Personal Training Arbitration —  

1. Introduction

Personal training arbitration refers to the resolution through arbitration of disputes arising from agreements between:

personal trainers and clients;

gyms and personal-training clients;

fitness clubs and personal trainers;

independent personal trainers and gyms;

online fitness platforms and trainers;

employers and personal-training employees; and

fitness businesses and contractors.

The disputes can concern:

injuries sustained during training;

negligent exercise instruction;

improper use of equipment;

failure to conduct appropriate fitness screening;

overtraining;

failure to account for a client's medical limitations;

payment and refund disputes;

personal-trainer employment claims;

unpaid wages and commissions;

classification of trainers as employees or independent contractors;

non-compete and non-solicitation obligations;

confidentiality;

termination;

discrimination or harassment;

consumer-protection claims; and

enforceability of arbitration clauses contained in membership or personal-training agreements.

A particularly important feature is that personal-training agreements frequently combine three different contractual mechanisms:

an arbitration clause;

an assumption-of-risk provision; and

an exculpatory/release clause.

These provisions must be analyzed separately. An arbitration clause determines where and how the dispute is decided; an exculpatory clause determines whether liability has been contractually waived.

The case law demonstrates that courts may enforce arbitration agreements even when the underlying dispute involves serious personal injury, while separately examining whether a release or waiver is valid. (MidPage) 

2. What Is a Personal Training Arbitration Agreement?

A typical personal-training contract might state:

"Any dispute, claim or controversy arising out of or relating to the personal training services, this agreement, the client's participation in physical activities, or the relationship between the parties shall be resolved by binding arbitration."

The agreement may also contain:

waiver of liability;

assumption of risk;

medical disclaimer;

cancellation policy;

payment provisions;

personal-training package terms;

trainer substitution provisions;

confidentiality;

governing law; and

venue/seat of arbitration.

The arbitration clause may be located in:

the gym membership agreement;

a separate personal-training agreement;

an employment agreement;

an online terms-of-service document; or

an employee handbook.

3. Two Principal Categories of Personal Training Arbitration

A. Client-versus-Gym/Trainer Arbitration

Example:

A client suffers a spinal injury during a personal-training session and sues the trainer and gym.

Issues include:

negligence;

duty of care;

assumption of risk;

release;

causation;

damages;

arbitration.

B. Trainer-versus-Gym Arbitration

Example:

A personal trainer claims the gym failed to pay commissions and overtime.

Issues include:

employment status;

wage claims;

arbitration;

class/collective claims;

independent-contractor status;

termination;

non-compete obligations.

These two categories should not be confused because the legal issues are substantially different.

4. Case Law 1 — Evans v. Fitness & Sports Clubs, LLC, No. 2:15-cv-04095 (E.D. Pa. 2016)

This is one of the most useful authorities concerning personal-training contracts.

Facts

Patricia Evans participated in personal training at an LA Fitness facility.

During a personal-training session, she fell while backpedaling and fractured both wrists.

She sued the fitness company for negligence and related claims.

She had signed:

a membership agreement; and

a separate personal-training agreement.

Both agreements contained:

assumption-of-risk provisions;

exculpatory provisions; and

arbitration provisions.

The relevant provisions were placed in a prominent boxed section using larger/bold text. (MidPage) 

Decision

The court held that the contractual releases were enforceable and granted summary judgment for LA Fitness.

The court emphasized that the agreements expressly addressed negligence and were conspicuously presented.

Principle

A personal-training agreement may contain enforceable provisions releasing a gym from liability for negligence when the governing law permits such releases and the contractual language is sufficiently clear.

Importance

The case demonstrates that a personal-training dispute may involve both arbitration and substantive liability limitations.

The fact that an arbitration clause exists does not itself establish that the gym is free from liability. The tribunal or court must separately determine the effect of the release.

5. Case Law 2 — Bennett v. Biernacki, 2022-Ohio-4449

Facts

Pamela Bennett joined Crunch Fitness and purchased personal-training services.

She was assigned Ian Biernacki as her personal trainer.

The plaintiff alleged that the trainer was inadequately qualified and that she suffered injury during training.

She had signed:

a gym membership agreement; and

a personal-training agreement.

The agreements contained liability limitations concerning injuries occurring during training. (Justia Law) 

Decision

The Ohio Court of Appeals reversed summary judgment because a genuine issue of material fact existed concerning the negligence claims.

