IN THE ABSENCE OF GENERAL TREATMENT CRITERIA, IT IS DEBATABLE WHETHER TREATMENT OF JUVENILE DELINQUENTS CAN BE OTHER THAN A VAGUE HOPE OCCASIONALLY REALIZED. THE POSSIBILITY MUST BE FACED THAT TREATMENT MAY NOT BE EFFECTIVE OR ATTAINABLE FOR LARGE NUMBERS OF JUVENILES. IN FACING THIS POSSIBILITY, SOME ALTERNATIVES PRESENT THEMSELVES. ONE ALTERNATIVE WOULD PROVIDE FOR JUVENILES THE CONSTITUTIONAL STANDARDS NOW PRESENT IN CRIMINAL TRIALS FOR ADULTS. THIS LEADS TO THE DEVISING OF 'LEAST RESTRICTIVE ALTERNATIVES' IN CONFINING ANY JUVENILE DELINQUENT IN AN INSTITUTION. INSTEAD OF REHABILITATION, THE GOAL SHIFTS TO MINIMIZING HARM. REHABILITATION EFFORTS WOULD BE MINIMAL AT BEST UNDER THIS ALTERNATIVE. A SECOND ALTERNATIVE WOULD BE TO NARROW THE LIST OF JUVENILE OFFENSES SO THAT ONLY THE MOST RECALCITRANT YOUTH WOULD EVER BE CONFINED. THIS WOULD MEAN THAT LIMITED TREATMENT RESOURCES COULD BE CONCENTRATED. PERHAPS CONFINED JUVENILES WOULD BE RESTRICTED TO THOSE ALLEGED DANGEROUS, AND THIS WOULD REQUIRE SEPARATE PROCEDURAL SAFEGUARDS. CONFINED JUVENILES WOULD THEN BE REQUIRED TO BE PROVIDED WITH ADEQUATE TREATMENT, WHICH WOULD INCLUDE A HUMANE PSYCHOLOGICAL AND PHYSICAL ENVIRONMENT, A QUALIFIED STAFF IN SUFFICIENT NUMBERS, AND INDIVIDUALIZED TREATMENT PLANS. PROVIDING A CUSTODIAL TREATMENT MILIEU FOR ONLY THE MOST RECALCITRANT OR 'DANGEROUS' JUVENILE OFFENDERS IS URGED AS THE BEST ALTERNATIVE. REFERENCES ARE PROVIDED. (RCB)