The problem is not the comma,comma; the problem is quoting. Regardless of which record and field delimiters you use, you need to be prepared for meeting them in the content. So you need a quoting mechanism. AND THEN you need a way for the quoting character(s) to appear too.
Following the RFC 4180 standard makes everything simpler for everybody.
I have personally had to write a script to probably fix the output from a program that got this wrong, so I am a bit militant about it. "probably fix" means that it worked for MY data, but I can see situations where it would fail. (In that programsprogram's defense, it was written before the standard.)