Principle

A personal-training agreement does not automatically eliminate factual questions concerning negligent training.

The court can examine:

trainer qualifications;

training instructions;

exercise selection;

causation;

foreseeability;

the exact contractual language.

Arbitration significance

Although the case principally concerned liability rather than arbitration, it demonstrates why an arbitrator dealing with a personal-training dispute may need to consider extensive factual evidence concerning the standard of care and trainer competence.

6. Case Law 3 — Nelson v. AT Fitness, LLC, 2020

Facts

Amey Nelson was exercising at an Anytime Fitness facility under the direction of personal trainer Stefani Kaufman.

Nelson suffered a hand injury while using a weight machine.

She alleged that the trainer improperly instructed her regarding use of the equipment.

The dispute involved:

negligence;

personal-trainer conduct;

the relationship between the trainer and gym; and

the effect of the gym's liability release. (FindLaw) 

Decision

The Supreme Court of Idaho examined whether the trainer was protected by the gym's contractual release and whether the trainer acted as an actual or apparent agent of the gym.

Principle

A personal-training dispute may involve several legally distinct relationships:

Client → Trainer

Client → Gym

Trainer → Gym

The existence of a contractual release between the client and gym does not necessarily resolve every question involving the trainer's independent legal status.

Arbitration relevance

When drafting an arbitration clause, it is therefore important to specify whether arbitration covers:

the gym;

the individual trainer;

employees;

independent contractors;

affiliated companies; and

agents.

7. Case Law 4 — Burton v. 24 Hour Fitness USA, Inc., California Court of Appeal (2012)

This is an important trainer-employment arbitration authority.

Facts

Terrance Burton worked as a personal trainer for 24 Hour Fitness.

He later sued the company alleging violations of California wage laws.

When hired, he had signed an employment application containing an arbitration agreement.

He also signed an employee-handbook acknowledgment agreeing to arbitrate employment disputes. (Casemine) 

Issue

The dispute concerned whether the employment arbitration agreement applied to Burton's statutory employment claims.

Principle

An arbitration agreement in an employment relationship can potentially cover statutory wage claims when the agreement validly encompasses disputes arising out of employment.

Importance

For personal-training businesses, this is highly relevant because trainers may be:

hourly employees;

salaried employees;

commissioned employees; or

independent contractors.

A personal trainer's employment classification can substantially affect the enforceability and scope of arbitration.

8. Case Law 5 — Edwards v. 24 Hour Fitness, No. C09-1016RSL (W.D. Wash. 2009)

Facts

Blaine Edwards was employed by 24 Hour Fitness as a Certified Personal Trainer.

He subsequently worked as a fitness counselor.

He brought employment-related claims against the company.

24 Hour Fitness moved to compel arbitration based on the employment arbitration agreement.

Decision

The federal court granted the motion to compel arbitration and stayed the case.

The court treated the employment arbitration agreement as binding on the employee's employment-related claims. (Justia Law) 

Principle

A valid employment arbitration agreement may require a personal trainer to arbitrate claims arising from the employment relationship rather than pursue those claims in court.

Importance

This case is particularly relevant to:

wage disputes;

wrongful termination;

employment discrimination;

commission disputes;

workplace claims.

9. Case Law 6 — Baldwin v. TMPL Lexington LLC, No. 1:23-cv-09899 (S.D.N.Y. 2024)

This is a particularly useful modern case.

Facts

The plaintiff worked as a personal trainer at TMPL luxury fitness clubs.

She alleged:

wage violations;

overtime violations;

statutory wage-notice violations;

sexual harassment;

sexual assault; and

other employment-related misconduct.

The defendants moved to compel arbitration of the wage claims.

Decision

The federal court denied the motions to compel arbitration on the record before it. (Justia Law) 

Principle

An employer cannot compel arbitration merely because it operates a fitness business.

It must establish an enforceable arbitration agreement covering the particular employee and claims.

Importance

This case demonstrates the other side of personal-training arbitration:

Arbitration is contractual; the employer bears the burden of establishing a valid agreement.

This is especially important where the trainer challenges:

whether they signed the agreement;

whether the agreement covers the claim;

whether the agreement is unconscionable; or

whether the employer's arbitration procedure is enforceable.

