Understanding the 2023 Updates to the CSA C22.2 No. 301 Standard – Part 5

26 Aug 2025

Risk Assessment and Functional Safety

When it comes to product certification and machinery approvals, two key concepts are almost always central to the conversation: risk assessment and functional safety. Risk assessments form the foundation of most machinery approvals. A risk-based approach is essential because machinery varies widely in design and application, making it impractical and costly to develop prescriptive standards that address every possible risk scenario.

In the previous edition of CSA C22.2 No. 301, the concepts of risk assessment and functional safety were mentioned, but primarily in informative notes. The second edition introduces several new requirements and elevates some of these notes to normative (mandatory) status.

Risk Assessments

In the first edition, the standard did not explicitly require a risk assessment. However, several clauses implied the need for one by requiring that appropriate design decisions be based on risk considerations.

The second edition now explicitly requires that a risk assessment be included as part of the documentation package provided with the machine. This assessment must be conducted in accordance with CSA Z432, CSA Z434, or other applicable standards.

Functional Safety

The term “safety control functions” was used in CSA C22.2 No. 301 to describe functional safety, and it only appeared in an informative note. This note also only included reference to CSA C22.2 No 0.8. The updated edition expands on this by allowing the use of ISO 13849-1, ISO 13849-2 or IEC 62061 in addition to CSA C22.2 No. 0.8 to address the functional safety requirements.

The standard also has clarified that the control circuits and functions that are described in Section 9 of CSA C22.2 No 301 need to all be verified by either testing them, or by conformance to the functional safety requirements.

Safety-Related Control Functions

Where the machinery contains safety related control functions (such as the use of sensitive protective equipment like pressure sensitive mats) that are not described in CSA C22.2 No. 301, then those features are evaluated against CSA Z432.

Second Edition Transition

As the certifications that manufacturers have from the first edition need to update to those in the second addition, there will be greater scrutiny and documentation required to be performed by the certification body.