As above -
I am not up on this aspect anywhere near well enough, but being as .38-40 is both a Rifle Cartridge and a Revolver Cartridge, in the old days, when it was a Black Powder Cartridge, it did not make any difference which it was fired from, other than one got a higher FPS out of the Rifle of course.
Now though, things may be different, in so far as Smokeless will allow there to be dedicated Rifle ( 'Rifle Only' ) Loads, and, Revolver Loads.
If there are off the shelf 'Rifle Only' Loads, they may or may not be clearly labeled as such, and, one would not want to use them in an old Revolver.
.32-20 is definitely this way, and I just do not know whether .38-40 is this way, so...one would want to find out about that I think.