SB68 compliance depends entirely on well-trained staff who can accurately communicate allergen information to customers and prevent cross-contamination in the kitchen. California law requires restaurant employees to have adequate knowledge of major food allergens, their symptoms, and proper handling procedures—making comprehensive training not just best practice, but a legal necessity starting July 1, 2026.
This guide outlines exactly what your servers, cooks, and managers must know to keep customers safe while meeting California's allergen disclosure requirements.
Why Staff Training Is Critical for SB68 Compliance
The Legal Foundation
California's existing Retail Food Code already mandates that persons in charge of food facilities must have adequate knowledge of major food allergens and educate employees on these matters. SB68 amplifies these requirements by making allergen information publicly visible on menus, which means staff will face significantly more allergen-related questions from customers.
The stakes are high:
- Misinformation about allergens can cause life-threatening reactions
- Staff errors can result in violations carrying fines
- Approximately half of all fatal allergic reactions occur from restaurant meals
- One mistake can lead to customer lawsuits, negative publicity, and license sanctions
Beyond Legal Compliance
Proper training delivers business benefits:
- Builds customer trust among the 2+ million Californians with food allergies
- Reduces liability exposure through consistent, accurate allergen communication
- Empowers staff confidence when handling allergen inquiries
- Prevents costly incidents that damage reputation and revenue
- Creates competitive advantage as an allergen-conscious establishment
What Do Servers and Front-of-House Staff Need to Know?
Understanding the Nine Major Allergens
Every customer-facing employee must be able to identify and explain the nine allergens covered by SB68:
The "Big 9" allergens are:
- Milk – Including butter, cheese, cream, yogurt, whey, casein
- Eggs – In all forms, including mayonnaise and some pasta
- Fish – All finned fish species
- Shellfish – Crustaceans like shrimp, crab, lobster
- Tree nuts – Almonds, walnuts, pecans, cashews, pistachios, etc.
- Peanuts – Including peanut oil and peanut butter
- Wheat – All wheat varieties, including spelt and kamut
- Soybeans (Soy) – Including soy sauce, tofu, edamame
- Sesame – Seeds, oil, and tahini
Training must cover:
- How to pronounce and spell each allergen correctly
- Common menu items that contain each allergen
- Hidden sources of allergens (e.g., wheat flour dusting on pizza stones, fish sauce in dressings)
- Which menu modifications eliminate allergens vs. which don't
How Should Servers Communicate with Customers About Allergens?
The Golden Rules of Allergen Communication:
1. Never guess or assume. If you don't know whether a dish contains an allergen, say: "Let me check with the kitchen manager to give you accurate information."
2. Take all allergen concerns seriously. Treat every inquiry as potentially life-threatening, not just a dietary preference.
3. Use clear, direct language. Say "This dish contains peanuts" rather than vague statements like "It might have nuts."
4. Acknowledge limitations honestly. If cross-contamination is possible despite ingredient changes, inform the customer: "We can make this without shellfish, but our kitchen does prepare shellfish dishes, so trace amounts may be present."
5. Document special requests. Write allergen alerts clearly on order tickets going to the kitchen.
Sample Server Scripts for Allergen Inquiries
When a customer asks about allergens:
"I'm glad you asked. According to our menu, [dish name] contains [specific allergens]. Would you like me to go over the full ingredient list or discuss modification options?"
When a customer requests modifications:
"I can have the kitchen prepare that without [allergen]. However, I should let you know that we do use [allergen] in our kitchen, so there's a possibility of trace contact. Is that acceptable for your needs?"
When you don't know the answer:
"That's an important question, and I want to make sure I give you accurate information. Let me speak with our kitchen manager who can confirm the exact ingredients for you. I'll be right back."
When a dish cannot be safely modified:
"Unfortunately, [dish] contains [allergen] as an essential ingredient and cannot be prepared safely for someone with a [allergen] allergy. However, let me show you other options that don't contain [allergen] at all."
What Information Must Be Readily Available to Servers?
