Transportation Secretary Elizabeth Hanford Dole says her first priority is safety and she misses few opportunities to tell the public and Congress that she is out front in making virtually all forms of transportation safer. But her critics have begun to ask whether her campaign is all press release and little action.

The issues she has dealt with during her 29 months as transportation secretary are complex, sometimes strain technology and sometimes require enormous expenditures for marginal gain.

Effectiveness is difficult to measure, but the issue has emerged as the key question about her tenure at the department.

Rep. Norman Y. Mineta (D-Calif.), once a Republican and rarely a fire-breathing partisan, is unusually blunt.

"I have become increasingly disappointed with her ability to follow through on her rhetoric with concerted actions," he said. "She continues to talk about her leadership in the safety field, but frankly I'm more frustrated by her lack of leadership."

Jim Burnett, Republican chairman of the National Transportation Safety Board, has regularly charged that the Federal Aviation Administration and the Federal Railroad Administration -- both in Dole's department -- have moved too slowly on such important safety issues as rules attacking the long-term problem of drug and alcohol abuse by railroad employes, particularly engineers.

Consumer and safety advocate Ralph Nader tries to be understanding.

"I would call her a weak, ineffectual secretary of transportation with good, basic instincts that would require a progressive president to nurture . . . ," he said.

"She does not like conflict or confrontations. When you're dealing with ideologues, you either have to go head-on or they roll over you."

When asked if she is more pragmatist than ideologue, Dole said, "Probably . . . . I feel I have strong feelings and strong views, but the goal is to reach the goal, and there are times when you're going to have to reflect other persons' views and thoughts and try to reach a compromise . . . ."

Dole, a Republican star tabbed as a potential vice-presidential nominee, is a complicated, proud, diligent person who packages it all in a pleasant smile and a disarmingly warm North Carolina accent.

She is sought-after as a political campaigner, and works for many of her party's candidates as well as for the 1986 reelection of Sen. Robert J. Dole (R-Kan.) -- her husband the majority leader, and the other half of "The Bob and Elizabeth Show."

"Obviously, I want to see him reelected," she says.

Last week she took what has become a typical Elizabeth Dole trip. Monday night, July 15, she dropped in at a Bob Dole for Senate affair in Lawrence, Kan. On Tuesday, in Kansas City, she told the National Conference on Highway/Rail Safety about a new demonstration program to reduce accidents at railroad crossings -- after alcohol, the nation's second most deadly hazard to automobiles and their occupants. No new federal money is programed.

Her department is essentially a collection of regulatory agencies, which deal with such varied concerns as buoys in Puget Sound, the air traffic control system, complaints about lost baggage, standards for building bridges and how many times railroad tank cars should roll over before they split open.

Every regulatory action crosses Dole's desk, and she reads what crosses her desk.

The charge, leveled both within her department and from its many constituencies, is that regulations, reports, even press releases, take too long for clearance once they reach the secretary's office.

Secondary complaints are that she doesn't delegate enough and that she is difficult to reach.

Mineta, chairman of the House Public Works and Transportation subcommittee on aviation, is unhappy with the pace at which improved fire-safety rules have been moving through the Transportation Department

Burnett's campaign to root out drunken engineers predates Dole; a draft rule bounced around her department for more than two years before it found its way to the Office of Management and Budget, where it now resides.

Nader is angry because Dole did not directly order air bags into new automobiles, but chose a middle course.

"Things don't sit in here," Dole said. "I think it's important to check that one out. I would be concerned that that was not fair criticism. That just ain't true."

She calls air bags the "toughest public issue I have faced" and cites it as evidence that the department can move. The issue took 14 years to reach the Supreme Court, then was bounced back to her for resolution. She set a schedule for publishing a final regulation and came within two weeks of hitting it in July 1984.

Air bags or other "passive restraints" will be mandatory in all new autos after Sept. 1, 1989, unless states containing two-thirds of the U.S. population enact laws requiring the wearing of seat belts.

