I'm making some metal seats with swaged or flared holes on the back. Do these holes have to meet the 2.5mm radius requirements?

IVA manual:

The surface of the rear parts of seats shall exhibit no dangerous
roughness or sharp edges likely to increase the risk of severity of
injury to the occupants. This requirement is considered as satisfied
if the vehicle complies to section 12.

Section 12 is interior fittings,
so it boils down to:

Interior design features and fittings in the “specified zone” which are contactable with a 165mm sphere must have a radius of curvature of 2.5mm or greater, except where a projection from a panel is less than 3.2mm where the edges must be at least blunted. (see note 3, 4and 9) see annex 1 and 2

However, further to that, the annex 1 of part 12 shows the rear of the seats to be an 'exempt area'
Bit of a contradiction, but I can only assume the 1st quote above realates to where you have rear seats that face the back of the front seats.

[Edited on 1/7/10 by loggyboy]

In other words yes, just do it otherwise you might fail and have to do it anyway