Twenty five years ago, 22 inch arms were the maximum everyone dreamed of.
I would say that without any steroids, just creatine and protein shakes etc, you can get to 17inch arms maybe 18 if your lucky, then to get up to bodybuilding standards you would have to take stuff, its just nor possible to have like 22. 23 inch without.
At about 190, I got to 16.5 inch arms. Nothing but a protein shake once in awhile. Alot of chicken and tuna though.
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