The wording "outside of transaction" irks me. Everything in a relational database is done within a transaction, the only question is whether it's the transaction you think it is, or some other.

I believe this is largely an API design problem. Many client APIs (especially ORMs) will start a transaction implicitly for you if you haven't explicitly specified your own, leading to problems like in the article.

Having implicit transactions is just wrong design, IMO. A better-designed API should make transactions very explicit and very visible in the code: if you want to execute a query, you must start a transaction yourself and then query on that transaction supplied as an actual parameter. Implicit transactions should be difficult-to-impossible. We - the programmers - should think about transactions just as we think about querying and manipulating data. Hiding from transactions in the name of "ergonomy" brings more harm than good.