I see no issue CCH a 1895 action that will be used for 22 RF, I have done many.

Yes, Winchester changed from a low carbon steel to a Med carbon steel around 1900-1903, on some models, Winchester continued the model line but with more modern “smokeless” steel.

Prime example is the 1886, the frames wer initially made out of low carbon 1010 steel, then around 1898-1900 Winchester switched to a higher carbon steel.

CCH the earlier frames is not a problem, but I would not feel comfortable CCH a smokeless framed 1886 chambered for 45-90 or 5-110.

Again a 1885 action chambered in 22 rf…no problem

V/R

Mike