In his first public appearance in many weeks, National Endowment for the Arts Chairman John Frohnmayer yesterday said some art may be too highly confrontational or offensive to be exhibited in very public places and that such art "would not be appropriate for public funding."

As an example, Frohnmayer said that "a photograph ... of Holocaust victims might be inappropriate for display in the entrance of a museum where all would have to confront it, whether they chose to or not." Such a picture "would be appropriate in a show which was properly labeled and hung so that only those who chose to confront the photographs would be required to do so," he said.

Frohnmayer offered this and other views that seemed to be intended as a response to the concerns of endowment critics in testimony submitted to a commission assembled to study the embattled agency and its procedures. While the NEA chairman maintained his opposition to proposed legislation restricting the content of federally funded art, he said he could accept a law imposing penalties on NEA grant recipients who are subsequently convicted on obscenity charges. Some NEA supporters in the House are developing such proposals, but many in Congress appear to favor more explicit restrictions on the type of art that may be funded.

Frohnmayer said a legislative restriction on the content of NEA-funded art is "a blunt instrument" that might not achieve its goal. Instead, he said, evaluations of grants must be made on a case-by-case basis. He emphasized that language in the original act creating the endowment instructs the NEA chairman and council to make the arts accessible to the public and to "encourage public understanding and appreciation of the arts."

"We haven't paid enough attention to some of these other criteria, particularly of making the arts accessible ... of really being a bridge," he said. Frohnmayer said the endowment must consider more than artistic quality when awarding grants. "We cannot look strictly at artistic excellence in a vacuum, but we have to look at how it's going to play in an audience that we are charged with serving, which is the people," he said.

If a given project is "so offensive that it simply leads to confrontation and solidification of positions ... then in my view that would not be appropriate for public funding," he said.

Under questioning by commission members, Frohnmayer declined to draw a distinction between the type of art that should get government money as opposed to art that is privately supported. But he said standards should be applied to "the time, place and presentation" of both private and public art.

Frohnmayer touched on his decision in late June to reject four potentially controversial grants for performance artists. Saying he had the support of the NEA's advisory council, he added, "I will not comment on the specific reasons for the council's decision because it is the agency's policy not to do so and the matter is currently under appeal and perhaps litigation."

The rejection of the grants is likely to be a topic of lively discussion when the council meets in Washington this weekend. Frohnmayer also said he will ask the council to reconsider a recommendation that he reject two grants to Philadelphia's Institute of Contemporary Art. That organization helped spark the current controversy over the NEA when it used a grant to assemble an exhibit of Robert Mapplethorpe photographs. But Frohnmayer said he thinks "the discussion was inadequate and the information incomplete" when the council urged him in May to kill two of three proposed grants to the gallery.

While the chairman has only rarely reversed recommendations with respect to grants, Frohnmayer said it should not "be deemed to be a sacrilege if the council or chairman disagrees with a panel."