NOW THAT THE administration has officially

returned ketchup to its proper status as a condiment and discovered that soybean curd is not everyone's idea of super lunch, where does that leave the school lunch program? Still in deep trouble in many areas. The program's real problem is not that the Agriculture Department issued some goofy regulations and then took them back. Its real problem is that it has lost $1 billion or so in federal aid.

Say this, anyhow, for the recently rescinded ketchup and tofu rules: they at least involved an honest recognition that declining federal aid means truly miserly lunches in many school districts. Relatively well-off districts may be willing and able to make up for the loss of federal aid. But in other areas it may well be half a glass of milk, half a piece of bread, a scoop of vegetables, a morsel of meat-- or nothing.

Office of Management and Budget Director David Stockman said on "Face the Nation" the other day that the dilemma had been caused by Congress' refusal to buy his plan for cutting back further on lunch subsidies for better-off students. This sounds sensible on its face, but as Congress discovered in its consideration of the issue, if students had to pay the full price of school lunches, most would head to the nearest fast-food outlet instead. Without their patronage, many programs could not operate at an efficient scale, and costs could go up instead of down.

Another approach would be to restore the lost federal aid and, as Sen. Gary Hart (D--Colo.) has suggested, finance it by a tiny cutback in the billions now spent through the tax system in financing business lunches and entertainment. If that's too radical for you, let us suggest another sort of heresy. Rather than stage a partial retreat from federal standards, why not give up on federal regulation of the school lunch program altogether?

This idea should certainly appeal to the administration. It reflects the general hands-off philosophy and lets the Reagan people off the hook with respect to the detailed consequences of this part of their budget program. But there's a practical case to be made for letting local school administrators decide how best to use dwindling federal aid to meet the needs of their particular school population.

A balanced and adequate diet is, without question, one of the most important contributors to healthy child development. Remember, however, that even the old federal regulations didn't guarantee that a nutritious meal would be served--let alone consumed--by every schoolchild. All they required was that certain minimum quantities of each broad food group be served. Whether the resulting meal built strong bodies or filled garbage cans depended primarily on the ingenuity and common sense of local school meal planners.

Leaving the choice of menus and clientele entirely up to local school administrators won't work perfectly. But neither will federal guidelines--especially if they have the effect of driving more schools out of the program entirely. In the case of something as tangible as school lunches, local school boards and parents are surely more effective watchdogs than federal monitors sifting through stacks of meal reports.

While we're perpetrating a heresy, let us also suggest that local school administrators use their new discretion to reconsider some of the dogma that has guided school lunch preparation over the years. Where, for instance, is it written that in order to be nutritious, a lunch has to be hot? We are, to be sure, only kitchen-chair nutritionists. But we're willing to bet that the average child will get a lot more nutrition from an offering of, say, a peanut butter sandwich on whole-grain bread, a glass of milk, a piece of fruit and a cookie than from what he or she can be persuaded to eat from that plateful or even half plateful of mushy vegetables, soggy potatoes and grayish meat.