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ABSTRACTThis paper reports on the first study to critically examine the sustainability of whale-watching practices along the entire migratory range of a pelagic baleen whale species, the gray whale (Eschrichtius robustus). Commercial boat-based whale-watching operations along the west coast of North America were observed for sustainable practices. Data recorded aboard whale-watching vessels and collected via an online survey were integrated into the Lean Six Sigma quality-improvement tool, in order to review business processes and identify where inefficiency or ineffectiveness exists in specific phases within a process. Whale-watching practices were analyzed using this method for 24 whale-watching companies operating in Canada, the United States and Mexico. The results show a high level of variation in management regimes, and operator non-compliance with guidelines, and highlight avenues to eliminate, revise or reduce inefficiency, and improve practices in the interests of high-quality and sustainable operations. We recommend more specific and operational guidelines that allow operators to focus on high compliance with the most critical aspects of their business operation in order to build the sustainability of commercial tourist interactions with gray whales in their migratory range.