I can see the hinges being a problem. To me that sounds like a fail as per the wording, as the hinge is neither internal nor shielded. How thick the steel on the hinges is itself is kinda irrelevant. You would need to shield them... with more steel... to prevent power tools or pry bars getting to them easily.
Or you can cross your fingers and hope your AO doesn't notice. But a homemade safe is bound to be subject to maximum scrutiny, so I don't rate your chances.
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