From relatively current Chronograph testing I found that the best NON +P round for the 38 Special is the Buffalo Bore 158 grain LSWCHP which out of my 2" Chief's did about 850 - 860 fps. The Remington and Winchester +P LSWCHP FBI loads which are actually rated +P, Chronographed to about the same velocity as the BB. So, either the BB is at the upper limit of pressure or the Remington & Winchester are at the lower end of the +P pressures. I suspect a bit of both. If you are hesitant to load rounds marked with the +P designation I'd definitely go with the BB # 20C, but from what I personally witnessed, the +P rated Rem's and Win's. are just about the same thing. Bottom line is all three will do the job and should not beat up your gun. The "Big Three" ammo Company's have really watered down their +P ammo according to my actual test test results.
I did NOT do any Ballistic Gel Block testing but there are many of them on Youtube should you care to watch. I much prefer 158 grain slugs out of a 38 Special and have always found them to shoot more to the point of aim than the lighter bullets do.
I also tested the Speer 135 grain short barrel GDHP which is +P rated, but did not have an exceptionally hard to handle recoil, did not seem like it was at the high end of pressure, and even though it is a lighter 135 grains has a very good reputation for getting the job done. Use them sparingly and you should be just fine. The velocity on the Gold Dots was just under the Buffalo Bore NON +P's so they are also a very viable choice and were specifically designed for short snub guns.