One of the most important responsibilities ceded to a newspaper by its community is the editorial page role as independent and unwavering observer, adviser and, sometimes, critic.

Generally speaking, I think we do a pretty good job of it. We investigate issues, weigh the facts and urge conclusions or make judgments. And, if we do our jobs well, these daily pronouncements may frequently be unpopular.

We weather the criticism and make our observations in the name of societal health and the overall best interests of our community. Thanks to our efforts to shine the light of fact on established institutions, our communities benefit from ``sunshine'' or open-meetings laws, public-accountability processes and, hopefully, an overall reduction of institutional secrecy.

But while we (modestly, of course...) accept the thanks of our community for shouldering this ongoing public responsibility, we'd better take some time to look in the ``accountability mirror'' ourselves. It is not a pretty sight.

Today I am sad to report that, according to the News Inc. newsletter, there are still only 34 newspaper ombudsmen in the United States and two in all of Canada. This means representation of ombudsmen is just barely over 2.2 percent of the papers now publishing in the United States. News Inc., in its Nov. 24 edition, also notes that the 34 ombudsmen now toiling for (mostly) major newspapers represent ``a little more than 15 percent of the total U.S. daily circulation of about 59 million.''

These are terrible statistics for an industry that purports to believe that sunlight is the ultimate community vitamin and antiseptic.

If other major institutions in our communities seemed as indifferent to consumer complaints, we'd incite -- or at least encourage -- a chorus of criticism. I am hard pressed to think of major organizations that don't already provide easy, direct public access to an institutional insider with whom to register a complaint. Our department stores, utilities, police departments, cable television operators, large and small manufacturers and other service providers all have, and promote, access to an internal customer service representative. But many of the nation's newspapers don't.

Even the lone, long-distance truck driver usually has a complaint line noted on the rear of his vehicle. And, most recently, that last bastion of arrogant, bulletproof impenetrability -- the IRS -- has had its front door kicked open by the cacophony of consumer complaints.

So why not newspapers in many cases?

Is there no public interest in complaining about our performance? We all know better than that.

Are we so ``different'' to be above designating a senior person to track down answers for unhappy readers and publishing the results? I don't think so.

I know that many newspaper publishers today resist the concept of news councils (also advocated by me) because they are often populated with ``outsiders'' who purport to ``judge'' our news decisions and coverage.

Ombudsmen, though, are, by definition, insiders -- usually well respected journalists -- who know how a newspaper works and what it stands for. Far from simply public grammarians, they provide a readily accessible public face and voice to whom the public can turn. And, ideally, with regular weekly columns, provide a steady source of information -- and, occasionally, an institutional apology or example of well-earned newspaper humility to our readers.

What about the claim that the publisher or editor is the newspaper's ultimate ombudsman?

Baloney.

I don't know a single publisher or editor who personally can, or does, handle each and every question or complaint that comes in daily. Why, we aren't even able to print every letter of complaint -- or praise -- that we receive each day.

Do other critical institutions rely on their CEOs to handle all the details of all customer compliants? Of course not.

Doesn't the reader/consumer deserve a prompt and knowledgeable response to their concerns? Of course they do.

Because our industry is ``special'' there are many things we can't, or won't, do -- like alter our news product to please large advertisers.

But embracing the ombudsman concept is something we can do -- and should. For a newspaper too small to afford a full-time ombudsman, appoint someone to handle it part-time and publicize their assignment.

The ombudsman, or reader representative or public editor, is a position that is ideal for far more than just 36 newspapers in all of North America. The establishment of ombudsmen fits our quest to improve our standing and value in our community. The cost is minimal. And the payoff in opening the front door to our readers is huge. In my mind, there's no credible excuse for not embracing both the concept and the position. And quickly.

David Cox, is president and chief executive of Cowles Media Co. and chairman of the Newspaper Association of America (NAA). A similar essay in the January 1998 issue of Presstime was entitled ``Access Goes Two Ways.''