Safety analysis is a part of the ITER Test Blanket Module (TBM) design process to ensure that the TBM does not adversely affect the safety of ITER. To get the license for TBM as a whole with International Thermonuclear Experimental Reactor (ITER), the relevant safety analysis is required for each TBM system proposed by each party. The safety analysis for the Chinese Dual-Functional Lithium-Lead Test Blanket Module (DFLL-TBM) has been performed based on the latest DFLL-TBM design. In this paper, the following safety considerations, such as source terms, operational releases, accident sequence analyses and waste assessment, have been analyzed. Both deterministic approach and complementary systematic approach starting with FMEA (Failure Mode and Effects Analysis) studies have been adopted in the accidental analysis. The preliminary results show that the DFLL-TBM system at normal operating conditions and under accident scenarios does not add additional safety hazards to ITER machine and can meet the ITER safety requirement and additional safety requirements for TBM system.