Multi-Site Allergen Governance Frameworks for ADDE Act Compliance

Building a Multi-Site Allergen Governance Framework

Practical guide for U.S. foodservice operators to manage allergens across multiple sites

In the U.S., an estimated 32 million people live with food allergies, and roughly 90% of reactions stem from nine allergens: milk, eggs, peanuts, tree nuts, wheat, soy, fish, shellfish, and sesame.

Restaurant chains and multi-location operators need more than written policies — they must implement practical, operational governance to ensure consistency across dozens or hundreds of sites, reduce guest risk, and support compliance with SB-68.

Governance framework overview

The table below shows a tiered model linking site operations to corporate oversight:

Governance Level Key Responsibilities Reporting Output
Site-Level Allergen Champion Maintains local allergen logs, verifies menu accuracy daily, tracks staff training, logs guest allergen inquiries or incidents. Weekly allergen verification checklist and staff training completion report.
Regional QA / Area Manager Reviews site-level data, validates corrective actions, ensures ingredient or recipe changes from vendors/broadliners are applied consistently. Monthly regional compliance summary with exceptions and recommendations.
Corporate Compliance Lead Defines standards, approves audit templates, oversees governance dashboards, reports SB-68 readiness to executives and regulators. Quarterly compliance dashboard aggregating site and regional performance.

Key elements of a multi-site allergen governance framework

A well-designed framework covers the following areas:

Area Practical Actions
Accurate data Validate allergen information from vendors and broadliners in real time before recipes are updated.
Real-time integration Connect vendor data, validation checks, recipes, menus, and customer-facing outputs using a digital food data system.
Recipe and menu management Track allergens at ingredient, sub-recipe, and full menu item levels, including specials and limited-time offers (LTOs).
Regulatory coverage Account for regional differences in regulations and menu requirements to ensure all outputs comply with local laws.
Staff accountability and training Assign site Allergen Champions, run refresher training, and ensure staff understand updates and processes.
Substitute and alternative lists Maintain approved allergen-safe alternatives and update menus promptly when ingredients change.
Supply chain monitoring Track ingredient substitutions, disruptions, or reformulations that could affect allergen status.
Outputs compliance Ensure all menus, digital and printed, meet legal requirements and include additional information your customers expect.
Treat allergen governance like financial controls — decentralize operational action, centralize accountability, and ensure every change is traceable with timestamped audit logs.

How to Set Up a Multi-Site Allergen Governance Framework

To ensure accurate allergen management across all locations, every level of your organization should operate from the same verified allergen dataset. A real-time digital food data system makes this possible by:

  • Capturing vendor and broadliner allergen data and validating it before it affects recipes.
  • Integrating validated data into your recipe management workflow.
  • Automatically updating menus (digital, printed, QR) with any allergen changes.
  • Logging every change with a user ID and timestamped audit logs for traceability.
  • Generating alerts to flag discrepancies or missing updates.
  • Providing dashboards for site and regional teams to monitor updates and compliance.
  • Incorporating regulatory flexibility to account for regional law differences while keeping operations consistent.

By implementing these steps, operators can achieve consistent, auditable allergen governance across all sites, reducing risk, ensuring accurate menu information for guests, and supporting compliance under SB-68.

Context: California Senate Bill 68 (ADDE Act) requires written allergen disclosure for restaurant chains with 20+ locations by July 2026. It amends Section 113820.5 and adds Section 114093.5 to the California Health and Safety Code.

Streamline multi-site allergen management

Implement a structured governance framework and real-time food data system to ensure consistent allergen information across all locations, reduce risk, and maintain compliance under SB-68.

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