In an effort to fend off legislation prompted by last year's disastrous chemical leak in Bhopal, India, the Environmental Protection Agency is drafting a list of chemicals that could pose acute health hazards if accidentally released into the air.

But the idea has so far drawn a round of raspberries from state air-pollution officials, who tend to see the proposed list as a way to put the monkey on their backs.

Nor has the list found many friends among environmental groups and labor unions, who contend that it not only excludes far too many dangerous chemicals but also doesn't require anybody to do anything about the chemicals that are on the list.

The list, which is expected to contain the names of 70 to 100 chemicals when it is released this month, will be coupled with a set of guidelines to encourage "community awareness" of airborne chemical hazards. The EPA believes the package will help state officials design emergency evacuation plans and "right-to-know" programs for local communities.

The guidelines have left state officials unimpressed, to say the least. "They intend to issue a list and then say 'here are some helpful hints to get yourself out of there when the thing goes off,' " said Mary Lyndon, an attorney for the state of New York.

"States need federal leadership and they need money," she said. "And the agency in charge of enforcing the law is saying 'the Garden Club and the Red Cross and the retirees should get in touch with the mayor.' "

Critics contend that the package is little more than "window dressing" designed to head off legislation that would require the EPA to keep far more comprehensive lists of hazardous substances and take regulatory action against them.

In the Senate, for example, Sen. Frank R. Lautenberg (D-N.J.) succeeded in adding a hazardous substances inventory to a bill to renew the "Superfund" toxic-waste law. Similar provisions were rejected in the House Superfund bill, but some lawmakers have vowed to force the issue again on the floor.

By contrast, the EPA list would be limited to substances that are immediately dangerous or lethal. Such criteria would probably have excluded aldicarb oxime, which sent more than 100 residents of Institute, W.Va., to the hospital when it leaked from a Union Carbide Corp. plant last month.

According to Bob Michaels, a scientist with the Natural Resources Defense Council, the agency also intends to exclude substances suspected of chronic effects, such as cancer and birth defects. The byproducts of burning would also be excluded, as would radioactive substances and chemicals used to manufacture food, drugs and cosmetics.

In written comments to the EPA, the council noted that "one of the most serious industrial accidents of all time, the disaster in Seveso, Italy, involved a chemical manufacturing facility that produced drugs."

According to state officials, even the most comprehensive list won't answer the question of where the dangerous chemicals are being produced or used. "People are going to look at that list and say 'where are these things?' and nobody knows where they are," Lyndon said.