Front-of-house staff should have instant access to:
- Updated allergen matrix or chart showing which menu items contain which allergens
- Ingredient lists for complex dishes and house-made items
- Modification guidelines explaining which customizations affect allergen content
- Cross-contact information about shared fryers, grills, and preparation surfaces
- Manager contact who can answer detailed allergen questions
Many restaurants provide servers with laminated allergen reference cards or tablets with searchable allergen databases to use tableside.
What Do Kitchen Staff and Cooks Need to Know?
Preventing Cross-Contamination
Kitchen staff training must emphasize cross-contact prevention—the unintentional transfer of allergens from one food to another. This is often more dangerous than intentional ingredients because customers don't expect it.
Critical kitchen practices include:
Handwashing protocols:
- Wash hands with soap and water between handling different allergens
- Gloves alone don't prevent contamination; hands must still be washed
- Change gloves after handling major allergens
Equipment and surface sanitation:
- Clean cutting boards, knives, and prep surfaces thoroughly between allergen-containing dishes
- Use separate utensils for allergen-free preparations when possible
- Don't wipe allergen residue with a towel—wash surfaces with hot, soapy water
Fryer and grill management:
- Know which fryers are dedicated to certain items (e.g., shellfish-only fryer)
- Understand that shared oil transfers allergens between foods
- Clean grill surfaces between cooking allergenic items for special orders
Storage separation:
- Store allergen-containing ingredients separately to prevent drips and spills
- Label containers clearly
- Use sealed containers for highly allergenic ingredients
How Should Kitchen Staff Handle Special Allergen Orders?
Step-by-step protocol for allergy-special orders:
- Read the ticket carefully – Look for allergy alerts marked by servers
- Clean work surfaces – Sanitize cutting boards, knives, and prep areas
- Wash hands and change gloves – Start with clean hands
- Use fresh ingredients – Don't cross-use utensils from allergen-containing ingredients
- Plate separately – Use clean plates, not surfaces where allergen items were placed
- Double-check before serving – Verify no garnishes or sauces with allergens were added
- Alert the expeditor – Ensure front-of-house knows this is an allergy order requiring careful delivery
Example scenario: A customer orders a burger without the sesame seed bun due to sesame allergy.
❌ Wrong approach: Remove sesame bun, use same gloves, place burger on same plate where bun was sitting.
✓ Correct approach: Wash hands, put on clean gloves, prepare burger with lettuce wrap or sesame-free bun on clean surface, plate on fresh dish, alert server this was prepared allergen-free.
What Do Managers Need to Know?
Comprehensive Allergen Management Oversight
Managers carry legal responsibility for ensuring compliance and must understand:
Legal obligations:
- Specific SB68 requirements and disclosure methods
- Penalty structure for violations ($25-$1,000 per offense, possible jail time)
- Documentation requirements for compliance audits
- Local health department enforcement procedures
Supplier management:
- How to request and verify allergen information from vendors
- When to re-verify supplier data (quarterly recommended)
- What to do when supplier formulations change
- How to handle suppliers who won't provide allergen data
Menu and recipe knowledge:
- Complete ingredient lists for every menu item
- How modifications affect allergen content
- Cross-contamination risks in your specific kitchen layout
- Seasonal menu changes and limited-time offers
Emergency response:
- How to recognize signs of allergic reactions (hives, swelling, difficulty breathing, vomiting)
- When to call 911 (immediately for severe symptoms)
- How to document incidents for insurance and legal purposes
- Post-incident customer follow-up procedures
When Should Managers Get Involved in Allergen Questions?
Managers should intervene when:
- Customers express serious allergy concerns beyond simple questions
- Staff are unsure about allergen content or cross-contamination risks
- Customers request complex modifications requiring kitchen coordination
- Any allergic reaction symptoms appear during or after the meal
- Customers complain about inaccurate allergen information
How Often Should Staff Training Occur?
