To quote the IFC committee, “the purpose of performance-based design criteria is to promote innovative, flexible and responsive solutions that optimize the expenditure and consumption of resources while preserving social and economic value.” Section 5001.3 Performance-Based Design Alternative is intended to be compatible with EPA’s RMP and OSHA’s PSM requirements, so it would reduce the burden on businesses in having to comply with duplicative or conflicting local and federal regulations. Based on the fact that “performance-based approaches” are already in widespread use in chemical storage and handling facilities, the topic of hazardous materials regulation stands out as an excellent place to start phasing performance-based concepts into the code. While a casual glance through the text of Section 5001.3 might lead one to conclude that the proposed section represents a massive loophole for the industry to jump through to avoid compliance with the code’s prescriptive requirements, a closer investigation will reveal that this is not the case.