I do not feel that a base cabinet does fulfill that requirement as the glass can be located above the cabinet, within reach of human contact and still a hazard, the permanent barrier would have to go high enough to actually separate the human from the possibility of glass contact.
I agree the counter may satisfy the requirement. However, as suggested by Michael, the height of the barrier must provide a barrier for any piece of nonsafety glazing within 60 inches of the floor.
agree with Joe and Michael.
Looked at Code commentary. They talk wall or other permanent barrier. Commentary states if not full height wall then you still have to consider any glazing within the 60" to require the safety glazing.