10. Case Law 7 — Stone v. Exos Human Capital, LLC, S.D.N.Y. 2025

Facts

The plaintiff was employed as a Personal Trainer by MediFit.

His employment agreement governed:

compensation;

employment duties;

payroll;

workplace obligations; and

personal-training responsibilities.

The defendants sought to compel arbitration. (Justia Dockets & Filings) 

Decision

The federal court granted the motion to compel arbitration and stayed the case.

The court directed the parties to proceed with arbitration.

Principle

Where a personal trainer's employment agreement contains a valid arbitration provision, employment-related disputes may be required to proceed through arbitration.

Importance

The case illustrates modern application of arbitration to personal trainers working within corporate fitness and wellness businesses.

11. Case Law 8 — Salas v. Endo Fitness Goleta, LLC, California 2026

This is a particularly current example.

Facts

Eric Salas worked as a personal trainer at a Fitness 19 gym.

He brought claims concerning alleged:

unpaid wages;

meal/rest-period violations;

wage-statement violations;

late payment;

unreimbursed business expenses; and

related Labor Code violations.

The defendants moved to compel arbitration.

The plaintiff argued that:

the defendants had not established that he signed the arbitration agreement; and

the agreement was unconscionable.

Decision

The court ordered arbitration of the individual's claims, dismissed the class claims, and stayed the non-individual PAGA claims pending arbitration. (decisiondepot.legal) 

Principle

Personal trainers working for fitness businesses may be required to arbitrate individual employment claims even where they attempt to bring those claims as class or representative proceedings.

Importance

This is highly relevant to modern gym businesses with numerous trainers.

12. Case Law 9 — Torrecillas v. Fitness International, LLC, California Court of Appeal (2020)

Facts

Torrecillas worked for Fitness International and eventually became vice-president of personal training.

The employer relied upon arbitration agreements signed during the employment relationship.

There were multiple arbitration documents, including a later agreement incorporating separate dispute-resolution rules. (FindLaw) 

Principle

An employee's arbitration obligations may arise from multiple contractual documents, but the court must determine whether those documents were properly incorporated and whether the arbitration obligation is enforceable.

Relevance

Fitness companies should avoid relying on a complicated collection of:

employee handbooks;

personnel manuals;

offer letters;

policy documents.

A single, clearly drafted arbitration agreement is usually preferable.

13. Case Law 10 — Evans and the Significance of the Personal Training Agreement

A particularly important feature of Evans is that the client did not merely sign a generic gym membership.

She separately signed a Personal Training Agreement containing prominent provisions concerning:

release;

assumption of risk;

arbitration; and

physical activity.

The court emphasized the prominence and wording of the provisions. (Justia Dockets & Filings) 

This demonstrates a valuable drafting principle:

A gym should not rely solely on a general membership agreement if it wants arbitration to cover specialized personal-training disputes.

A separate personal-training agreement provides much stronger contractual clarity.

14. Comparison of the Principal Cases

15. The Most Important Distinction: Arbitration vs Release

This distinction is frequently misunderstood.

Arbitration clause

Says:

"You must bring the dispute before an arbitrator."

Release clause

Says:

"You have waived the right to sue us for specified injuries."

These are not the same thing.

Suppose a client suffers a serious injury.

The contract contains:

an arbitration clause; and

a negligence release.

The arbitration clause may mean:

The arbitrator decides the dispute.

The release may mean:

The arbitrator ultimately concludes that the gym is not liable.

Thus, arbitration does not necessarily create liability or eliminate liability; it primarily changes the forum and procedure.

Evans is a particularly useful illustration of this distinction. (MidPage) 

16. Negligence During Personal Training

A client may allege that the trainer:

selected an inappropriate exercise;

used excessive weight;

failed to demonstrate the exercise;

failed to correct improper technique;

ignored pain;

failed to stop the session;

failed to account for the client's physical condition;

pushed the client beyond safe limits.

The arbitrator may have to determine:

Duty

Did the trainer owe the client a duty of reasonable care?

Breach

Did the trainer depart from reasonable professional practice?

Causation

Did the trainer's conduct cause the injury?

Damages

What loss resulted?

17. Medical Screening

Personal trainers often ask clients to complete:

health questionnaires;

PAR-Q forms;

medical history forms;

injury disclosures.

A dispute may arise where:

Client disclosed a heart condition but the trainer nevertheless prescribed high-intensity exercise.

