Except for broken drives, i.e. hardware failure.
bcwipe does a nice job of sterilizing drives.
I think I've had the issue where Windows won't downgrade versions. ie. I had NTFS on the drive and needed to put Win98 on it. The Win installer refused to do so, and so I had to really wipe the drive to remove NTFS.
This was a while ago, so YMMV.