April 18, 2006

Mail Stop 7010


By U.S. Mail and facsimile to (250) 477-9912

Daniel B. O`Brien
President and Chief Executive Officer
Flexible Solutions International, Inc.
615 Discovery Street
Victoria, British Columbia
V8T 5G4, Canada


Re: 	Flexible Solutions International, Inc.
	Amendment No. 2 to Registration Statement on Form S-3
Filed March 30, 2006
	File No. 333-124751
	Form 10-KSB for Fiscal Year Ended December 31, 2005
	Filed March 9, 2006
	Form 10-KSB/A for Fiscal Year Ended December 31, 2004
	Filed March 9, 2006
	Form 8-K filed March 13, 2006
	File No. 1-31540


Dear Mr. O`Brien:

      We have reviewed your filings and have the following
comments.
We welcome any questions you may have about our comments or any
other
aspect of our review.  Feel free to call us at the telephone
numbers
listed at the end of this letter.


Form 10-KSB for the year ended December 31, 2005
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-1

1. It is not clear why Cinnamon Jang Willoughby & Company appears
to
have issued two different audit reports related to the financial
statements for the year ended December 31, 2004.  Please advise
why
they reported separately to the shareholders on February 11, 2005,
and then reported again on these same financial statements to the
board of directors and shareholders on March 15, 2005.

Item 8A. Controls and Procedures

2. Given the restatement related to your inventory, please provide
us
with a detailed explanation as to how you were able to conclude
that
your disclosure controls and procedures were effective as of
September 30, 2005, and December 31, 2005.  Please address how
management determined that the restatement was not the result of a
material weakness with respect to your disclosure controls and
procedures or your internal controls over financial reporting.


Form 8-K dated March 10, 2006

3. You present operating cash flow which appears to be cash used
in
operating activities, as calculated in accordance with GAAP and
presented on your statements of cash flows, adjusted for certain
items.  Given this, the amount appears to constitute a non-GAAP
financial measure.  Please amend your Form 8-K to provide the
disclosures required for non-GAAP financial measures.  Refer to
Instruction 2 to the Form 8-K and Item 100(a) of Regulation G.


      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  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 the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* 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 pursuant 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a 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 relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Marie Humphrey, Staff Accountant, at (202)
551-
3734 or Nudrat Salik, Senior Staff Accountant, at (202) 551-3692
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact Matt Franker, Staff Attorney, at
(202) 551-3749 or Chris Edwards, Special Counsel, at (202) 551-
3742
with any other questions.  Alternatively, you may contact me at
(202)
551-3760.


Sincerely,



Pamela A. Long
Assistant Director

cc:	Deepak Nanda, Esq. (via facsimile 310/557-8475)
      Foley & Lardner LLP
      2029 Century Park East, Suite 3500
      Los Angeles, California 90067

Daniel B. O'Brien
Flexible Solutions International, Inc.
April 18, 2006
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

           DIVISION OF
CORPORATION FINANCE