There have been lots of posts on this type of question in the past. One of our friends had a Yorkie that broke his back by falling off a bed, so yes, it needs to be a concern for anyone who does this and has a high bed.
We also use the doggy steps, and our guys always use the steps becuase our bed is high and has a pillow top. The steps lead to a bench, which has a fabric/stuffed covering. We snug a towel over top of the fabric, between the steps and the bed. This serves as a launch pad so our guys can jump up the rest of the way (maybe 18" from there).
There are two things we do to minimize the risks of an accidental fall. One is we line the bottom of the bed with large pillows and a big dog bed. The other is that our guys are ONLY allowed in the middle of the humans. They know that if they try and sleep on the longitudinal ends of the bed outside of us, that we will pick them up and put them back in the middle. They are pretty well trained on that by now, and almost never even try to get outside the valley of the giants.
It's so hard when they are pups and cry to be with you at night. We have always been suckers for that. I am sure it is safe for most little dogs if you take the right precautions..
