The big question is, though, did Colt heat treat the cylinders when they started officially chambering the guns in .38 Special?
I don't believe the Army-Navy models had heat treated cylinders.
I don't know that in of itself is a concern. S&W made a ton of 38 specials before the heat treating of cylinders. With appropriate ammo, those pre-heat treat guns can still be fired safely. I think the concern is what type of ammo should be used, in this case standard velocity 38 specials (assuming the gun can chamber them) moreso than whether or not the heat treating was done. Even if heat treated, I think standard velocity 38 specials are the only choice for shooting such a gun.