THE KIDNAPING 10 days ago of Lt. Col. William Higgins brought to a boil once more the frustrations many Americans feel about dealing with the crime of hostage-taking.

We genuinely want to do something to get our hostages out and deter future kidnapings. But what are our real options? One way to begin to answer this question is to look at how other countries respond to hostage-taking and then to ask whether those methods would be sensible -- or legal -- for the United States.

Because hostage-taking commands so much media attention, it looks like a bigger problem than it really is. In fact, in 1986, kidnapings and hostage-takings accounted for just 6 percent of all international terrorist incidents. Bombing, shooting and arson were the real threats. But knowing that hostage-taking is a minor statistical risk doesn't make it any easier to swallow the latest kidnaping or the plight of the eight other kidnaped Americans.

The Higgins kidnaping doesn't pose any new issues. It merely stirs up the old ones. Should we retaliate in kind against the terrorists or their sponsors? Is assassination a proper weapon? If not, what other choices do we have? As the following survey makes clear, different nations have tried various answers to these questions. Their sometimes hard-nosed tactics raise obvious moral and legal problems; the evidence also suggests that these tactics often don't work.

The Soviet approach. Four Soviet embassy officials were taken hostage in Beirut in September 1985. There was no discernible publicity in the Soviet Union. One hostage was killed, but a month later three hostages were released. The question is: How?

The story on the street in Beirut is that in the period between the taking of the hostages and their release, Soviet KGB agents identified the hostage-taking group as the Sunni Moslem Islamic Liberation Organization. The KGB supposedly then captured a member of that group, cut off his testicles and sent the body back to his friends as a warning of what would happen if they didn't release the hostages.

This gruesome story may simply be a bit of KGB propaganda, as some U.S. experts suspect. It is more likely that the Soviets turned up the heat on their Syrian clients and told them to get the Russian hostages out -- quick! Any dirty work that may have been done was probably the work of the Syrians, not the Soviets.

Whatever the case, the Soviets haven't been bothered by hostage-takers since then and have continued to operate relatively freely in West Beirut -- despite an ever-present terrorist threat that has driven most other diplomats into Christian East Beirut.

A tough Soviet response to the Beirut hostage inci-dent would be in line with other known Soviet reactions to terrorism. When a Soviet airliner was hijacked in the Soviet republic of Georgia several years ago, they stormed the aircraft on the ground -- killing passengers and hostage-takers alike until the incident was resolved.

Their political system, so different from ours, allows responses that would be unthinkable for the United States. In dealing with terrorist incidents, Soviet officials behave with no apparent need to consider the morality or legality of their tactics or the reactions of their own people and critics abroad.

The Lebanese approach. In Beirut, the traditional respone to hostage-taking has been tit-for-tat. If someone kidnaps a member of your family or religious group, you abduct a member of his -- and then try to arrange a trade. This hard-nosed approach sometimes works in the short run, but it generates a continuing chain of grievances. During the Lebanese civil war in 1975-76, this approach reached absurd dimensions, as opposing factions erected barricades throughout the city and took hostages by the hundreds.

When the hostage-trade approach fails, many Lebanese factions turn to rougher and less discriminate methods. They park a Mercedes Benz outside the house of their enemy, loaded with 100 pounds or so of plastic explosive, and wait for the dust to settle.

Some Lebanese privately suggest that the United States and Europe should adopt similar tactics: That is, go into Shiite Moslem areas of West Beirut, abduct members of hostage-taking families like the Mugnieh clan or the Moussavi family -- and negotiate a trade.

This approach is hardly a model for successful anti-terrorism policy. Most observers contend that such cut-throat tactics are part of Lebanon's problem -- not part of the solution.

The French approach. Their response is rooted in a centuries-old Gallic tolerance for dissenters. France has been a second home for political outcasts and exiles -- from Ho Chi Minh to the Ayatollah Khomeini. Most of the time, this French openness has been cost-free and a matter of pride to the French. But beginning with the Algerian revolution, when revolutionaries concluded that they could influence French policy by bombing Paris cafes, the French have had a terrorism problem.

During the 1980s, the French have used a range of unconventional approaches to terrorism. One method is to provide safe haven for terrorists -- even to such established villains as "Carlos the Jackal" and Syria's Rifaat Assad -- on the understanding that they will refrain from acts of violence inside French territory. (The Syrians follow a similar approach -- allowing terrorists to come and go relatively freely, so long as they don't foul the nest.)

The danger with this approach became clear in the case of the Basque terrorist group ETA. The French allowed ETA terrorists safe haven in Basque regions of France, even though they were wanted for terrorist bombings and other crimes across the border in Spain. The Spaniards protested loudly, but to no avail. Finally in 1984, a "private group" carried out a raid inside France and executed nine members of ETA who had been involved in bombings. The raid was a blunt message -- to the ETA terrorists and to the French authorities. Since then, cooperation between France and Spain has improved so remarkably that they may now have the ETA terrorists on the run.

