The limitations on FAT32 are high rather fast in our use cases, esp. when recording audio / guano files. In one test that was reached over the course of a weekend:
pi at ops-prototyp-mntr in /
$ ls data/ops-prototyp-mntr/soundscapepipe/ | wc -l
12742
More on file limits here: https://stackoverflow.com/questions/37135262/fat32-number-of-files-per-directory-limit