The Reagan administration, hoping to counter criticism of its record in appointing women and minorities, is preparing an analysis that White House personnel director E. Pendleton James says will show this administration ahead of Jimmy Carter's in placing women and Hispanics in high-level jobs.

But James acknowleged in an interview yesterday that the figures will not be so favorable for blacks, at least not at this point. The analysis is being prepared for release Thursday, the 100-day mark for the administration.

The Carter administration was proud of its record in seeking out and hiring women and minorities, and James said yesterday that he, too, was impressed when he looked at the figures the outgoing administration had left in a White House computer.

"I thought, my God, how am I going to match that?" he said.

But James contended that the figures were misleading. "Jimmy Carter loaded boards and commissions with women and Hispanics and that's where they were getting those impressive figures," he said.

He indicated that the Reagan White House is placing women and Hispanics in positions of greater authority, and is confident that even the raw numbers "will look better" than those of the Carter administration at the same point in its term. As far as blacks are concerned, he said, "We will come up on the black count."

The personnel office's attempt to counter what James called a "perception" of failure in the hiring of women and minorities also comes at a time when the administration that pledged to "hit the ground running" is taking some heat for the leisurely pace of its appointments.

The White House has repeatedly excused the personnel logjam by saying that the process has been slowed by security clearances and the conflict-of-interest checks required by the Ethics in Government Act of 1978. The act is being found so onerous that the Reagan administration -- the first to have to deal with it during a transition -- may attempt to get it changed, according to White House counsel Fred Fielding.

The administration has complained from the early days of the transition that the ethics law, passed in what James called the "Watergate hysteria" period, was serving to keep qualified and interested candidates from taking government posts.

The act is under "very serious review," Fielding said yesterday. "We're trying to take a very good look at it to see if it has caused a problem serious enough to warrant legislative proposals."

Even so, President Reagan was, as of mid-April, only slightly behind the record of the Carter and Nixon administrations in formal nominations for key departmental slots, though he was well behind in nominations to independent and regulatory agencies.

By April 15, Reagan had formally nominated 91 persons to fill the nearly 250 Cabinet services, that are subject to Senate confirmation. At the same point in 1977, Carter had forwarded 98 formal nominations to the Senate. President Nixon had sent over 97 by April 15, 1969.

But the Reagan administration had, by April 15, forwarded just 15 nominations for independent agencies, of more than 170 the Senate will have to consider. At the same point in their presidencies, Carter and Nixon each had submitted 38 such nominations.

The Reagan administration also is behind in nominations to key civilian slots in the departments of the armed services, having sent over by April 15 only the nominations for the three secretary jobs. Nixon had filled 16 jobs in the services by mid-April 1969, and Carter had filled seven.

The Reagan White House also had nominated fewer than half the number of ambassadors Jimmy Carter and Richard Nixon had appointed by trhe same point in their presidencies. That, James said, is deliberate. "We have elected to go slow as a strategy," he said.

But James insisted that the formal nomination figures don't tell the full story. More than 70 nominations that will require Senate confirmation are pending at the White House, he said, and the majority of those await security clearances.

Meanwhile, nominations have been piling up behind another logjam on the Hill, where political family fights have kept dozens of nominations bottles up in the Senate. Of the 91 Cabinet and sub-Cabinet nominations sent to it by Reagan, the Senate had confirmed only 58 by April 15. Eighty-two of Carter's nominations, and 88 of Nixon's, had been confirmed by that point.

Some nominations approved by Reagan are still hanging fire in the White House, waiting for congressional liaison Max Friedersdorf to smooth their way through the offices of senators who had their own deeply held convictions of who should hold the job.

But in the presidential appointments process, the only deeply-held convictions that really count are Reagan's, as evidenced earlier this week when a key State Department position and the directorship of the Arms Control and Disarmament Agency were filled with persons of other than key senators' choosing.

"In many cases we go against the wishes of congressmen," James said. "I am just trying to staff this presidency with the best we can."