I think OP meant opening up a safe with some explosives. But let us say it is a magic safe that incinerates the contents if it detects excessive tampering - I am assuming the purpose of which is to protect sensitive documents in case if the entire safe is stolen. Then the safe maker is not liable for obstructing justice any more then a paper shredding manufacturer.
For a more concrete instance, we have the case of a friend of the Boston marathon bombers deleting his search history and getting charge with obstruction of justice[1]. However, that doesn't mean the DOJ can use the Sarbanes-Oxley Act to prevent browsers from allowing the user to delete history.
The safe maker wouldn't be liable, the owner of the safe would be. If there's a warrant for the contents of the safe, but the owner refuses to open it up, then the owner is guilty of whatever law requires you to cooperate with the warrant. Isn't that enough?
Punishing the owner for not giving the government access to the contents of the safe doesn't change the fact that the government doesn't have the contents of the safe, so I guess they might not consider it enough.
