For a non-system hard drive there is no need to run the error checker outside of Windows. The check would be exactly the same whichever way it was done.
The only reason that the error checker runs outside of Windows for a check of the system drive is because it cannot run while Windows is running from the disk that's being checked. Many system files are "locked" (in use) when Windows is running, so it wouldn't be possible to check them. That doesn't apply to drives which don't contain the OS.