The arbitration may therefore involve:

contractual obligations;

negligence;

professional standards;

causation;

assumption of risk.

A waiver should not be assumed to cover every form of misconduct.

18. Gross Negligence and Willful Misconduct

Many jurisdictions distinguish:

Ordinary negligence

Failure to exercise reasonable care.

Gross negligence

A significantly more serious departure from reasonable conduct.

Intentional misconduct

Deliberate harmful conduct.

A contract may successfully waive ordinary negligence under the law of some jurisdictions but may not be permitted to waive:

gross negligence;

recklessness;

intentional misconduct;

statutory rights.

This is jurisdiction-specific.

The Herren litigation illustrates the importance of distinguishing ordinary negligence from gross negligence in personal-training disputes. (Justia Law) 

19. Assumption of Risk

Personal training naturally involves some physical risk.

A client may voluntarily accept risks associated with:

lifting weights;

running;

resistance training;

cardiovascular exercise;

balance exercises.

But assumption of risk does not necessarily mean:

"The client accepts every risk created by negligent training."

The legal effect depends heavily upon jurisdiction.

20. Personal Trainer as Independent Contractor

A major dispute may be:

Is the trainer an employee or an independent contractor?

This matters because employment laws can determine:

minimum wage;

overtime;

meal periods;

expense reimbursement;

workers' compensation;

discrimination protections;

tax obligations.

It also affects who is bound by an employment arbitration agreement.

21. Wage Arbitration

Personal trainers frequently receive compensation based on:

hourly wages;

per-session payments;

commissions;

client packages;

membership sales;

performance bonuses.

Disputes can arise where a gym claims:

"The trainer is an independent contractor."

while the trainer argues:

"I was actually an employee."

The arbitration clause should expressly cover:

classification, compensation, commissions, wages, overtime, expenses, termination and all employment-related claims.

Burton, Edwards, Stone and Salas demonstrate the importance of employment arbitration in the fitness industry. (Casemine) 

22. Class and Collective Arbitration

A fitness company may employ hundreds of trainers.

Suppose 200 trainers allege:

"We were improperly classified as independent contractors."

If their agreements contain individual arbitration clauses, the company may attempt to prevent:

class actions;

collective actions;

representative proceedings.

Salas illustrates the modern interaction between personal-trainer employment arbitration, individual claims and representative claims. (decisiondepot.legal) 

23. Online Personal Training

Modern personal training increasingly occurs through:

mobile apps;

video platforms;

wearable devices;

online coaching;

subscription fitness services.

The contract may be accepted by:

clicking "I agree."

The central question becomes:

Did the client receive reasonable notice of the arbitration clause?

Baldwin and modern online-contract cases demonstrate why electronic assent must be documented carefully.

24. Personal Trainer Misconduct

A client may allege:

sexual harassment;

inappropriate touching;

discrimination;

bullying;

abusive conduct;

invasion of privacy.

Such claims may involve statutory protections.

The arbitration clause must therefore be examined in light of:

applicable employment legislation;

anti-discrimination legislation;

sexual-harassment laws;

public policy;

statutory restrictions on arbitration.

A general personal-training clause should not be assumed to resolve every statutory claim.

25. Third-Party Issues

A personal-training agreement may involve:

Client

↓

Trainer

↓

Gym

↓

Franchise owner

↓

Corporate parent

↓

Equipment manufacturer

The client may sue all of them.

The arbitration question becomes:

Which defendants actually have the right to enforce the arbitration agreement?

A well-drafted agreement should expressly cover:

employees;

trainers;

independent contractors;

agents;

affiliates;

franchisees;

successors and assigns.

26. Unconscionability

Personal-training agreements are often standardized contracts.

A claimant may argue:

"I had no meaningful choice."

The court/arbitrator may examine:

Procedural unconscionability

Was the clause hidden?

Was it presented in tiny print?

Was the client pressured to sign?

Was sufficient time provided?

Substantive unconscionability

Is arbitration excessively expensive?

Is the clause one-sided?

Can only the gym bring claims in court?

Are the client's remedies disproportionately restricted?

The outcome depends upon the applicable jurisdiction.

27. Conspicuousness

Evans provides a particularly useful lesson.

The personal-training agreement used:

a separate box;

larger font;

bold headings;

prominent placement;

signature/initial requirements.

