The ASME Pressure Vessels for Human Occupancy codes and standards are engineering standards developed to provide a reliable design method for pressure vessel windows. This empirical method is based primarily on years of government-sponsored testing and development and does not directly use engineering theory. This empirical algorithm makes it challenging to revise without additional large-scale physical testing. The industries using the PVHO code need a way to incorporate advances in material science, manufacturing technology, and overall engineering advances without spending years in code case review. Verification & Validation techniques, coupled with stochastic Finite Element Analysis to address operational variables, can be the basis for a "design by analysis" method to complement existing testing requirements to produce a full engineering package consistent with other pressure vessel and pressure vessel component design. A design method sufficiently reliable for PVHO could be used in other applications.