Contrary to the reference in David Korn's Middle East Watch report that appeared in "Iraq Long Avoided Censure on Rights" {front page, Sept. 22}, U.S. criticism of Iraqi violations of human rights has not been limited to the Annual Country Reports on Human Rights.

Before, during and after the time covered by the Middle East Watch report, the U.S. government on many occasions raised its concerns with Iraqi officials in private discussions that dealt extensively with our findings of extra-legal executions, disappearances and torture, as well as other problems, such as the pervasive and brutal secret police apparatus. We also raised the issue forcefully in public, both in the human rights report and in other forums, including hard-hitting testimony by the principal deputy assistant secretary of the human rights bureau, Joshua Gilder, before the Senate Foreign Relations Committee on June 15.

That testimony accurately catalogued Iraq's numerous human rights abuses and discussed in detail the use of poison gas against the Iraqi Kurds. When it came to speaking out against the flagrant human rights violations of Saddam Hussein's regime, we didn't pull any punches, and the public record demonstrates as much.

I might also add that while Middle East Watch may gloss over the importance of the Annual Country Reports on Human Rights, that report, which covers the entire world, is generally acknowledged to be the most accurate, complete and comprehensive human rights report available. It is widely and intensively read by other governments and, it should be pointed out, greeted with some consternation by dictators around the world who often complain to us bitterly about our findings.

I can also say from almost a decade in the human rights field, it is one of the best means we have to effect changes in human rights practices in other nations.

RICHARD SCHIFTER Assistant Secretary For Human Rights and Humanitarian Affairs U.S. Department of State Washington