You should still be able to use one of the various “standard” risk assessment approaches for this. There are various templates available if you don’t want to have to make one of your own – for example, a kind fellow IFSQN member shared one in this thread:https://www.ifsqn.co...plate-required/
Whilst I agree it looks like the risk will be fairly low, you can still go through the process of doing the risk assessment to determine if this is really the case. I'm not sure which Food Safety standard you’re working with, but consider e.g. the categories required by BRC:
Historical evidence of substitution/adulteration
Likely to be extremely limited given that you’re working with whole fruit. The only exception to this may be if you’re looking at specific varietals – e.g. with our Indian sources we’d be considering potential for Alphonso mango to be partially substituted for cheaper varieties like Totapuri, Kesar etc
You’d probably need to consider reviewing this section several times a year, as crop availability and pricing fluctuates before/during/after the crop season for many fruits. Obviously the separate question to this is, what would the impact of the economic factors actually be? e.g. If the price of oranges is high then is there a fruit that your suppliers could actually use to try to substitute it?
Ease of access to raw materials in the supply chain
You’ll need to decide how to characterise this. It’s relatively simple to walk into many farms, so at face value access is indeed easy. My experience of sourcing fruit in India has been that many of the growers for some types of fruit are smallholders where the boundaries etc aren't walled/fenced, so this makes it even easier still.
However, this should perhaps be considered in terms of whether this actually provides an opportunity to adulterate/substitute the raw material. It's not really the case that one can walk into an orange grove, steal the oranges and staple apples to the trees in their place!
Obviously there are a few cases of adulteration of whole fruits - e.g. the recent issue with needles in strawberries in Australia, oranges injected with Mercury in the late 1970s - but they’re thankfully rare and in general it’s more difficult to adulterate whole fruit than processed products. Neither of these examples are based on adulteration for economic gain so this type of risk may already be covered separately in your food defence / TACCP or similar.
If your supply chain involves collection points, local markets and similar then you’d want to document this too, as again this provide further potential points of access, but the actual opportunity is probably very low - it's therefore about showing that you've considered this.
Sophistication of routine testing
Again this one is likely to be relatively easy / low risk for you. Your routine testing for this is probably just visual inspection on receipt of fruit, and if it looks like e.g. an orange then it (probably) is an orange. Obviously you’ll potentially be doing other checks when fruit is delivered (Brix, acid, flavour, colour etc.) too, but these don’t really relate to authenticity in quite the same way, at least in this particular context.
The only bits I’d consider giving further attention to in this area are:
- Sampling frequency vs. lot size – it’s possible to hide one type of fruit in another if you’re receiving large volumes, e.g. would your intake process identify say 1000kg of oranges mixed in with 20000kg of mandarins? You'll need to consider if this is actually a significant risk.
- Any varietal or similar claims, and how easily these can be verified at this stage. This will depend on the specific nature of the fruits you’re processing – some are quite visually distinct (for example the main Indian mango varieties for processing tend to have different size/shape/colour) but this isn’t necessarily the case for all fruits, and as above you’d want to consider how much of this your sampling plan would identify, whether your colleagues doing the inspection have the relevant training to be able to identify these etc.
This area could perhaps be considered in conjunction with prerequisites in the form of your supplier approval and management program – if you know that certain growers only produce one type of fruit then it’s less likely that they’ll be mixing other types in.
Nature of the raw material:
As noted above, with whole fruit you can fairly readily conclude that the likelihood of adulteration is very low. The potential for substitution is a slightly more complex question if you’re doing anything with varietals – I’ve talked with many juice processors about this, and a number have decided that they can’t offer varietal products as they don’t feel able to genuinely verify that 100% of the incoming fruit is the claimed variety. Many of these cases are not a matter of trust/honesty, but one of the practicalities of their supply chains when very large quantities of fruit from large numbers of growers. Equally, I know of many who do produce single-variety and have a great deal of confidence in their systems/controls for this. Two of these are factories in India and their inspection controls combined with the management and knowledge of their supplier base are more than sufficient to ensure the claim is met.