The court considered these circumstances significant when evaluating the contractual provisions. (Justia Dockets & Filings) 

Therefore, an arbitration clause should not be buried on page 17 of a 20-page gym membership contract.

28. Scope of Arbitration

Consider three clauses.

Narrow

"Disputes concerning payment shall be arbitrated."

This may not cover injury claims.

Medium

"Disputes arising from this Personal Training Agreement shall be arbitrated."

This is broader.

Very broad

"Any claim, dispute or controversy arising out of or relating to the services, physical activities, membership, personal training, relationship between the parties, this agreement or its termination shall be arbitrated."

This is substantially broader.

For personal-training businesses, the third formulation is generally more comprehensive, subject to applicable law.

29. Arbitration of Personal Injury

Personal-injury claims can potentially be arbitrated when:

there is a valid arbitration agreement;

the claimant is bound by it;

the injury claim falls within its scope; and

the claim is legally arbitrable.

The existence of bodily injury does not automatically make a dispute non-arbitrable.

The important question is:

Did the parties agree to arbitrate this particular type of dispute?

30. Evidence in Personal Training Arbitration

The tribunal may consider:

Training records

exercise programs;

session notes;

progression charts.

Client records

medical disclosures;

health questionnaires;

injury history.

Communications

WhatsApp messages;

text messages;

emails;

app communications.

Video

CCTV;

training-session footage;

exercise demonstrations.

Expert evidence

physiotherapists;

sports physicians;

exercise physiologists;

certified trainers;

biomechanics experts.

31. Expert Evidence and Standard of Care

A particularly difficult issue is:

What should a competent personal trainer reasonably have done?

The arbitrator may require expert evidence concerning:

appropriate exercise intensity;

progression;

warm-up;

spotting;

equipment use;

client screening;

contraindications;

injury response.

The cases involving Bennett, Nelson and Evans illustrate why factual and expert questions can become central in disputes involving personal trainers. (Justia Law) 

32. Damages

Depending upon applicable law, a claimant may seek:

medical expenses;

rehabilitation costs;

lost income;

future medical expenses;

pain and suffering;

emotional distress;

disability-related losses.

The trainer or gym may counterclaim for:

unpaid training fees;

contractual charges;

equipment damage;

unpaid membership fees.

33. Indian Legal Position

India does not have a substantial body of reported Supreme Court decisions specifically titled "personal training arbitration."

Therefore, an Indian dispute would primarily be analyzed under:

Arbitration and Conciliation Act, 1996;

Indian Contract Act, 1872;

Consumer Protection Act, 2019;

applicable employment laws;

tort principles;

medical/health regulations where relevant;

data-protection/privacy requirements.

The key provisions of the Arbitration and Conciliation Act, 1996 include:

Section 7

Arbitration agreement.

Section 8

Reference to arbitration.

Section 9

Interim measures by courts.

Section 11

Appointment of arbitrators.

Section 16

Competence-competence.

Section 17

Interim measures by arbitral tribunal.

Section 34

Setting aside an arbitral award.

Section 36

Enforcement of awards.

34. Important Indian Arbitration Authorities

Booz Allen & Hamilton Inc. v. SBI Home Finance Ltd., (2011) 5 SCC 532

The Supreme Court distinguished disputes involving rights in rem from rights in personam.

A straightforward personal-training contractual dispute concerning:

fees;

service quality;

contractual negligence;

cancellation

is conceptually different from a dispute involving non-arbitrable statutory rights.

A. Ayyasamy v. A. Paramasivam, (2016) 10 SCC 386

The Court considered fraud and arbitrability.

A personal-training claimant alleging:

"The trainer falsely represented his qualifications"

does not automatically make the dispute non-arbitrable.

The nature of the fraud and relief sought must be examined.

Vidya Drolia v. Durga Trading Corporation, (2021) 2 SCC 1

This is a foundational Indian case on arbitrability.

It is relevant where the parties disagree about whether a personal-training dispute can legally be referred to arbitration.

Mayavati Trading Pvt. Ltd. v. Pradyuat Deb Burman, (2019) 8 SCC 714

The Supreme Court emphasized the limited nature of judicial scrutiny at the Section 11 stage.

This can become relevant when a fitness company seeks appointment of an arbitrator.

