The risk of poor food safety is a major focus for managers in the food manufacturing industry. Despite industry-led and regulatory efforts to improve the overall food safety of US packaged consumer foods, product recalls and market withdrawals are increasing. This is especially true for the most frequent cause for food recall: the undeclared allergen. With industry trends leaning toward adoption of third-party food safety management certifications, a popular food safety code from the Safe Quality Foods Institute is evaluated using Systems Analysis. Three changes to the food safety code are proposed to address three of the top causes for an allergen-related recall in the United States. In practice, the SQF code should make better use of control theory to reduce delays in production monitoring activities, should make better use of purposeful action in the implementation of a HACCP plan to ensure continuing validity of the plan, and SQFI needs to consider adding an organizational assessment for food safety culture.