In a number of 'what's the best steel' threads it's not uncommon for makers and others to point out that the heat treat is as important and maybe more important. The authors of an older Fine Woodworking test of chisels concluded the same. The article was in a small book on hand tools from the mid 1980s, and they looked performance, hardness, type of steel, carbon content, and grain of some US, English, German, and Japanese woodworking chisels. Most of the chisels were W type tool steel, one was an S type, one was 1095 (Stanley) and another was 1050 (Sears). The 1050 didn't do well but as I recall the Sears chisels did fairly well in a more recent review by the same magazine, and the 1095 did pretty well. They observed that hardness combined with fine grain produced sharper, longer lasting, more durable edges, where the Japanese chisels as a group did the best but were also the most expensive. One author noted that one of his Japanese chisels was prone to chipping due to the very high hardness, but they didn't have that problem with any in the test. Hardness ranged up to +RC62.