Peter,
It can be done either way. I just use the checkering file. You have to finish the area completely before heat treat. I use a Beartex wheel to deburr and take off the sharp edges then touch it up again. You can use 400 grit paper after heat treat to clean the grooves up.
Let me add a couple of options...
If you have a milling machine you can put the part to be serrated in a vise, horizontal to it, and use a 60° or 90° cutter and cut one, move down .xxx (.100) cut the next one, etc.
Or, if you can tilt the head, tilt it to 45° and use a 1/4" center (end) cutting endmill with the part in the vise and parallel to it and cut the first one, move forward .xxx (.100) and cut the second one, etc, etc
I ground a 1/2" checkering file down to 1/4" wide and use it for radius areas that I serrate (like the lock release area).
BTW, when I say serrate, I don't mean edge cutting serrations. I'm talking about V shaped cuts (traction grooves)
