All junction boxes and conduit bodies I've ever used do require tools to open because they are secured by screws. The question should be, how do you access the wiring?

Look in Article 100.

"Capable of being removed or exposed without damaging the building structure, other electrical equipment, other building systems, or finish of the building."

The answer is no, the code does not say "without tools".

However, regarding your other posted question, covering a junction box or conduit body with plywood would mean that you have to damage the "finish of the building" to then access the wiring.

All junction boxes and conduit bodies I've ever used do require tools to open because they are secured by screws. The question should be, how do you access the wiring?

Look in Article 100.

"Capable of being removed or exposed without damaging the building structure, other electrical equipment, other building systems, or finish of the building."

The answer is no, the code does not say "without tools".

However, regarding your other posted question, covering a junction box or conduit body with plywood would mean that you have to damage the "finish of the building" to then access the wiring, unless this plywood is somehow made into a door or access panel.