Here’s an illustration I use. 2009 IRC says flight of stairs with four or more risers. I would call this out as a safety issue, someone trips and there’s nothing to grab onto.
Many jurisdictions specifically state that handrails are not required for exterior and entryway steps leading to the residence. Regardless of how this is interpreted, guards (guardrails) would not be required for these particular steps.
With that, I will still recommend handrails on all steps where there are 4 or more risers. As previously mentioned, the bigger issue here is the missing paver, which is a hazard regardless of whether there’s a handrail or not.
I think your CodeCheck may be in error (which is not uncommon for CodeCheck). I don’t have an older version of the IRC, but the UBC requires handrails on steps/stairs with 4 or more risers as early as 1996.
Thanks for the link Chris. We also had this discussion on the HIP forum a while back. I will look for the thread as the picture posted there would make for interesting comment here. I will post it here if I can find it. 
I go with no railing required for most of it based on this.
http://www.boabc.org/assets/Codes~and~Regs/code_idx_980146.pdf
See attached photo for interpretation.
I do write that the client should consider full railing depending on their situation to at least make them aware.
Since you can egress to grade without having to go down th entire stairs, it is what it is.
When you have just a guard/handrail, it is wide open. What becomes of the 4" or less baluster condition?
Balusters not required if less that 30" above ground level.
Guards and handrails are not the same, and are required under different circumstances.
Condition A: Guards are required at locations where the elevations of standing/walking surfaces differ by 30 inches or more. All “guards” require intermediate rails (balusters) with openings less than 4 inches.
Condition B: “Handrails” are required on steps and stairways where there are four or more risers.
If both conditions exist, guards can also be used as handrails, as long as they are constructed appropriately.
What if no pavers existed and it was just uneven dirt??? Would you need a handrail then? What if some old bag tried walking up the hill of uneven dirt and fell down while screaming “I’ve fallen and I cant get up!”
You guys should focus on the home instead of picking apart some landscaping.
I had an agent tell me today that another inspector wrote up a gravel driveway. I had to laugh…
What’s the rest of the story?
I have written up many gravel driveways over the years. The last I recall was for my client… handicapped and wheelchair bound. The driveway, which was in terrible condition, would have been cheaper to pave than to do the repairs necessary to make it usable for my client. My findings on the driveway alone caused her to “walk” from the deal.
Still think it’s funny?
I would have had a few words for that Realtor.
Each Client must be treated differently according to needs. I too agree with Jeffrey and have seen this with individuals that have disabilities.
As for the guard rail yes always no matter how many times I here it is not an issue.
If you have not yet looked around you probably still see ones using 2x4 as a graspable handle also.
Property condition should reported the same, regardless of any special needs the client may have.
If you’re performing an ADA compliance inspection, then you would report on ADA compliance.
Special needs should certainly be discussed, but have no business being included in a report, unless that’s what you were hired to do…
My reports are for my Client only!
It is up to them to give it to any other person they want.
Within my report are all considerations for the individual and never have I given a soft report just to keep the Real Estate Agent or AHJ happy.
You do whatever you want Jeffrey what works for you will not work here.
I’m quite certain it will work “there,” Kevin. The “right” way to report works everywhere.
Do you also recommend lowering all countertop heights, widening door openings, adding handrails at tub and showers, etc.? Or do you just pick a few random items to add to your report in an effort to impress your clients?
OK now you are just being an xxxxxxx So I will end conversation!
Good answer…
But pavers do exist in this case as part of a stairway leading from front porch to driveway, more than general landscaping. Landscaping is for decoration and/or to control water/soil erosion. This stairway serves a specific purpose. If your clients grandma falls down and breaks her hip and a lawyer/insurance company suggest a handrail could have prevented it; you may be paying for a new hip.
So what?
This make no sense.
Point it out if it makes you feel better but I generally work with clients having at least a few brains cells.