current filesystems attempt to schedule data to be written to disk within about 5 seconds or so in most cases (I remember that at one point reiserfs allowed for 30 seconds, and so was posting _amazing_ benchmark numbers, for benchmarks that took <30 seconds to run), but it's possible for it to take longer, or for the data to get to disk on the wrong order, or partially get to disk (again in some random order)
because of this, applications that really care about their data in crash scenarios (databases, mail servers, log servers, etc), do have fsync calls "littered" through their code. It's only recent "desktop" software that is missing this. In part because ext3 does have such pathological behaviour on fsync
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