The Office of Personnel Management's newly proposed regulations for the government's annual charity drive are under attack by advocacy groups for blacks, women and environmentalists, whose representatives fear they will have a hard time qualifying for the chance to solicit donations from federal workers.

The proposed regulations, according to these groups and others, will reduce the number and types of organizations that can join the charity drive and will shift control and distribution of collections in local communities to one group, expected to be the United Way in virtually all cases.

"It's a question of who gets in and how to divide up the money," said one critic of the regulations, which were announced this week by OPM Director Donald J. Devine and are set to be implemented in June or July.

Devine defended the regulations this week, saying the categories for participation had been broadened, not limited, and would provide more opportunities for advocacy groups. He did say, however, that some groups may have to affiliate with or form their own umbrella organizations in order to be eligible to join the fund-raising effort.

"If they put a little imagination into it, they'll be able to qualify," the OPM director said. His office said later that the complaints about the regulations reflected the groups' "paranoia" rather than the facts.

Payroll deductions to the Combined Federal Campaign raised an estimated $13.7 million here and $93 million nationwide last fall and constituted the largest charity solicitation drive in the country. It is for this reason that the struggle to participate in the collection process has repeatedly turned into what has been uncharitably dubbed the "charity wars."

The competition, at times, is fierce.

The president of the National Black United Fund, for example, says, "We will do whatever we have to do to make sure the . . . BUF is represented in this tremendous marketplace." The New York-based group, which is not related to the United Way-affiliated United Black Fund here, was admitted to the campaign for the first time last year after a court battle, and now its president, Walter Bremond, worries that it will again be barred.

Upon entry last year, NBUF was allowed to join 56 of the campaign's 550 local drives. With 28 reporting so far, it has raised about $104,000, a drop in the bucket compared to the approximately $66 million United Way raised last year for its 37,000 local community service member agencies. Bremond's group had hoped for a more generous response in future drives.

Under the new guidelines, Bremond said, "It doesn't look good" for NBUF's participation in the campaign. His concern, he says, is the threat to groups involved in nontraditional charity projects. He believes his group, for example, fills a unique advocacy role in black communities by focusing "on the causes and solutions to poverty, not the consequences."

The NBUF, the Women's Legal Defense Fund here and other groups are worried that two provisions in the new regulations--requirements that they provide direct charity services and that they be organized in all or most of the states--will bar them from the campaign or choke them in red tape. They argue that advocacy work for blacks, women and other special constituencies is as valid as direct charity services and gives them a national scope beyond their geographical bases of operation, which are limited.

The expanded role of United Way--which critics said would attain the status of Principal Combined Fund Organization and therefore a controlling voice in nearly all of the campaign's community drives--is another concern.

Some national and local fund-raising groups complain it amounts to a conflict of interest for the nation's best-known and leading charity solicitation organization to take charge of conducting the campaign and distributing the much coveted "undesignated" funds that accumulate when donors don't earmark their contributions for specific charities.

"Who are they to say?" argues George Lewis, executive director of the 27-member National Health Agencies, which represents groups like the American Cancer Society, Arthritis Foundation and the American Heart Association.

United Way spokesman Steve Delfin, acknowledging his group's expanded role in most campaign drives, said all groups who now participate will get a portion of the undesignated funds "at least equal to the share" they received under the old OPM regulations.

"We've pledged we're going to be fair and equitable," said Delfin, adding that all eligibility decisions will rest with OPM and federal officials, not the United Way. He said United Way, which receives about 72 percent of the campaign's total collections, would "hopefully absorb a lot of these groups" to help them qualify for participation.

"We're not trying to lock people out, we're trying to get them to work with us," Delfin said.

Devine said Federal Coordinating Committees composed of federal employes would monitor fund-raising and distribution and ensure that the government rather than charities runs the campaign.

But a National Health Agencies spokeswoman said the committees are composed of volunteers, not fund-raising experts, and will offer little meaningful campaign management. Further, she said, Devine's proposed regulations would probably triple her group's charity solicitation costs.

OPM's regulations encourage donors to make contributions to specific organizations, a change applauded by groups that hope this will cut down on the fighting over undesignated funds. But these same groups want the campaign kept open to more organizations, arguing that the growth in the number of participating groups over the past few years has encouraged more contributions.