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Who Speaks for the Leech?
On August 25 and 26, 2005, the Food and Drug Administration convened a meeting of its General and Plastic Surgery Devices Panel of the Medical Devices Advisory Committee. The FDA's Federal Register notice explains that the meeting agenda includes discussion and recommendations " on the classification of five preamendments medical devices: bone wax, medical maggots, medicinal leeches, tissue expander, and wound dressing with a drug." (emphasis added).

Uhhh....maggots and leaches? Yes, gentle reader, the FDA is planning to regulate the medical use of maggots and leeches, putting these humble living creatures in the legal category of medical devices. After lengthy, in-depth research (one Google search) Winston learned that microsurgeons now often use leeches to drain excess blood during transplant or re-attachment surgery. Doctors use maggots to clean festering wounds that fail to heal (a frequent problem among diabetics). Leeches drink blood, and maggots are very good at eating dead but not living flesh. In fact, that is about all they eat.

The FDA has not regulated maggots and leeches before, and the Agency feels the time has come. The Agency's Federal Register notice requested public written comment on how best to regulate leeches and maggots. Public comment was allowed at the meeting. The Comments made and received were not available at the time Winston had to submit this column. Be assured, however, that Winston will continue to dog this emerging regulatory issue because he has a concern that has not yet been addressed by anyone.

With apologies to Dr. Seuss: who speaks for the leeches and maggots in this matter? They save human lives; yet they have no voice in the matter. They have no trade association or NGOs, and no K-Street lobbyists represent them. Are leeches and maggots to be denied the rights Winston has, thanks to organizations like PETA ? Actually, Winston's PETA friends complain bitterly to Winston that he has no rights, but at least he has someone complaining about it.

Winston hopes this column will inspire the creation of leech and maggot watchdog groups, NGOs who will tirelessly work to ensure equal rights for the lovely leech and the magnificent maggot.

Winston already has suggested acronyms for them. How about NLDC (National Leech Defense Council) or MDF (Maggot Defense Fund)? Winston prefers PETL (People for the Ethical Treatment of Leeches), and PETM (People for the Ethical Treatment of Maggots). They convey a softer image.

Winston is also working on appropriate logos, but it is hard to make leeches and maggots look cute.

  • Click for FDA leech and maggot Federal Register notice .

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