Consider that the 32 Safety was manufactured until 1937. There was no documented difference in the overall strength of the later models than the pre-1898. Obviously hundreds of thousands were routinely used in the smokeless era. After the initial resistance to smokeless powder at the turn of the century, S&W accepted and guaranteed their products with the proper use of smokeless powder.
There is nothing to suggest that the manufacturing process changed for any top-break S&W after the transition to smokeless powder. The 32 DA was made until 1920, the 38 Safety was made until 1940 and the 38 DA made to 1911. Hoglegs were made well into the Twentieth century as well. 44 New Models were made up to 1912 and the 44 DA went until 1913.
It has to be mentioned that the 38 Perfected was intended to offer a stronger design when it was introduced in 1909, but was never embraced by gun owners and ceased production only 10 years later. The Safety revolvers, on the other hand, continued in production for many decades.
. . . Metallurgy and manufacturing have come a long way since 1898 (and before) . . .
Most people aren't historical metallurgical experts, or ballistic engineering experts, etc. And the fact that some guy shot a top break .32 with modern ammo in his backyard doesn't constitute "proof" that it's safe . . .
I have been waiting a long time for someone to show me the "improved metallurgy" that would have been offered by S&W in the early 1900s as compared to the late 1800s but have never seen such a document. I think some put way too much emphasis on metallurgical developments as the reason why older S&Ws are dangerous with smokeless powders. It's metallurgy and not alchemy and improvements during the times we are talking would not have been meaningful in this discussion.
So now those who commonly use smokeless powder in old S&W revolvers are called lazy, and inferred to be stupid and reckless??
The invention of the Bessemer process in 1813 was the start of the economically feasible steel industry. Steel was introduced as an affordable commodity by 1850. Introduction of oxygen gave pig iron marvelous properties. The open hearth process invented in the 1860s basically improved the way steel was made and not the properties. Open hearth overtook the Bessemer process around 1900. Improvements in strength and ductility of steel from the 1880s into the early 1900s was minimal.
By 1880, yield strength of steel exceeded 30 ksi and in the late 1800s, steel was available with 47 ksi yield strength. Not until 1950s was this high strength considered standard. What we will probably never know is the exact steel strength used by S&W. We do know that the company always found ways of keeping costs of production down, but always provided a quality product, so my bet is high strength steel was used to make quality revolvers for a very long time.
Over-pressure loading is a real danger, and many - many firearms have been destroyed by exceeding the structural capabilities of the gun. Ammunition manufacturers have been making "standard" pressure ammunition forever (Buffalo Bore excepted). They continue to manufacture ammunition made to safely shoot in all makes, models, and ages of revolvers today. The last thing these companies want to do is face multiple lawsuits over the use of their 32 S&W ammunition for example, and am confident they have gone to great lengths to ensure the safe use in good quality top-break revolvers.