Company stated that
although the exclusive distribution agreement would be modified, Ondeo Nalco would
continue to be the manufacturer of the product. With the acquisition of the Donlar assets
and plant, the Company would now be in a position to not only distribute the Water$avr
product in the United States and other countries, but would now also be in a position to
manufacture the product. The processes employed by Donlar to manufacture and produce its
biopolymers were very similar to the processes used by the Company to manufacture
Water$avr.

        The
Water$avr product was a patented product by the Company that when deployed onto a water
surface significantly reduced evaporation. With the addition of the Donlar assets the
Company was now able to continue its development of the Water$avr product and expand its
capabilities to Water$avr-BTI. Water$avr-BTI combines the original Water$avr technology
with mosquito larvae control. Water$avr-BTI, since the end of 2004, has been marketed
primarily for use in the reservoir, potable water storage, aqueduct, canal, agricultural
irrigation and mining industries. The Company would not have been able to profitably
manufacture this product without the addition of the Donlar assets.

Ms. Pamela A. Long

Securities and Exchange Commission

August 11, 2005

Page 4

        Water$avr-BTI
falls under the pest control ruling of the United States Environmental Protection Agency
(“EPA”). All factories manufacturing pest control materials must be EPA
approved in addition to obtaining the approval of the product itself. FSI has already had
the old Donlar plant EPA approved for Water$avr-BTI manufacture and is awaiting EPA
product approval in order to fulfill existing product orders. It is extremely difficult to
manufacture pest control products intended for use in the USA outside of the US, and FSI
would have found it difficult if not impossible to provide this product without a US
factory. Internal research by FSI has shown that the Water$avr-BTI market size in the USA
is in the range of $35 million per year — far in excess of the historical sales of
Donlar. FSI was specifically planning for this situation when assessing the purchase of
Donlar assets.

        FSI
has performed research and filed US patents for methods of sensing biohazards and
chemical pollutants in drinking water. This sensitive work leads to opportunities to
reformulate our Water$avr product in the old Donlar plant for sales to homeland  security channels. This type of work
must be done in US labs and factories by US citizens. The management of FSI perceived the
Donlar assets including the scientific team as ideal for these purposes. FSI is also
actively working on Water$avr versions that control algae as well as evaporation for use
in reservoirs that suffer from both problems. This product when finalized will be
formulated and distributed from the Donlar plant.

        In
addition to the above, and concurrent with the acquisition of the manufacturing plant, the
Company also negotiated with the Donlar leaseholders to obtain the use of Donlar’s
former corporate office space and laboratory facilities. These leases were independently
assumed by the Company and are on financial terms that differ from Donlar’s previous
obligations.

        The
addition of the Donlar assets and operating plant has provided the Company with
significant benefits apart from rebuilding the discontinued business of Donlar. The most
significant benefits of acquiring the Donlar assets are as follows:

         (1)
          The addition of the operating assets and manufacturing plant will enable the
          Company to consolidate some of its manufacturing processes that were previously
          in two locations in British Columbia, in Alberta, and in Illinois. The Company
          does not expect to consolidate all of the manufacturing operations in the Donlar
          plant as there are still some specific expertise and economies of production in
          the Alberta plant that would not be realized in the Donlar plant for some time.
          Once sales of certain products exceed the production capabilities of the
          Albertan plant, the Company intend to manufacture the additional sales in the
          Donlar facility:

Ms. Pamela A. Long

Securities and Exchange Commission

August 11, 2005

Page 5

         (2)
          Has enabled the Company to create one large distribution center in the United
          States for all of its products. The new distribution centre has assisted the
          Company to replace the distribution channels previously used by Sun Solar
          Technologies to market and distribute the Tropical Fish;

         (3)
          Has enabled the Company to continue its development plan by adding Water$avr-BTI
          to its list of products that it can now market to different segments; and

         (4)
          Will enable the Company to manufacture the Water$avr product in-house rather
          than relying on outside manufacturers such as Ondeo Nalco.

        Donlar
Business. When the Company acquired the assets of Donlar it was aware that the
business of Donlar was very poorly managed and that it had lost all of its major
customers. As stated, a secondary objective of the Company was to try and rebuild the
Donlar business since it was very similar. After the acquisition, the Company attracted
some of the old Donlar customers back to NanoChem only after they were convinced that a
complete new business with new management had been created. Many of the remaining Donlar
customers intended to switch to Lanxcess, a Donlar competitor as soon as stock in hand was
exhausted. Extensive efforts by FSI personnel were required to convince these customers to
try the new NanoChem products. Only after the acquisition did the Company begin to develop
and market its own TPA biopolymer products.

        Prior
to filing for bankruptcy protection, Donlar and its predecessors were engaged primarily in
the production, marketing, distribution and sale of the following three product lines:

•
Nutraceuticals
(nutrition supplement and sports bar markets);

•
Biopolymers
(performance chemical markets); and

•
Agriscience
Compounds (agricultural product markets).

         (a)
          Nutraceuticals. Prior to the Company’s acquisition of the Donlar
          assets, Donlar was engaged in the research, development, distribution and sale
          of nutraceutical and medical food products and supplements. These nutraceutical
          products were developed by Donlar and incorporated a patented whey protein
          technology designed to provide or increase protective immunities from and immune
          response to disease and to provide nutritional supplements. Donlar’s
          nutraceutical products were marketed to health food stores, health clubs and
          sporting good stores.

         (b)
          Biopolymers. Prior to the Company’s acquisition of the Donlar
          assets, Donlar was also engaged in the development, manufacture and marketing of
          biodegradable polymers (“biopolymers”). Biopolymers are
          non-hazardous, non-toxic, hypoallergenic, environmentally friendly and
          biodegradable chemical protein compounds. Biopolymers are used in a broad range
          of industrial and consumer markets and are manufactured from the common
          biological amino acid, L-aspartic acid. Donlar’s biopolymers were marketed
          by Donlar to prevent mineral scale and metal corrosion in industrial processes
          that use high volumes of water. The manufacturing processes used for biopolymers
          is very similar to the processes used to manufacture Water$avr.

Ms. Pamela A. Long

Securities and Exchange Commission

August 11, 2005

Page 6

         (c