Well that is why it is not specifically stated in the guidelines, because there may be situations where it is not a safety issue and it is left to the appraiser's judgment. For example, if you had only 3-4 stairs in a hallway with walls, or even half walls, on both sides the risk level is relatively low. The appraiser could also consider the age and mobility of the occupants. Even FHA clarified its position on handrails in such a way that they may not be required and they are usually much more strict than VA.
In a broadcast in 2011, Gerry Kifer was put on the spot on this issue and he stated that it was a judgment call, but in his opinion, a fall of 42" or greater should require a handrail. The problem with a statement like from the VA's Chief appraiser is that even if it is not written, because HE said it, it is now policy and appraisers were measuring the fall distance. 41"! It's good!