Initial Training Requirements
Before SB68 launch (by July 1, 2026):
- All current employees must complete comprehensive allergen training
- Training should be 2-4 hours minimum for thorough coverage
- Include both classroom instruction and hands-on demonstrations
- Require signed acknowledgment forms confirming understanding
- Test comprehension through quizzes or role-playing scenarios
For new hires (ongoing):
- Incorporate allergen training into onboarding on Day 1 or Week 1
- Don't allow customer interaction until training is complete
- Assign mentors to reinforce allergen protocols during initial shifts
Ongoing Refresher Training
Quarterly refreshers (every 3 months):
- Brief 15-30 minute reviews of key concepts
- Cover any menu changes affecting allergen content
- Share lessons learned from recent allergen-related incidents
- Update staff on any regulatory changes
Semi-annual deep training (every 6 months):
- Comprehensive 1-2 hour retraining session
- Full review of all allergen communication protocols
- Retesting to ensure knowledge retention
- Opportunity for staff to ask questions and share concerns
Trigger-based training:
- Whenever menu changes introduce new allergens
- After any allergen-related customer incident
- When suppliers change formulations
- Following health department violations or warnings
Are Allergen Training Certifications Required?
Current California Requirements
California already requires food handlers to obtain food handler cards after completing training that covers major food allergens. SB68 doesn't create additional certification requirements beyond existing food handler card mandates.
What's required:
- Food handler certification through approved providers
- On-the-job allergen training specific to your menu
- Documentation of completion for both
What's recommended but not required:
- ServSafe Allergens online course certification
- AllerTrain allergen awareness certification
- Internal certification programs documenting mastery of your specific menu
Documentation Best Practices
Even without certification requirements, maintain records of:
- Training attendance logs with dates and topics covered
- Signed acknowledgment forms from each employee
- Quiz or test scores demonstrating comprehension
- Refresher training dates and attendance
- Copies of food handler cards for all employees
These records prove compliance if health inspectors investigate violations or customers file complaints.
What Topics Should Be Covered in Training Materials?
Comprehensive Training Curriculum Checklist
Module 1: Understanding Food Allergies (30 minutes)
- What are food allergies vs. intolerances
- The nine major allergens and why they matter
- Symptoms of allergic reactions (mild to severe anaphylaxis)
- Why restaurant meals pose unique risks
- Statistics on food allergy prevalence in California
Module 2: SB68 Legal Requirements (20 minutes)
- Overview of the law and who it applies to
- Effective date and penalties for non-compliance
- How your restaurant discloses allergen information
- Employee responsibilities under the law
Module 3: Menu-Specific Allergen Content (45 minutes)
- Detailed review of which items contain which allergens
- Hidden allergen sources specific to your recipes
- How modifications affect allergen content
- Using allergen reference materials and tools
Module 4: Customer Communication (30 minutes)
- How to discuss allergens with confidence
- Sample scripts for common scenarios
- When to escalate to management
- Handling difficult situations empathetically
Module 5: Cross-Contamination Prevention (45 minutes for BOH, 20 minutes for FOH)
- What is cross-contact and why it's dangerous
- Handwashing and glove protocols
- Equipment sanitation procedures
- Special order preparation techniques
- Storage and handling best practices
Module 6: Emergency Response (20 minutes)
- Recognizing allergic reaction symptoms
- When to call 911
- How to support a customer experiencing a reaction
- Incident documentation procedures
Total training time: 3-4 hours for comprehensive initial training
Frequently Asked Questions
Q: What happens if a server gives incorrect allergen information to a customer?
A: The restaurant can face legal liability, fines under SB68, and potential lawsuits if the customer has an allergic reaction. This is why training emphasizes saying "I don't know, let me check" rather than guessing.
Q: Do servers need to memorize every allergen in every dish?
A: No. Servers should have quick reference tools (allergen charts, tablets, printed guides) accessible at all times. The goal is knowing where to find accurate information quickly, not memorizing everything.
Q: How should staff handle customers who are rude or dismissive about allergen questions?
A: Take all allergen inquiries seriously regardless of customer tone. Use calm, professional language: "I understand this may seem excessive, but we take allergen safety very seriously to protect our guests. Let me verify this information for you."
Q: What if a cook accidentally uses the wrong ingredient in an allergy-special order?
A: Immediately alert the manager, discard the dish, and prepare a new one correctly. Never serve food if there's any doubt about allergen contamination. The customer must be notified if food has already been served.
Q: Can restaurants fire employees who repeatedly make allergen mistakes?
A: Yes. Allergen handling is a critical job function. Repeated failures to follow protocols endanger customers and expose the restaurant to legal liability. However, employers should provide adequate training and support before resorting to termination.