ALMOST NOTHING can fire OOB. The design makes it impossible.
The typical 9 mm AR upper is an example of a design in which out of battery firing actually can occur, due to the design um,
not making it impossible. Using a S&W Mod 38, whatever that is (unless you meant a S&W Model 52, rather than Model 38) and a locked-breech pistol as examples to support your argument suggests that you may not realise that these are not applicable to a simple blowback design.
