Allergen Disclosure for Dining Experiences Act Knowledge Hub

Are Your Allergen Records Inspection-Ready?

Written by

Dr Laura Kirwan PhD

in

Are Your Allergen Records Inspection-Ready?

Learn how to build an audit-ready allergen process that protects guests and your business

Under the Allergen Disclosure for Dining Experience (ADDE) Act (also known as Senate Bill 68), the legal requirement for allergen disclosure is “knowing or reasonably should know.” That makes documentation your strongest protection.

Simply saying you manage allergens isn’t enough — you need to prove it with traceable, time-stamped records.

Considering that over 32 million Americans live with food allergies, having clear and up-to-date allergen documentation isn’t just regulatory — it’s essential for protecting guests and your reputation.

The principle: if it’s not documented, it didn’t happen

Local health inspectors can verify allergen disclosure visually, but during audits or incidents, your documentation becomes your defense. It shows that your business followed structured, repeatable steps to keep allergen information accurate — even if human or vendor errors happen.

In allergen management, due diligence means having documented, traceable processes that show you took all reasonable steps to identify and disclose allergens .

Five pillars of allergen disclosure documentation

Pillar Purpose Example of Strong Evidence
Vendor Specifications Show ingredient data was obtained from authoritative sources. vendor allergen declarations with upload timestamps or change notifications.
Recipe-Level Allergen Mapping Demonstrate correct application of allergen data within recipes and sub-recipes. Ingredient-level allergen tags and system logs confirming review and approval.
Menu Publication Records Prove that allergen disclosures were communicated accurately to guests. PDF copies of menus, QR snapshots, and digital version logs.
Training Records Verify staff training and awareness of allergen communication procedures. Attendance sheets, completion certificates, or digital training logs.
Audit & Change Logs Provide traceability for all allergen updates and corrections. Digital change logs showing dates, items, and republish confirmations.

How digital systems simplify documentation

Modern allergen disclosure platforms generate much of this documentation automatically — logging vendor updates, recipe changes, and menu republications with timestamps and user IDs. They can:

  • Track every change to vendor allergen data and link it to affected menu items.
  • Generate allergen matrices instantly for inspectors or internal reviews.
  • Store previous versions of recipes and menus for verification.
  • Prevent publication of menus missing verified allergen data.
While digital automation makes allergen tracking easier, inspectors ultimately care about whether your data is current, traceable, and defensible. A manual log, while harder to maintain, can demonstrate the same due diligence as a fully automated system — if it’s consistent and accessible, but digital trails with audited chang.

Demonstrating due diligence in a real-world scenario

Imagine a guest reaction incident involving sesame in a breaded appetizer. A compliant operator could demonstrate due diligence by presenting:

  • A vendor allergen update email dated May 10 noting the addition of sesame flour.
  • A recipe update log on May 11 showing that the breadcrumb ingredient was revised.
  • A menu republish record on May 12 confirming updated allergen info across channels.
  • A manager sign-off and photo proof of updated allergen binders on May 13.
With a clear, digital trail , the operator can prove they took timely, reasonable action — satisfying the “knew or reasonably should have known” requirement under SB-68.

Checklist: What inspectors may ask to see

  • Current allergen matrix or written alternative available to guests.
  • Recent vendor specifications and ingredient change notices.
  • Copies of printed and digital menus showing disclosures.
  • Training and sign-off records for current staff.
  • Evidence of allergen data audits or verification cycles.

Building your audit-ready binder (digital or physical)

An effective allergen documentation binder should be version-controlled, searchable, and updated regularly. Include:

  1. Vendor Data: Specs sorted by category and last update date.
  2. Recipes: Allergen-mapped recipes and sub-recipes.
  3. Menus: Copies of printed menus, QR versions, and written alternatives.
  4. Training: Proof of staff training sessions and refreshers.
  5. Change Logs: Timestamped vendor and recipe updates.
Use your menu management system to generate a compliance record bundle every time you publish or update a menu. This should include the allergen matrix, a change log showing who updated what/when, and a timestamped menu copy.

These files form an instant, verifiable audit trail proving that your allergen data was accurate at the time of service.

Allergen compliance under the ADDE Act is based on the phrase “reasonably should know.”

A digital, documented allergen-update routine proves that your organization has systems in place to identify and disclose new allergen risks and supports” due diligence”.

Make your compliance verifiable

Download documentation templates and checklists to help your team prove due diligence, not just claim it — and ensure every allergen disclosure is traceable, accurate, and inspection-ready.

Get documentation templates Ask an expert View official legislation

More posts