In the meantime, air bags are being sold by some manufacturers and the technology is moving forward. It is less than Nader wanted, but it may be more than might have been expected from this administration.

"For the first time, lives are being saved," Dole said. New York's new law requiring that seat belts be worn has resulted in a 27 percent drop in fatalities, she said. Thirteen other states have adopted seat-belt laws.

The FAA airplane fire-safety rules have a different history. Twenty-three people died in an on-board fire on an Air Canada flight that made an emergency landing in Cincinnati in June 1983. Soon thereafter, the FAA announced new fire-safety steps, including more smoke detectors, fire extinguishers, exit signals and fire-resistant or fire-retarding interior fabrics.

The proposals had been lying around the FAA for years, partly because the airline and aerospace industries resisted many of them, partly because there are no easy answers. Some of the proposals have been enacted, but most are still churning in the regulatory mill.

Dole, in a second interview, uncharacteristically volunteered this: "I said that overall I felt that things do move well up to our desk. I have to say that some of our FAA regulations would not be out without my getting in and prodding. It is frustrating, the process within the FAA . . . ."

There is a distrust between the FAA and the secretary's office that predates Dole, and it reached new levels after the June 14 hijacking of Trans World Airlines Flight 847 out of Athens.

The FAA's long understaffed and underfunded security office was ordered to churn out new proposals to improve airport and airline security and survey the world's airports to locate trouble spots.

Reporters were clamoring for details, but the FAA's press office was told to refer all questions to Dole's press shop, where knowledge about airplanes and airports is in short supply.

That may be part of Dole's obvious policy of never getting out in front of the White House, of being a team player. It was only after President Reagan announced his plans to combat terrorism on airplanes that Dole went public with her department's package of proposals.

Then she showed the kind of skills in using the media that are a must for modern politicians.

She flew to Montreal to address the International Civil Aviation Organization on airport security and passenger safety, and held a news conference, portions of which made all the networks.

A week later she appeared, on the same day, on NBC's "Today" show, the CBS "Morning News" and the PBS "MacNeil-Lehrer Report" and taped an appearance on CBS' "Nightwatch" -- again to talk about airport and airline security and do no harm to her reputation as the protector of safety.

Dole is unquestionably image-conscious. "She has a finely honed sense that tells her that power is perception, and she doesn't want anything to tarnish the perception," said a source who knows her well.

As for her political ambitions, Dole says only, "I am immersed in what I am doing and enjoying it thoroughly."

Those who work most closely with Dole are impressed with her skills and her willingness to work. Members of that relatively small group describe her as committed to public service and to safety and admire her grasp of issues.

But the farther one gets from Dole's office, the less lofty the opinion.

"Her work habits have isolated her a bit and she's very dependent on people around her," said a source. "She's not a first-class administrator . . . . My sense is the secretary is not comfortable with a lot of people around, not that she's afraid. She's not always confident of herself and has no reason not to be, because she is so bright and her instincts are so good."

When Dole applies her personal charm to a problem -- always after extensive preparation to guard against surprises -- she is formidable. Rep. James J. Florio (D-N.J.), chairman of the key House subcommittee handling Dole's proposed sale of federally owned Conrail to Norfolk Southern Corp., spent months complaining about Dole's process in choosing a buyer.

After a bit of partisanship by both Florio's and Dole's staffs about access to documents and hearing dates, Dole appeared before his committee. She was a hit, as she almost always is on Capitol Hill. Florio conceded, "As an individual, she makes a very good presentation . . . . Once the communications were opened, she has been very forthcoming."

Another time-consuming issue on Dole's platter is the legislation to transfer Washington National and Washington Dulles airports from federal control to a regional authority. She spends huge chunks of time lobbying for the transfers.

If she is preparing to testify on National Airport or Conrail, or a major regulation is on the agenda, those with other issues say they have trouble getting through to Dole, even if there is a fire.

"So many things are going on, you just can't take them serially, you have to do them in parallel," a department source said. "You can't hold up railroads while you deal with aviation or highways. It's an organizational problem."