With the recent re-tuning of martial arts towards a semblance of sanity, I thought it pertinent to bring up an observation I consider pertinent. Judo, Wrestling and other fighting systems that heavily incorporate throws are practiced on thick mats and on people who have spent a lot of time training to fall safely.
Throw someone untrained, who has no concept of or desire to protect their head (ex: a zombie) onto concrete with the intention of breaking their skull and you are likely to succeed.
So I suggest, just as being sent flying by brutes and hulks checks to see if you landed on soft grass vs. asphalt, attacks that knock entities down should do the same. As getting tossed down a flight of stairs, over broken glass or onto the hood of a car holds a higher risk of being lethal.