The Allergen Audit Trail: How to Evidence Every Ingredient Change under SB-68

The Allergen Audit Trail: How to Evidence Every Ingredient Change under SB-68

How to track allergens across ingredient, recipe, and menu changes

Creating a Digital Audit Trail for Allergen Disclosures

Every ingredient change carries risk under SB-68 (Allergen Disclosure for Dining Experiences Act). Supplier reformulations or recipe updates can make allergen disclosures inaccurate overnight.

Maintaining an allergen audit trail ensures you have a verifiable record showing exactly when ingredients, recipes, and menus changed, who approved them, and when the allergen data was republished.

What is an allergen audit trail?
It’s a clear, verifiable record that tracks every ingredient, recipe, and menu change, showing who approved updates and when allergen information was republished — giving your foodservice operation defensible proof of compliance under SB-68.

Why an audit trail matters

SB-68 introduces the phrase “knows or reasonably should know.” If your organization had access to updated ingredient information but failed to act on it, you could be considered non-compliant. An allergen audit trail provides proof that you acted responsibly and promptly — converting intent into documented evidence.

What a complete allergen audit trail contains

Record Type Purpose Example Evidence
Supplier Change Log Tracks when suppliers update ingredient specs or allergens. Email or digital feed update showing new spec uploaded on specific date/time.
Recipe Revision Record Shows when the affected recipe was reviewed and updated. System log: “Sesame added to multigrain bread recipe — updated by L. Kirwan, 2025-09-10.”
Menu Publication Log Confirms when allergen data was republished across channels. Digital menu timestamp + archived PDF of printed menu version.
Approval Workflow Documents who reviewed and authorized each change. Manager sign-off in digital menu management system.

How digital systems automate this process

  • Time-Stamped Updates
    Every ingredient, recipe, and menu edit is logged with date, user, and version ID.
  • Change Alerts
    When suppliers reformulate an ingredient, affected recipes and menus are automatically flagged for review.
  • Instant Republishing
    Once verified, allergen data cascades to all digital and printed menus simultaneously.
  • Audit Export
    One click generates a downloadable report showing compliance activity for inspectors.
Treat your audit trail as live data, not just an archive. Review it monthly to confirm all allergen changes have matching recipe and menu updates — a simple routine that keeps you inspection-ready year-round.

Example: turning an allergen change into evidence

When a mayonnaise supplier adds egg powder, the system automatically flags all recipes containing that mayonnaise. A QA manager approves the update, and menus are republished overnight. The audit trail then shows:

  • Supplier update received: 2025-08-18 09:22 AM
  • Recipe update completed: 2025-08-18 11:05 AM
  • Menu republished: 2025-08-18 11:45 AM
  • QA approval: 2025-08-18 12:10 PM

This demonstrates “reasonable action” under SB-68 and provides defendable proof if an allergen incident occurs.

A complete, automated allergen audit trail ensures your foodservice operation stays compliant under SB-68, protects guests, and provides defendable proof of every ingredient, recipe, and menu change.

Make your allergen audit trail automatic

Automated audit logs record every supplier, recipe, and menu change — creating instant, defensible evidence of due diligence under SB-68.

Talk to an expert Explore ADDE resources Read the legislation

Context: The Allergen Disclosures for Dining Experiences (ADDE) Act requires restaurant chains with 20 or more U.S. locations to publicly disclose allergens and maintain verifiable update records by July 1, 2026. The Act is administered under the California Department of Public Health (CDPH). If unsure, always check the bill or ask an expert.