The practices listed by Jimmie Marshall, chief information officer of the Hong Kong Economic and Trade Office in New York, in defense of the screening procedure for Vietnamese boat people in Hong Kong {letter, Aug. 25} are still lacking.

The procedure that Hong Kong has used since June of 1988 has, indeed, been seriously flawed. Based on a recent mission to Asia in May of this year, we remain concerned about the determination procedures in Hong Kong. Even a much-heralded decision last April by the colony's Refugee Status Review Board to give individualized reasons for negative decisions has not yet been put into practice. No provision has yet been made for particularized legal counseling and assistance to the boat people facing screening. While the approval rate for refugees in Hong Kong is somewhat greater in recent months, it is difficult to tell whether the increased rate is due to the screening or to other factors like unusual characteristics in the case-load adjudicated. The refugee status recognition rate still may not reflect the population of genuine refugees in need of protection in Hong Kong.

The office of United Nations High Commissioner for Refugees, of course, can provide something of a safeguard by using its mandate power to resettle refugees, a prerogative that has been used infrequently in recent months. Our concern is that over time, given limits on resources, UNHCR will be unable to guarantee on a sustained basis that genuine refugees are not at risk of forced return from Hong Kong to Vietnam. Compulsory return, therefore, should not take place until certifiably reliable and fair screening and review procedures have been achieved in Hong Kong.

ARTHUR C. HELTON Director, Refugee Project Lawyers Committee for Human Rights New York City