nodequeue.actions.inc not included when in maintenance mode or during update

I had a user report this error during an update:

An error occurred. http://localhost:8082/acquia-drupal/update.php?id=316&op=do <br /> <b>Fatal error</b>: Call to undefined function nodequeue_add_action() in <b>C:\Users\David\Sites\acquia-drupal-site\acquia-drupal\sites\all\modules\rules\rules\modules\rules.rules.inc</b> on line <b>352</b><br />

You can read through the whole issue, but essentially what happened is that the user has a rule setup to fire a nodequeue action on content update. My module's upgrade ended up calling a bunch of node_save()'s, and triggered the rule.

The function isn't found, because nodequeue.actions.inc is loaded via hook_init(). However, module_invoke_all('init') isn't called when running in maintenance mode or from update.php.

Ironically, I've also pulled my module's actions out into their own file, but I include it from the global scope of mymodule.module, just under the define() statements. If nodequeue were to do the same, this error wouldn't happen.