Prattling facetiously in the course of her semi-gaudy concert film "Divine Madness," opening today at fearless area theaters, Bette Midler favors the audience with the following observation about Queen Elizabeth: "My dears, she is the whitest woman in the whole world!"

An honest mistake, but Midler may owe Her Majesty an apology. With the advent of the fall movie season, the outstanding candidate for this dubious superlative is a lady from the world of fiction: Beth Jarrett, the monstrously aloof maternal villain and whipping girl of "Ordinary People."

Nevertheless, the Queen Elizabeth joke remains a fair sample of Midler's comic patter at its wittiest, a level often abandoned in favor of the relentlessly bawdy and offensive in "Divine Madness." It preserves 95 presumably definitive minutes of wailing and clowning from her erstwhile Broadway show, as refurbished for the cameras and recorded at three special performances last spring at the Pasadena Civic Auditorium.

The filming was supervised by Michael Ritchie, a Midler fan best known for his direction of "Downhill Racer," "The Candidate," "Smile," "The Bad News Bears" and "Semi-Tough." (The charitable will forget his last credit, "The Island.") A noted cinematographer, William Fraker, supervised the lighting, and 10 cameramen cranked away once the show began, accumulating about 90 hours of footage for Ritchie and the editors to play with.

"This is the time capsule version of my show, so I guess I better do everything I know," Midler remarks at one point. What she seems to know best are burlesque jokes -- she does extended comedy routines in her own voice, which is a little reminiscent of Joan Rivers', plus impressions of Sophie Tucker and an apocryphal lowbrow lounge entertainer called Delores DeLago -- and torch songs culminating in mock orgasm and campy production numbers, backed by a close-harmony trio called the Harlettes. What she should have left on the cutting room floor is a would-be wistful mime number which finds her portraying an old rummy on a park bench in a kingdom of dry ice.

I gather that a few things regarded as indispensable by fans may have been lost in the compilation. For example, "Friends" didn't make the song cut, although "Big Noise From Winnetka," "Boogie Woogie Bugle Boy," "Leader of the Pack," "Stay With Me" and "I Shall Be Released," the finale, remain prominently featured.

Midler was struggling to fight off bronchitis while the shooting was in progress, and Ritchie is convinced that the extra raspiness and exhaustion in her voice made the renditions of the rock songs even more forceful.It's the kind of thing a director would prefer, but I'm not so sure. That sheer raspy belting is gutty all right, but I'm not convinced it's more gratifying and expressive than the crisp articulation on "Boogie Woogie Bugle Boy," whose lyric invention and charm refuse to date.

Midler seems a curiously mixed, ambivalent performer to an occasional, nonpartisan spectator like myself. The most appealing thing about her is an authentic comedienne's spontaneity and lack of vanity. You feel as if she wouldn't spare herself to take advantage of any comic opportunity. The best example in "Divine Madness" is the moment when she suddenly becomes aware of one of the all-too-human little flaws in her own physiognomy -- flabby underarms -- and begins twanging that loose flesh as if she were playing a dulcimer.

On the other hand, she seems to cultivate an indiscriminate taste in lewd material, cherishing the brutal and obvious as much as the playful or subtle. The accumulated vulgarity of her act begins to seem exhausting and oppressive, and every so often one gets the reassuring impression that it weighs a bit heavily on the performer. She's evidently established a familiarity with her public that has certain drawbacks, as one begins to perceive when she resists requests to strip or repeat certain jokes ("The taco joke? This is a bunch of scumbags . . .I know just how far I can go with the American public, kids") and vents the occasional hostility ("Darling! What a high-pitched voice you have").

The audiences entreating her remain in shadow, often vociferous but indiscernible. According to Ritchie, he deliberately kept the house dark and downplayed the crowd scenes in order to concentrate on the performer and to try to persuade the film audience that it is part of that original theatrical audience. Maybe and maybe not. There's a raw side to Midler's rapport with her public that seems to demand concealment.