THOUSANDS OF OLDER Americans could freeze to death this winter.

A pamphlet called "Accidental Hypothermia in Older Adults," which has been submitted to the government for publication, would help prevent this dreadful outcome. But it hasn't been published yet, and if things continue the way they are going, it may not be out before the first crocuses begin to shine through the snow.

Government is a great glacier, always. But its natural tendencies are, in this case, stiffened by a freeze on government publications that has been decreed by budget director David Stockman.

Hypothermia is an insidious, Trojan horse kind of deadly affliction. The victims do not know what is happening; neither do the people who visit or take care of them. The first symptom is confusion, and there are others, like shivering, cold and stiff muscles, puffy face and forgetfulness. The author of "Accidental Hypothermia," W. Moulton Avery, tells, in clear language and large type, what they are and what to do about them.

He also gives practical suggestions on how to forestall their occurrence -- by keeping "toasty warm" at all times. Example: "Wear a hat and scarf to insulate your head and neck." And "cotton is rotten" for winter wear.

Avery, 33, is the head of the privately funded Center for Environmental Physiology and devotes full time to the study and prevention of hypothermia. He prepared his pamphlet for the North Carolina Senior Citizens' Federation. It is the only one of its kind. Thousands of government pamphlets are redundant or frivolous; his, obviously, is neither.

In the introduction, he states the urgency of the problem:

"Thousands upon thousands (of older adults) are stricken each winter and die quietly in their own homes, the victims of neglect, inflation and rising fuel costs which they are unable to pay."

He boldly states that the government owes its old more than survival:

"Comfort is an equally important consideration. Far too many of our nation's older adults are miserably cold in their own homes, and this is an unacceptable situation. They have a right to expect more from the society to which they have contributed so many years, and we have an obligation to work to end their suffering."

Most of the bureaucrats in the Reagan administration warmly agree. A task force made up of representatives of Health and Human Services, Action and the Department of Energy is doing its best to see that this life- saving manual gets into print and around the country -- to public libraries, churches, supermarkets, fuel assistance offices and senior citizens' centers.

But it is not so easy. It never is in government. They have to add a chapter on heat- stroke, which took many lives in the South last summer, to give it a more national flavor.

And due to the Stockman freeze, they have, moreover, to draw up memos, hold strategy sessions and compose legal position papers in order to get a warm smile from OMB.

"All this nuttiness added on," is how one bureaucrat, with an understandable passion for anonymity, puts it.

The Stockman guidelines, set forth in Order 81-16, state that, to be considered for exemption, publications must be held not only to a standard of "providing essential services" but also comply with "mandatory provisions of law." The second condition requires government lawyers to search the books to find something that says you will not break the law if you help save lives.

The question of why these departments did not start preparing for action before the first snow -- much of the Midwest is below freezing and New England is blanketed -- is one that no one can answer. The Public Health Service somehow never got around to it. A big government conference on hypothermia is scheduled for February, which will, of course, be much too late for a lot of old people who are huddled over their kitchen stoves, wearing their hats and scarves and wondering if they are going to make it through the day.

Fuel assistance can help, but in some states, the requirements are of a Draconian severity. In North Carolina, for instance, anyone with $1,000 in the bank is not eligible.

Says Avery, "They are saving the money for their funerals. Don't you think that's the bitterest irony? They're going to die sooner because they have just enough to bury themselves."

What may be a more bitter irony is that the cost of printing the hypothermia manual probably comes to $50,000, which is not a big ticket item, even in the Reagan administration.

If the bureaucrats can assemble their papers and a case that will thaw Stockman, the pamphlet could be ready for distribution in early January.

One frustrated official said, "Why are we even discussing this Why isn't it being done, when it's so obvious it should be done?"