T Nation

Female Arm Training Advice?

I have been asked to give some training advice for a female, specifically arms and I don?t know the answer? The example she gave me was Katie Uter a fitness model. I checked her out and she has very tight, small arms. Now how does a female achieve this? Is it through high reps, low reps, no direct arm training at all or is it genetics? This female is already very low in BF about 15-16% but her arms are larger then she would like. Any input is appreciated.
Thanks