Executives of CBS must be howling with laughter over the "petty cash fund" penalty the Federal Communications Commission levied against the network for Janet Jackson's "flash dance" during this year's Super Bowl halftime show.

The FCC could have accomplished as much via a strong verbal reprimand and a stern warning to other broadcasters. A $550,000 penalty for a multibillion-dollar enterprise - especially when that penalty is distributed among 20 CBS-owned television stations - amounts to no real penalty at all.

If decency-on-the-airwaves laws are going to exist - and there are strong differences of opinion on how far guidelines and enforcement should extend due to the constitutional free-speech guarantee - they ought to have the teeth of realistic penalties. The FCC could have sent a much firmer financial message by also fining CBS' more than 200 affiliate stations that also aired the halftime show but are not owned by the network's parent company, Viacom Inc.

Failure to send a stronger message in regard to the incident in question, in which the singer's right breast was briefly exposed to the millions of viewers, young and old, who were watching the telecast, lessens the impact of FCC chairman Michael Powell's statement likening the happening to a "stunt more fitting of a burlesque show."

Actually, the individual fines of $27,500, adding up to the $550,000 figure, was the maximum that could have been imposed for indecency. For fines to have an impact, they must represent more of a bite than parting with pocket change, and parting with petty cash is all this one does for the stations in question.

A one-minute advertising message during the Super Bowl costs much more than the "penalty burden" CBS and its stations were made to endure.

In addition to extending the penalty beyond the 20 CBS-owned stations, FCC officials should have promised an effort on behalf of having penalties beefed up to a more realistic level.

The Super Bowl incident was outside the realm of the argument that if viewers suspected that something would be aired that they might find offensive, they could have opted to watch another channel. The Super Bowl halftime show is supposed to be a production suitable for people of all ages, but the 2004 Super Bowl show, thanks to Jackson, wasn't.

While that wasn't the direct fault of CBS, by virtue of having the event telecast on its network and reaping the strong viewer ratings and income that accompany this premier sporting event, it was ultimately responsible for the content of the show and must shoulder blame.

A CBS statement said the network was reviewing its options in terms of responding to the ruling. The company has 30 days to ask for reconsideration and provide an explanation as to why the network should not be held liable.

Instead of accepting the penalty and considering itself lucky, and moving ahead, hopefully on a positive course, the network, through its statement, raised troubling questions about its attitude in regard to the Jackson incident.

The statement says, "We continue to believe that nothing in the Super Bowl broadcast violated indecency laws." That attitude ignores the spirit of federal law that bars radio and noncable television stations from airing, between 6 a.m. and 10 p.m. - hours when children are more apt to be watching television - references to sexual or excretory functions.

CBS projects its image as family oriented, and the network claims its own investigation of the incident produced no evidence that anyone within the company had advance knowledge about what was to occur. However, the network obviously didn't impress upon those in charge of the halftime show strongly enough the decency guidelines about which the network must be constantly vigilant.

Therefore, CBS must share a significant amount of the blame for Jackson's antic - as unpalatable and as unfair as that might seem to network executives.

The Super Bowl, World Series and any such family event must remain just that.

- J.R.K.