SAP implementation of RFC 1738

When looking over the ABAP implementation of RFC 1738 (don't ask) I noticed that SAP marks the following characters as unsafe and as a result URL encodes them:
"<, >, “, #, %, {, }, |, \, ^, ~, [, ], `" and ";, /, ?, :, @, =, &" (the ABAP code makes no distinction between the character set types of unsafe and reserved in its validation buffer, but I've separated them for clarity.)
The code also URL encodes characters LE 0x1F and GE 7F. This seems mostly correct, but it appears to be missing coma and $ which are both a part of RFC 1738 (to the best of my knowledge). I was unable to find a technote on this, but wanted to solicit some feedback on why this might be the case. Am I missing something, or does the SAP implementation of this standard appear to be slightly off? Any thoughts the development community has on this would be greatly appreciated.
Edit:
Just to clarify I'm specifically refering to the translate subroutine code in the program SAPLSCMS_URL. It defines the following as unsafe:
unsafe(23) value ' <>"#%{}|\^~[]`;/?:@=&+'.
These include all of the unsafe and reserved characters except for , and $.
Message was edited by:
        Aaron Jack

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