I bought my trailer frame from a guy who had to abandon his project and it has the chains welded directly to the coupler. The quality of his welds everywhere on the trailer are great (at least in appearance) but when I look at the inspection requirements when I finish my project, I won't pass. This will fail for 2 separate reasons - they are connected to the coupler and they are welded.

I think welds can be superior when it all goes perfectly but an inspector would have no way to easily tell how strong the welds are by looking at them or if the metals were affected by the heat, but fasteners are more readily inspectable.
I'll need to change this and have been checking the Washington State Patrol's requirements
http://www.wsp.wa.gov/traveler/docs/cvd/170_129.pdf which says:
The means of attachment of safety chains shall be located equally distant from and on opposite sides of the longitudinal centerline of the towing vehicle and of the trailer. Each means of attachment shall not be common with or utilize fasteners common with a ball or coupling. No welding operation shall be performed on a safety chain subsequent to its manufacture, including the direct welding of safety chain link to the towed and towing vehicles. Safety chains shall be so connected that the slack for each length of chain between trailer and towing vehicle is the same and is not more than necessary to permit the proper turning of the vehicles. When passing forward to the towing vehicle, safety chains must be crossed in such a manner as to prevent the tongue from dropping to the ground and to maintain connection in the event of failure of the primary connecting system. The linked definitions also go so far as to say the "chain" includes the attachments at both ends.
I am thinking of a few options to connect new safety chains (or cables) using either:
1. some big strong U-bolts or eye-bolts with holes through the diagonal frame tongue members.
2. same bolts through either side of the T in the center of the frame, or
3. bolting two 1/4" steel plates across the top and bottom of the intersection of the T in the center, then attach to:
a. the front corner bolts holding the 2 plates sandwiched together, or
b. leave 2 holes set back from the front corners of the lower plate.
The "T" in the center of the tongue is 18" behind the coupler so I'd need to be careful to get the chains or cables long enough but not so long that they drag. All tongue members are 2x2 steel box tubes. I have searched for hardware for attaching to the trailer but all I seem to find are eye bolts or U bolts.
