Here in East TX, our soil is acidic red clay with just about every type of wood eating bug out there. Creosote soaked railroad ties will not last ten years on the ground in contact with the soil. The bugs get through the creosote and eat them out from the inside. You never even see it happening. Just all of a sudden, it collapses. The outside looks fine, but it's hollow in the inside. I've never seen them used for steps, just in landscaping and fence posts.
I believe one of the main reasons the railroad sets the ties on a bed of gravel is make sure they do not touch the dirt so they last longer. Water will drain through the rock, and bugs do not get to them from the soil.