In dealing with hostage-takers, the French have taken a pragmatic approach. They have sought on the one hand to placate the Iranians, who are the principal sponsors of the Hezbollah terrorists holding French hostages in Lebanon. To obtain the release of one hostage, the French promptly settled a claim with Iran that totalled more than $300 million. Moreover, there have been peristent indications, including some in the French press, that the French have been trying in several countries to arrange arms purchases for Iran.

At the same time, they have made independent approaches to Hezbollah. For example, they are reported to have offered some months ago through Lebanese intermediaries to release (or vacate the sentence of) convicted terrorist bomber Georges Ibrahim Abdullah in exchange for release of French hostages held by Hezbollah in Lebanon. The deal appears to have fallen through because of strong disagreement between French political leaders and law-enforcement officials. The latter appear to have won, and Abdullah is now serving a life term.

The Israeli approach. In the early 1970s, the Israelis established themselves as the role model for hard-nosed anti-terrorist operations. After the massacre of Israeli athletes at the Munich Olympics in 1972, they quietly went to war against the PLO Black September faction -- and assassinated nearly a dozen Black September terrorists. The Israeli-PLO "War of the Spooks" eventually wound down to a rough balance of terror.

Since then, the Israelis probably have lived more on reputation than actual successes in the anti-terrorism war. Their involvement in Lebanon, which peaked in 1982, brought them much international criticism and left them, if anything, less secure -- because of the additional grievances that were generated in the Sabra-Chatilla massacre and other operations.

The dilemma facing the Israelis is clear in their current struggle to contain activist opposition in the occupied West Bank and Gaza. To maintain control, they have decided that it is necessary to use live ammunition against stone-throwing youngsters. For some inexplicable reason, the Israeli riot police sometimes show up at street incidents in khaki shirts and soft hats -- unprotected by the defensive gear that riot police usually wear. The Israelis might be able to moderate their tactics in some confrontations if they were better protected. Unfortunately, the harsh tactics they are using are inevitably forcing them to ever-greater repressive measures to suppress an increasingly active Palestinian protest.

The American approach. By comparison with these other nations, the United States approach has been very cautious. Complaints about Ronald Reagan's Rambo-like pronouncements entirely miss the point that the United States hasn't used methods routinely practiced by some other nations. Nor should we.

Take the issue of assassination. During the 1980s, I have participated in numerous discussions within government and among counter-terrorism experts about whether we should change the existing executive order banning assassination. My conclusion; It would be counterproductive. We would adopt a highly controversial solution that would apply to only a very small element of international terrorism.

We have some historical experience to draw on. Back in the days when assassination wasn't formally prohibited, most senior U.S. government officials considered it unwise. Probably nobody was happier to see consideration of this option dropped than the clandestine services. For one thing, killing an individual didn't necessarily kill his movement. For another, in this kind of warfare, the world's democratic governments are at a severe disadvantage -- because they are all accountable to their own publics. That means, very simply, that assassination is not sustainable policy.

What we're left with is a constrained list of new options, or variations of old ones.

1) Shoot the terrorists. It has been suggested that we adopt a policy of shooting terrorists on sight whenever we catch them in the act of kidnaping or hostage taking. Police can shoot hostage-takers in America if they judge that the terrorist may injure hostages, bystanders or the police themselves. Unfortunately, that's next to impossible in places such as Lebanon where there is no effective local authority and the United States has no jurisdiction.

2) Kidnap the terrorists. Americans who use this term generally mean getting the terrorist into custody so that he can be prosecuted under American law. The trick is to bring the terrorist before a judge by means that don't "offend the sensibilities of the court." Officials must be scrupulously careful with this approach, as shown in the case of accused hijacker Fawaz Yunis. U.S. District Court Judge Barrington Parker last week threw out a Yunis confession on grounds of unnecessary roughness (both of the suspect's wrists had been broken). Parker didn't object to the FBI sting operation used to lure Yunis onto a yacht in the Mediterranean, and U.S. authorities can use that tactic on other terrorists.

3) Rescue the hostages. Shortly after Higgins' capture, President Reagan mused publicly about a rescue mission. Indeed, in the lawless conditions dominating much of Lebanon, doing it ourselves may be the only option for assuring a forceful response. To mount a rescue on our own, however, the United States would have to know precisely where all of the hostages are at the exact moment of any proposed raid, not in some general time frame. The available intelligence indicates that the hostages are moved around with some frequency. The chances of locating all of the hostages precisely at one time and of executing a simultaneous rescue of them are pretty slim.

4) Control our public responses. This means we must develop an open, restrained endurance of terrorist incidents so that we don't unwittingly help the terrorists. A government and public that are openly agitated and distressed concede to the terrorists significant control of the bargaining -- control that is difficult to retrieve. Terrell Arnold is a terrorism consultant to the State Department and private companies and the author of "The Violence Formula: Why People Lend Sympathy and Support to Terrorism."