How to Carry Out Internal Allergen Audits under the ADDE Act

How to Conduct Internal Allergen Audits under the ADDE Act

Conducting Internal Allergen Audits Across Multi-Location Restaurants

An allergen audit is a systematic review of a restaurant’s ingredients, recipes, menus, staff knowledge, and operational practices to ensure allergen information is accurate, up-to-date, and communicated consistently. For multi-location operators, internal audits provide evidence that allergen management systems comply with California’s Allergen Disclosure for Dining Experiences (ADDE) Act requirements (SB-68) and that staff are trained, menus are correct, and cross-contact risks are minimized.

Audit Framework: Scope, Cadence, and Evidence

Standardize audits across locations using this framework. Cadence refers to the frequency and scheduling of audits based on risk.

Audit Area What to Verify Evidence to Capture Common Findings
Vendor Data All ingredients have current allergen declarations; change notices actioned promptly. Vendor spec PDFs, data feed timestamps, approval logs. Outdated specs, missing cross-contact statements, unlogged reformulations.
Recipe Integrity Recipes reflect latest ingredients; derivatives map to top allergens. Version-controlled exports, comparison reports. Unlinked sub-recipes, missing allergen roll-ups.
Menu Publication Printed and digital menus updated; third-party platforms current. Archived PDFs, change tickets referencing recipes, timestamps. Lags between approval and republishing; inconsistencies across channels.
Training Records All onboarding, refreshers, and role-specific modules completed and current. Digital dashboard export, attendance sheets, quiz results. Missed refreshers, no link to menu updates, turnover gaps.
FOH (Front of House) Communication Staff can locate allergen data and follow guest escalation scripts. Spot-check forms, secret-shopper notes, pre-shift briefing logs. Verbal guesses, outdated counter cards, missing escalation.
BOH (Back of House) Cross-Contact Segregation of utensils, labeled storage, cleaning validation, fryer policy compliance. Photos, line checklists, sanitizer logs, fryer sign-offs. Shared utensils without cleaning, unlabeled containers, fryer gaps.
Incident & CAPA (Corrective and Preventive Actions) Allergen queries/incidents logged; CAPAs completed on time. Incident reports, CAPA tracker with owners, due dates, effectiveness checks. Open CAPAs, repeated issues at same site.

Digital Food Data Systems for Audit Support

Modern digital food data management systems allow restaurants to automatically update menus when ingredients change. During internal audits or inspections, these systems ensure staff access the most current allergen information, reducing errors and simplifying verification.

By linking vendor data, recipes, and menu publishing, operators can instantly confirm compliance, track historical changes, and produce audit-ready reports. This reduces the risk of inconsistencies across locations and supports corrective actions if issues are identified.

Risk-Based Cadence for Multi-Site Operations

Audit frequency should align with risk tier, factoring in site volume, menu changes, past incidents, and staff turnover.

Risk Tier Criteria Audit Frequency Additional Controls
High High volume, frequent menu changes, recent incidents, high staff turnover. Monthly audit + quarterly regional QA review. Pre-shift allergen checks, weekly menu spot checks.
Medium Moderate volume/changes; stable team. Bi-monthly audit + semiannual QA review. Monthly refresher micro-modules.
Low Low change, strong historical performance. Quarterly audit + annual QA review. Randomized corporate spot checks.

Closing the Loop: Corrective Actions

  • Assign ownership and deadlines: Every finding should have a responsible person and due date.
  • Verify effectiveness: Recheck within 14–30 days; escalate recurring issues.
  • Share learnings: Disseminate anonymized findings and fixes across regions.
Tip: Use internal allergen audits as a team-building tool to boost staff confidence in their roles and daily operations. Integrate audits with your menu and training systems for streamlined evidence tracking.

Viewing audits this way reinforces accountability and ensures your team is inspection-ready while maintaining compliance.

Make Internal Allergen Audits Inspection-Ready

Standardize audits across all sites, link vendor data, recipes, menus, and training, and generate instant evidence packs for SB-68 compliance.

Talk to an expert Download resources Read the legislation

Context: The Allergen Disclosure for Dining Experiences (ADDE) Act applies to restaurant chains with 20 or more U.S. locations and requires public allergen disclosure by July 1, 2026. Administered by the California Department of Public Health (CDPH).

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