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I don't think so. The data matters, but the recs are pretty conservative in both cases, so it's a wash between trial and implant there.you got it backwards.
From a face validity standpoint, in a trial, a sterile lead going through skin and, admittedly, sticking out, which was sterilized and prepped then covered with tegaderm, is a low infection environment. It remains a relatively closed system in a good way, and there's in theory not that much opportunity for biofilm to develop and track infectious material up the leads.
In an implant, you have a midline and flank incision which was exposed to OR air, mucked around with fingers and instruments, and then sealed up, creating a closed system in a bad way. There is plenty of opportunity for biofilm to form, seroma formation and possible static fluid, and a larger length of incision (compared to puncture) in an implant.
The potential harms of infection in an implant are severe infection sequelae, harms of re-operation for hardware removal, loss of therapy, and need for resurgery to reimplant. Postop abx for implant makes way more sense at every level compared to trial.
IIRC surgical literature implies that most gram positive bacterial ingress happens at the time of incision (or second incision, something like that).