Stair Lobbies in Flats

[Growler]

New build, small block of flats, single staircase condition (grd, 1st & 2nd floors), Three flats per floor, all have inner protected hallways with FD30(s) flat entrance doors which are accessed directly from each staircase landing i.e there are no lobbies. TD is irrelevant with no lobbies but would vary, with one floor within 4.5 metres and another exceeds but would be under 7.5. The building fits Approved Document B Section 2.21 for "small premises".
Whats the forums opinion should the staircase be lobbied or not.
My view is it should, at all levels including the top floor.
As there are more then two flats per floor Diagram 9b is ruled out, leaving Dia 9a to apply.
Further reference is made to lobbies in Approved Document at Section 4.34 (a) and states that lobbies can be excluded in small premises as defined  at 4.6(a) then to 3.33 (3.32), however the way I see it small premises in section 3.33 (3.23) is for buildings "other then flats" (flats having their own definition of small premises at section 2.21).
Am I reading it correctly or is anyone aware of a hidden paragraph in the Approved Document that says doors between the top of the stairs and the dwelling entrances can be omitted in such a building.
 

[colin todd]

There used to be but isn't now.  I blame Wee B, but on the other hand its right not to omit from the top floor, so the little feller was doing his best.

[wee brian]

yup, that's how I read it.

[col10]

On the point about whether it is ok to have private entrance halls forming the lobby protection the problem is that the private entrance halls are under the maintenance, management, control of the individual flat occupier who is a lay person and this is not the same as having a common lobby under RP control and risk assessed.  The risk assessment may not go beyond the flat entrance door.  A door to a small kitchen is likely to be removed.
Personally I don't think private entrance halls should be accepted as lobby protection for circumstances beyond the two flats per floor in the AD, but it is something that is done by many BCOs and often a lobby to an individual flat is bunged in as an afterthought, late in the design, and the flat entrance door then later moved to include the lobby within the flat.
There's also no door closers in the  private entrance hall and there should be AOV as opposed to just OV to the stairway.

[kurnal]

I agree Colin, anything that lies behind the flat entrance door comprises domestic premises and therefore falls outside the control of the Fire Safety Order.

[Bruce89]

With the exception of Article 31.