"I don't know of any administration that in the first 16 months that it was here placed as many women--certainly not the last administration . . . in high positions, a great number of them requiring Senate confirmation," President Reagan said Wednesday night in the second straight news conference during which he's pointed with pride to his record on appointing women.

It's a claim that's not backed up by the numbers.

A list released yesterday by the White House showed 104 appointments of women to positions requiring Senate confirmation. More than 40 of those were to part-time jobs on advisory commissions and councils. Seventeen were to one such panel, the National Advisory Council on Women's Educational Programs, after the president fired all of the previous members, most of them women.

The administration's figures immediately drew fire from the National Women's Political Caucus (NWPC), which argued less with the statistics than with Reagan's contention that the women in his administration were in "high positions."

"The numbers are very close," executive director Gail Melich acknowledged. "Our complaint is with the level. They aren't power appointments. There's just no comparison. And they're often women's jobs: treasurer of the United States, director of the women's bureau. President Carter made substantive appointments."

In his first 16 months Carter named two female Cabinet secretaries: Patricia Roberts Harris, who headed the Housing and Urban Development Department (and later the Health and Human Services Department) and Juanita M. Kreps, who headed Commerce. Shirley M. Hufstedler later was named secretary of education. Reagan has appointed one female Cabinet member: U.N. Ambassador Jeane J. Kirkpatrick.

Reagan can take credit for naming the first female Supreme Court justice. There were no vacancies on the court during Carter's term. But at this point in his administration, Carter had nominated four women to be U.S. attorneys, two to be judges of the D.C. Superior Court and three to U.S. District Courts. Reagan has named two female U.S. attorneys and three U.S. District Court judges.

The NWPC noted, however, that Reagan has had the chance to fill 65 federal judgeships and has given three to women. During that same period Carter had 43 vacancies to fill, according to The Washington Post's calculation.

At the sub-Cabinet level Carter appointed 52 women to jobs requiring Senate confirmation in his first 16 months, according to The Post's research. These included the chairman of the Equal Employment Opportunity Commission, the head of the Community Services Administration, undersecretaries of state and treasury, the deputy administrator of the Environmental Protection Agency and deputy director of Action.

Reagan, by comparison, has nominated 41 women to sub-Cabinet jobs requiring confirmation, including the EPA administrator. At least two of these women were first named to their jobs by Carter or President Ford, and a third, the inspector general at NASA, had served as an IG at another agency in the Carter administration.

In addition, Reagan has not nominated a woman to any job at the Pentagon. At this point in the Carter administration there were two: the general counsel of the Defense Department and an assistant secretary (later undersecretary) of the Air Force.

The NWPC, counting full-time appointments requiring Senate confirmation, figures Reagan with 51 female appointments compared with Carter's 65. Women accounted for 7.5 percent of Reagan's appointments and 10.2 percent of Carter's, it said.

The breakdown becomes fuzzier when political appointments and appointments to non-career positions in the Senior Executive Service (SES) are added in. Reagan said his administration had named 314 women in all three categories in the first 16 months of his administration, compared with Carter's 289.

But the SES didn't exist in the first 16 months of Carter's administration. Pat Korten, a spokesman for the Office of Personnel Management, said Carter named 78 women to non-career SES jobs immediately after the service was created in July, 1979, moving up to a peak of 117 in the waning months of his administration. By comparison, he said, the Reagan administration had named 88 women to non-career SES jobs as of mid-May.

"We have a problem with strict comparability," Korten said, but added, "We're way ahead of where they were in terms of non-career SES." Korten could not provide a breakdown by sex of political, or schedule C, positions, and information released by the White House yesterday did not include the Carter figures.