35. Consumer Disputes in India

A client purchasing personal-training services may potentially qualify as a consumer.

A dispute could therefore involve:

deficiency in service;

unfair trade practice;

misleading representations;

defective service;

refund disputes.

The existence of an arbitration clause does not automatically answer whether a statutory consumer forum can exercise jurisdiction.

The arbitrability analysis must consider the Consumer Protection Act and Supreme Court jurisprudence concerning statutory remedies.

36. Privacy and Fitness Data

Modern personal training generates substantial personal data:

weight;

body-fat percentage;

medical history;

heart rate;

exercise performance;

photographs;

biometric information;

wearable-device data.

A personal-training arbitration clause should therefore contain confidentiality protections.

The agreement should specify:

who owns the data;

who may access it;

whether the trainer can retain it;

whether it can be used for marketing;

when it must be deleted.

37. Personal Trainer Arbitration Clause — Model

A suitable clause could provide:

Arbitration: Any dispute, controversy or claim arising out of or relating to this Personal Training Agreement, the provision of personal training services, fitness assessments, exercise programs, payments, cancellation, injury, negligence, confidentiality, personal data, termination or the relationship between the Client and Trainer or Fitness Facility shall, to the maximum extent permitted by applicable law, be finally resolved by binding arbitration before a neutral arbitrator. The arbitrator shall have authority to determine all claims legally capable of arbitration and shall apply the governing substantive law. Nothing in this clause shall waive any statutory right that cannot lawfully be waived or prevent a party from seeking urgent interim relief from a competent court where such relief is legally available.

38. Recommended Contract Structure

A professional personal-training agreement should ideally contain:

Identification of trainer;

Identification of fitness facility;

Client information;

Services;

Training frequency;

Fees;

Cancellation policy;

Medical disclosure;

Fitness assessment;

Assumption of risk;

Liability provisions;

Trainer qualifications;

Client responsibilities;

Confidentiality;

Health and biometric data;

Intellectual property in training programs;

Termination;

Dispute resolution;

Arbitration;

Governing law;

Emergency relief;

Signature/acceptance mechanism.

39. Key Principles Derived from the Case Law

Principle 1 — A personal-training contract can contain an enforceable arbitration clause

Evans, Edwards, Stone and Salas demonstrate this in different contexts. (MidPage) 

Principle 2 — Arbitration and liability releases are different

A client can be required to arbitrate but still potentially establish liability if the release does not apply.

Principle 3 — Conspicuous drafting matters

The prominence of the personal-training provisions was important in Evans. (Justia Dockets & Filings) 

Principle 4 — Trainer qualifications matter

Bennett demonstrates the importance of factual questions concerning the trainer's qualifications and conduct. (Justia Law) 

Principle 5 — Agency matters

Nelson demonstrates that the legal relationship between trainer and gym may affect liability. (FindLaw) 

Principle 6 — Employment arbitration is especially important for trainers

Burton, Edwards, Stone and Salas show that trainers can be required to arbitrate employment-related disputes. (Casemine) 

Principle 7 — Class and representative claims require separate analysis

An individual trainer may be bound to arbitrate even where representative claims are treated differently, as illustrated by Salas. (decisiondepot.legal) 

40. Conclusion

Personal training arbitration is an important mechanism for resolving disputes between clients, trainers and fitness businesses. It is particularly useful because personal-training relationships generate two very different types of disputes:

Client-side disputes

personal injury;

negligent instruction;

unsafe exercise;

improper equipment use;

inadequate screening;

breach of service obligations;

refunds.

Trainer-side disputes

unpaid wages;

commissions;

overtime;

employment classification;

discrimination;

termination;

non-compete obligations;

confidentiality.

The leading authorities show that the exact contractual wording is decisive. Evans demonstrates the importance of a clearly drafted personal-training agreement; Bennett and Nelson illustrate the substantive negligence and trainer-liability issues; Burton, Edwards, Stone, Baldwin and Salas demonstrate arbitration involving trainers as employees. (MidPage) 

For India, the principal framework would be the Arbitration and Conciliation Act, 1996, read with contract, consumer, employment, tort, privacy and applicable health/safety law. The safest drafting approach is to keep the arbitration clause, liability waiver, assumption of risk, medical disclosure, data protection and emergency-relief provisions separately and clearly drafted, rather than attempting to combine them into one broad paragraph.